No Child Left Behind Act: Education Actions Could Improve the	 
Targeting of School Improvement Funds to Schools Most in Need of 
Assistance (29-FEB-08, GAO-08-380).				 
                                                                 
Under the No Child Left Behind Act (NCLBA), the federal 	 
government provides millions of dollars annually to assist	 
schools that have not met state academic goals. In the 2006-2007 
school year, over 10,000 such schools were identified for	 
improvement. NCLBA requires states to set aside 4 percent of	 
their Title I funds to pay for school improvement efforts. GAO	 
was asked to determine (1) the extent to which states have set	 
aside these funds and used other resources for school		 
improvement, (2) which schools received improvement funds and the
extent funds are tracked, (3) the activities states and schools  
have undertaken and how activities are assessed, and (4) how	 
Education supports states' improvement efforts. GAO administered 
a survey to state education officials and received a 100 percent 
response rate, matched survey data to an Education database, and 
conducted site visits to five states.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-380 					        
    ACCNO:   A81169						        
  TITLE:     No Child Left Behind Act: Education Actions Could Improve
the Targeting of School Improvement Funds to Schools Most in Need
of Assistance							 
     DATE:   02/29/2008 
  SUBJECT:   Education						 
	     Education program evaluation			 
	     Educational grants 				 
	     Educational standards				 
	     Elementary education				 
	     Federal aid to states				 
	     Federal funds					 
	     Federal/state relations				 
	     Funds management					 
	     Program management 				 
	     School management and organization 		 
	     Schools						 
	     Secondary schools					 
	     State-administered programs			 
	     Statutory limitation				 
	     Program goals or objectives			 

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GAO-08-380

   

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material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

February 2008: 

No Child Left Behind Act: 

Education Actions Could Improve the Targeting of School Improvement 
Funds to Schools Most in Need of Assistance: 

GAO-08-380: 

GAO Highlights: 

Highlights of GAO-08-380, a report to congressional requesters. 

Why GAO Did This Study: 

Under the No Child Left Behind Act (NCLBA), the federal government 
provides millions of dollars annually to assist schools that have not 
met state academic goals. In the 2006-2007 school year, over 10,000 
such schools were identified for improvement. NCLBA requires states to 
set-aside 4 percent of their Title I funds to pay for school 
improvement efforts. GAO was asked to determine (1) the extent to which 
states have set aside these funds and used other resources for school 
improvement; (2) which schools received improvement funds and the 
extent funds are tracked; (3) the activities states and schools have 
undertaken and how activities are assessed; and (4) how the Department 
of Education supports statesï¿½ improvement efforts. GAO administered a 
survey to state education officials and received a 100 percent response 
rate, matched survey data to an Education database, and conducted site 
visits to five states. 

What GAO Found: 

A statutory requirementï¿½known as a hold-harmless provisionï¿½has limited 
some statesï¿½ ability to target the full 4 percent of Title I funds for 
school improvement to low-performing schools. However, many states have 
used other federal and state funds for this purpose. While this 
provision is designed to protect school districts from reductions in 
their Title I funding, it has also kept 22 states from setting aside 
the full portion of Title I school improvement funds since 2002 because 
they did not have enough funds to do so after satisfying the hold-
harmless provision. To address this, Education has proposed repealing 
the hold-harmless provision. However, it is not known how removing this 
provision would affect districts protected by it. In addition to Title 
I school improvement funds, 38 states have dedicated other federal 
funds, and 17 have contributed state funds for school improvement. 

Though states generally target improvement funds to the most 
persistently under performing schools, some states did not fulfill key 
NCLBA requirements. Specifically, 4 states did not follow all 
requirements to ensure that schools most in need of assistance received 
funds. Although Education monitors how states allocate improvement 
funds, it did not identify this issue. Also, 4 states were unable to 
provide a complete list of schools that received improvement funds, as 
required by law. Education has not provided guidance on this 
requirement and does not monitor compliance with it. 

Schools and states are engaged in a variety of improvement activities, 
and most states use student data and feedback to assess activities. 
Most states reported that schools receiving improvement funds used the 
funds for professional development and for reorganizing curriculum or 
instruction time. Nearly all states assisted schools with school 
improvement plans and professional development. Most states use student 
achievement data and feedback from schools and districts to assess 
improvement activities. 

Education provides a range of support for school improvement, including 
technical assistance and research results. Nearly all states want more 
help, such as more information on promising improvement practices. 
Education has a new Web site to provide additional resources and plans 
to collect more information on promising practices through a new grant 
program. 

Figure: Number of States That Could and Could Not Set Aside Full 4 
Percent of Title I Funds for School Improvement Due to the Hold-
Harmless Provision, 2004-2007: 

[See PDF for image] 

This figure is a multiple vertical bar graph depicting the following 
data: 

Fiscal year: 2004; 
Number of states, 4 percent: 39; 
Number of states, less than 4 percent: 9. 

Fiscal year: 2005; 
Number of states, 4 percent: 38; 
Number of states, less than 4 percent: 12. 

Fiscal year: 2006; 
Number of states, 4 percent: 38; 
Number of states, less than 4 percent: 12. 

Fiscal year: 2007; 
Number of states, 4 percent: 39; 
Number of states, less than 4 percent: 11. 

Source: GAO survey of states. 

[End of figure] 

What GAO Recommends: 

GAO recommends that Education review its monitoring to ensure that 
states comply with NCLBA requirements for allocating school improvement 
funds for district-level activities and prioritizing funds to the 
lowest achieving schools; provide guidance on when and how states are 
to make information available about which schools receive improvement 
funds; and analyze the effects of removing a hold-harmless provision on 
those districts protected by it. Education agreed with these 
recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.GAO-08-380]. For more information, contact 
Cornelia Ashby at (202) 512-7215 or [email protected]. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

A Statutory Requirement Limits Some States' Ability to Target Title I 
School Improvement Funds to Lowest-Performing Schools, but Many States 
Have Used Other Resources for School Improvement Efforts: 

States Generally Target Funds to the Most Persistently Underperforming 
Schools, However, Some States Did Not Fulfill NCLBA Requirements for 
Allocating or Tracking Funds: 

Schools and States Are Engaged in a Variety of Improvement Activities 
and Mainly Assess Them Using Student Achievement Data and Feedback: 

Education Provides a Range of Support for School Improvement, Including 
Some New Efforts Aimed at Areas in Which States Want More Help: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of Education: 

Appendix III: GAO Contacts and Acknowledgments: 

Related GAO Products: 

Tables: 

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

Table 2: NCLBA Technical Assistance Districts Are Required to Ensure 
for Schools Identified for Improvement: 

Table 3: Federal Programs Related to School Improvement: 

Table 4: Characteristics of the 12 States Unable to Set Aside the Full 
4 Percent of Title I Funds for School Improvement, Fiscal Year 2006: 

Table 5: Changes in Title I School Improvement Set-aside, Fiscal Years 
2005-2007: 

Table 6: State Funds for School Improvement under NCLBA, Fiscal Year 
2006: 

Table 7: Selected Characteristics of Schools That Received Title I 
School Improvement Funds, Other Schools Identified for Improvement, and 
All Other Title I Schools, Fiscal Year 2006: 

Table 8: School Districts Selected for Site Visits: 

Figures: 

Figure 1: Title I Grants to Local Education Agencies, 2001-2007: 

Figure 2: Distribution of Title I Set-aside Funds for School 
Improvement: 

Figure 3: States' Title I School Improvement Set-aside Portions since 
2002: 

Figure 4: States' Average Title I Set-aside Amounts Available per 
School Identified for Improvement, Fiscal Year 2006: 

Figure 5: Median Title I School Improvement Allocations by Improvement 
Status, Fiscal Year 2005: 

Figure 6: States' Methods for Allocating School Improvement Funds, 
Fiscal Year 2006: 

Figure 7: Number of States That Reserved Less than 5 Percent, 5 
Percent, or More than 5 Percent of School Improvement Funds for Their 
Statewide System of Support: 

Figure 8: Differences in Types of Assistance States Provided to Schools 
in Different Stages of Improvement: 

Figure 9: Example of a Middle School's Data Room to Track Students' 
Progress: 

Figure 10: Education's Technical Assistance and Research-Related 
Resources That Support School Improvement Efforts: 

Figure 11: Extent to Which States Found Assistance from Education 
Helpful: 

Abbreviations: 

AYP: adequate yearly progress: 

CCD: Common Core of Data: 

CSR: Comprehensive School Reform: 

CSPR: Consolidated State Performance Reports: 

ESEA: Elementary and Secondary Education Act of 1965: 

IASA: Improving America's Schools Act of 1994: 

NCES: National Center for Education Statistics: 

NCLBA: No Child Left Behind Act of 2001: 

SES: supplemental educational services: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

February 29, 2008: 

The Honorable Tom Harkin: 
Chairman: 
The Honorable Arlen Specter: 
Ranking Member: 
Subcommittee on Labor, Health and Human Services, Education, and 
Related Agencies: 
Committee on Appropriations: 
United States Senate: 

Over the past 40 years, the federal government has invested billions of 
dollars annually in grants to states and school districts to improve 
educational opportunities for economically disadvantaged students. The 
most recent reauthorization of the Elementary and Secondary Education 
Act of 1965 (ESEA), known as the No Child Left Behind Act of 2001 
(NCLBA), sought to hold schools, districts, and states accountable for 
student progress.[Footnote 1] Specifically, states are required to 
develop academic standards and tests, measure student proficiency in 
certain grades and subjects, and determine whether schools are meeting 
proficiency goals. Schools that fail to meet state academic goals for 2 
or more years are to be identified for improvement and are required to 
take a series of actions intended to improve student performance. The 
number of schools identified for improvement under NCLBA increased from 
about 8,400 in school year 2004-2005 to over 10,700 in 2006-2007, and 
if this trend continues, more schools will be identified for 
improvement in the future. To assist these schools, NCLBA requires 
states to set aside 4 percent of their Title I funds to help pay for 
school improvement efforts, which in fiscal year 2005-2006 totaled 
close to $500 million nationally. States are required to target funds 
to districts that serve the lowest achieving schools, have the greatest 
need for assistance, and are committed to using funds to help their 
lowest performing schools meet annual goals.[Footnote 2] However, the 
availability of these funds may be limited because of a hold-harmless 
provision that prevents states from giving any district less Title I 
funds than it did in the previous year as a result of setting aside 
improvement funds.[Footnote 3] 

While states have spent over a billion federal dollars on school 
improvement since NCLBA was enacted in 2002, questions remain about how 
Title I school improvement dollars are allocated and expended, or the 
types of improvement activities schools use and find effective. 
Further, in a report accompanying the fiscal year 2006 appropriations 
bill for the Department of Education (Education) and other departments, 
the Senate Appropriations Committee expressed concern about the hold- 
harmless provision and its effect on high-poverty districts as well as 
states' ability to set aside the full 4 percent.[Footnote 4] To shed 
light on these issues and to assist Congress in the reauthorization and 
funding of NCLBA, you asked GAO to determine (1) the extent to which 
states have been able to set aside Title I school improvement funds and 
dedicated other federal and state funds to school improvement since 
NCLBA was enacted, (2) the schools to which states targeted school 
improvement funds and the extent to which these funds are tracked, (3) 
the types of activities that states and schools have undertaken to 
improve schools and how the these strategies are being assessed, and 
(4) how Education provides support to help states make the best use of 
school improvement funds. 

To do this work, we administered a survey to state education agency 
officials in all 50 states and the District of Columbia between July 
and October 2007 and received a 100 percent response rate. Because 
national information is not available on states' expenditures of school 
improvement funds, we collected this information through our survey. In 
addition, we requested information from each state on the schools 
receiving improvement funds and linked data on these schools to 
Education's Common Core of Data (CCD) to identify school 
characteristics. Three states were unable to provide this information, 
and 1 state provided partial information, so our data on school 
characteristics are presented for only those states that provided this 
information.[Footnote 5] We reviewed both the survey data and the lists 
of schools receiving improvement funds for obvious inconsistencies, 
errors, and completeness. When we found discrepancies, we brought them 
to the attention of state officials and worked with them to correct the 
discrepancies before conducting our analyses. On the basis of these 
efforts, we determined that the survey data and lists of schools were 
sufficiently reliable for the purposes of this report. We also 
conducted site visits to 5 states--California, Georgia, Michigan, New 
Mexico, and Ohio--which were selected based on having high percentages 
of schools identified for improvement, variation in Title I set-aside 
funding allocation methods and administrative structures, and 
geographic diversity. We met with state officials in each state and, to 
understand the local perspective, we met with officials in 12 districts 
and 22 schools. Districts and schools were selected to provide variety 
in student demographics, locale, and stage of improvement.[Footnote 6] 
We interviewed Education officials and reviewed relevant federal laws, 
guidance, and monitoring tools to learn about federal requirements for 
school improvement funds and efforts to monitor these funds and 
activities. We also interviewed officials from national interest groups 
and researchers and reviewed published research and reports about 
school improvement funding and activities. See appendix I for more 
information about our survey and other data collection methods. We 
conducted our work from January 2007 through February 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Results in Brief: 

A statutory requirement has limited some states' ability to target the 
full 4 percent of Title I funds for school improvement to low- 
performing schools. However, many states have used other federal and 
state funds for this purpose. While the 4 percent set aside does not 
affect the total amount of Title I funds a state receives, the 
statutory requirement known as the hold-harmless provision can affect 
how those funds are allocated within a state. Specifically, when states 
set-aside funds for school improvement, the hold-harmless provision 
prevents the state from reducing the Title I funding for any school 
district from the previous year. Sometimes, after taking into 
consideration the hold-harmless provision, there are not enough funds 
available from those districts with increasing Title I allocations to 
cover the full 4 percent set-aside. Specifically, we found that 22 
states have been unable to set aside the full 4 percent of Title I 
funds for 1 or more years since NCLBA was enacted because of the hold- 
harmless provision. Six of these--Florida, Kansas, Kentucky, Maine, 
Massachusetts, and Michigan--have been unable to set aside the full 
amount for 3 or more years. The change in available funds from year to 
year can make it difficult for affected states to provide steady 
assistance to schools in need of improvement, and some states have held 
back funds in some years to ensure that funds would be available in the 
future. Education, recognizing challenges associated with the hold- 
harmless provision, has proposed repealing the provision in the past 
and has raised this issue again as part of its proposed revisions to 
NCLBA, which is currently being considered for reauthorization. In 
addition to the Title I funds for school improvement, 38 states have 
dedicated other federal funds, and 17 have contributed state funds to 
school improvement efforts. Since 2002, state funds supporting school 
improvement activities have totaled almost $2.6 billion, compared to 
nearly $1.3 billion in Title I improvement funds nationwide for this 
period. 

Though states generally target improvement funds to the most 
persistently underperforming schools, some states did not fulfill all 
NCLBA requirements for allocating or tracking funds. Overall, we found 
that in 2006 states provided schools in restructuring nationwide a 
median grant of about $40,000 more than for schools in corrective 
action. In addition, schools that received Title I school improvement 
funds had higher percentages of low-income and minority students than 
all other Title I schools. To allocate school improvement funds, 37 
states used state-established criteria, which included factors such as 
the number of years schools have been identified as needing 
improvement; 2 states used a competitive grant process; and 8 used some 
other method. However, we found that 4 states reported that they 
required funds be allocated equally to schools and may not have taken 
into consideration factors required by NCLBA, such as focusing on the 
lowest-achieving schools. In addition, during our site visits, we found 
that 1 state allocated Title I improvement funds to districts in 
improvement with no schools in improvement without determining first 
that it had excess improvement funds, as required by NCLBA. We referred 
this issue to Education for follow-up. Although Education monitors how 
states allocate improvement funds, it did not identify these issues 
during its state monitoring efforts. Also, 4 states could not provide 
the required list of all schools in their state that received 
improvement funds. Education has not provided guidance on how states 
should make lists of schools receiving funds publicly available and 
does not monitor states' compliance with this requirement. 

Schools and states that received funds have undertaken a variety of 
improvement activities, and most states assess these activities through 
reviewing changes in student achievement and feedback from district and 
school officials. For school year 2006-2007, 45 states reported that 
schools that received improvement funds were engaged in professional 
development, reorganizing curriculum or instructional time, or data 
analysis using student assessment information. Schools in all 5 states 
we visited cited the importance of professional development, and 
several noted that school improvement funds helped them participate in 
training that would not have been available otherwise. Nearly all 
states reported that they help schools identified for improvement with 
school improvement plans and professional development, and officials in 
42 states consider this assistance key to helping schools improve. For 
some activities, such as support from school support teams, more states 
provided this assistance to schools in corrective action or 
restructuring than to those required to offer public school choice and 
supplemental educational services. To assess school improvement 
activities, 42 states reported that they analyze student achievement 
data or track school performance trends, and 36 of those states also 
use feedback from school and district officials. 

Education provides various forms of support related to school 
improvement, including some new efforts aimed at areas in which states 
want more help. Education staff provide direct assistance with school 
improvement to states through written guidance, policy letters, and 
national meetings or conferences. Education also offers support through 
its comprehensive centers, which provide technical assistance and 
research results to states on developing approaches for improving 
schools. In addition, Education provides information on school 
improvement strategies through its Web-based What Works Clearinghouse. 
State officials reported that Education's written guidance, nationwide 
comprehensive centers, and national conferences were the most helpful 
forms of assistance and the What Works Clearinghouse was relatively 
less helpful. Some state and district officials we visited said that it 
is difficult to figure out how to translate the research on the 
clearinghouse into practical application in the classroom. At the same 
time, 48 states also reported that they could benefit from more 
assistance such as additional national or regional meetings to share 
lessons learned and promising practices. Education has begun some new 
efforts that are aimed at addressing these areas, including the 
development of a Web site to provide additional resources intended to 
help educators adapt and use the research-based practices on the What 
Works Clearinghouse. In addition, Education is planning to collect 
information on how states assess school improvement activities as part 
of a new school improvement grants program that was authorized under 
NCLBA but was funded for the first time in 2007. 

To enhance state efforts to target school improvement funds to schools 
most in need of assistance, we recommend that Education review the 
Title I monitoring process to ensure that steps are in place to ensure 
that states comply with requirements in the statute for allocating 
funds to districts for district-level activities and prioritizing funds 
to the lowest-achieving schools. We also recommend that Education 
provide guidance to clarify when and how states are to make information 
about which schools receive Title I improvement funds available and 
track state compliance with this requirement. Finally, to provide 
further support for its proposal to eliminate the hold-harmless 
provision, we recommend that Education develop an analysis comparing 
the characteristics of districts that contribute to the set-aside with 
those protected by the hold-harmless provision. Education agreed with 
our recommendations and stated it would explore options for analyzing 
additional data related to eliminating the hold-harmless provision, 
improving its monitoring process, and providing additional guidance to 
states regarding disclosure of schools receiving Title I improvement 
funds. Education also identified some of the steps it has taken to 
collect additional information on the allocation and use of school 
improvement funds and to identify successful school improvement 
strategies. 

Background: 

Under NCLBA, states are required to hold their Title I schools 
accountable for students' performance by developing academic standards 
and tests, measuring student proficiency in certain grades and 
subjects, and determining whether schools are meeting proficiency 
goals. Schools that have not met state established goals for 2 or more 
consecutive years are identified as in need of improvement and must 
implement certain activities meant to improve student academic 
achievement. NCLBA also requires states to set aside Title I funds to 
assist schools in implementing improvement activities. 

Title I: 

Title I of the Elementary and Secondary Education Act (ESEA), as 
amended and reauthorized by NCLBA, authorizes federal funds to help 
elementary and secondary schools establish and maintain programs that 
will improve the educational opportunities of economically 
disadvantaged children.[Footnote 7] Title I is the largest federal 
program supporting education in kindergarten through 12th grade, 
supplying an estimated $12.8 billion in federal funds in fiscal year 
2007. Appropriations for Title I grew rapidly in the years following 
the enactment of NCLBA, from about $8.8 billion in fiscal year 2001 to 
$12.3 billion in 2004. However, Title I funding growth slowed between 
2004 and 2007. (See fig. 1.) Title I funds are allocated through state 
educational agencies to districts using statutory formulas based 
primarily on Census Bureau estimates of the number of students from 
families below the poverty line in each district. States retain a share 
for administration and school improvement activities before passing 
most of the funds on to school districts. In turn, districts are 
required to allocate Title I funds first to schools with poverty rates 
over 75 percent in rank order, with any remaining funds distributed at 
their discretion to schools in rank order of poverty either 
districtwide or within grade spans. A school's Title I status can 
change from year to year because school enrollment numbers and 
demographics vary over time, and annual allocations to districts under 
Title I formulas can vary considerably. 

Figure 1: Title I Grants to Local Education Agencies, 2001-2007: 

[See PDF for image] 

This figure is a line graph depicting the following data: 

Fiscal year: 2001; 
Dollars in billions: $8.762. 

Fiscal year: 2002; 
Dollars in billions: $10.35. 

Fiscal year: 2003; 
Dollars in billions: $11.668. 

Fiscal year: 2004; 
Dollars in billions: $12.342. 

Fiscal year: 2005; 
Dollars in billions: $12.739. 

Fiscal year: 2006; 
Dollars in billions: $12.713. 

Fiscal year: 2007; 
Dollars in billions: $12.838. 

[End of figure] 

School Improvement under NCLBA: 

In 2002, NCLBA added several new provisions to the ESEA, as amended, to 
strengthen accountability of all schools identified for improvement, 
which included requiring states to develop academic achievement 
standards and establish proficiency goals for making adequate yearly 
progress (AYP) that will lead to 100 percent of their students being 
proficient in reading, mathematics, and science by 2014.[Footnote 8] To 
measure their progress, states administer an annual assessment to 
students in most grade levels.[Footnote 9] 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 performance goals. 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. 

The last reauthorization of ESEA prior to NCLBA--the Improving 
America's Schools Act of 1994 (IASA)--required that schools be 
identified for improvement if they did not make AYP for 2 consecutive 
years and that they take certain actions to improve student 
performance. NCLBA also includes a timeline for implementing specific 
interventions based on the number of years a school fails to make AYP 
and adds some interventions that were not required under IASA. (See 
table 1.) Under NCLBA, schools that fail to make AYP for 2 consecutive 
years are identified for improvement and must develop an improvement 
plan in consultation with the district, school staff, parents, and 
outside experts. This plan, which is subject to district approval, must 
incorporate strategies to address the specific academic issues that 
caused the school to be identified for improvement. At this stage 
districts also must offer students in the school the opportunity to 
transfer to a higher-performing public school in the district--an 
option that is called offering public school choice. After the third 
year, districts must also offer supplemental educational services 
(SES), such as tutoring. 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 law, such as implementing a new curriculum or 
extending the school year or day. Finally, if a school fails to make 
AYP for 5 or more years it must make plans to restructure its 
governance and implement those plans. Schools exit improvement status 
if they make AYP for 2 consecutive years. In addition, all schools 
identified for improvement are required to spend at least 10 percent of 
their Title I funds on professional development for the school's 
teachers and principal as appropriate. 

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

Adequate yearly progress: First year missed; 
School status in the next year: Not applicable; 
NCLBA interventions for Title I schools: None. 

Adequate yearly progress: Second year missed; 
School status in the next year: Public school choice (first year of 
improvement); 
NCLBA interventions for Title I schools: Required to offer public 
school choice[A]. 

Adequate yearly progress: Third year missed; 
School status in the next year: SES (second year of improvement); 
NCLBA interventions for Title I schools: Required to offer public 
school choice and SES. 

Adequate yearly progress: Fourth year missed; 
School status in the next year: Corrective action (third year of 
improvement); 
NCLBA interventions for Title I schools: Implement certain corrective 
actions and offer public school choice and SES. 

Adequate yearly progress: Fifth year missed; 
School status in the next year: Planning for restructuring (fourth year 
of improvement); 
NCLBA interventions for Title I schools: Plan for a change in 
governance and offer public school choice and SES[B]. 

Adequate yearly progress: Sixth year missed; 
School status in the next year: Implementation of restructuring (fifth 
year of improvement); 
NCLBA interventions for Title I schools: Implement a change in 
governance and offer public school choice and SES. 

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

[A] At this stage, the school must also develop the school improvement 
plan. 

[B] While 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. 

[End of table] 

Both Districts and States Provide Technical Assistance to Schools in 
Improvement: 

School districts bear the primary responsibility for ensuring that 
their schools in improvement receive technical assistance. 
Specifically, districts 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 2. 

Table 2: NCLBA Technical Assistance Districts Are Required to Ensure 
for Schools Identified for Improvement: 

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: 
* instructional deficiencies; 
* parental involvement and professional development requirements, and: 
* implementing the school improvement plan. 

Identification and implementation of strategies: The district must 
ensure that the school receives help to identify and implement: 
* instructional strategies and methods that are grounded in 
scientifically based research and address specific issues that caused 
the school to be identified for improvement; 
* professional development relevant to implementation of such 
strategies and methods. 

Budget analysis: The district must ensure that the school is provided 
with: 
* assistance in analyzing and revising its budget to fund activities 
most likely to increase student academic achievement. 

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

[End of table] 

States provide technical assistance to districts and schools through 
their statewide systems of support, with a priority given to those in 
improvement status. In developing their statewide system of support, 
the state educational agency must (1) establish school support teams 
that include individuals who are knowledgeable about scientifically 
based research and practice to assist schools throughout the state that 
are identified for improvement in areas such as strengthening 
instructional programs; (2) designate and use distinguished teachers 
and principals who are chosen from Title I schools and have been 
especially successful in improving academic achievement; and (3) 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. 

States Are Required to Set Aside a Percentage of Their Title I Funds to 
Support School Improvement Activities: 

NCLBA requires states to set aside a portion of Title I funds to 
allocate to districts for use by and for schools for school improvement 
activities and to carry out the state's responsibilities for school 
improvement. In fiscal years 2002 and 2003, states were required to 
reserve 2 percent of the Title I funds for school improvement, and in 
fiscal years 2004 to 2007, states were required to reserve 4 percent. 
[Footnote 10] However, states may not always be able to reserve the 
full amount for school improvement because of a hold-harmless provision 
that prevents states from reducing the amount of Title I funds any 
district receives from what it received the prior year. The hold-
harmless provision is intended to protect school districts from 
declines in Title I funding from year to year, by preventing the state 
from giving them less funds than the year before. If the total increase 
in Title I funds from districts with increasing allocations is less 
than 4 percent of a state's total Title I allocation, then that state 
would not be able to set aside the full 4 percent of Title I funds for 
school improvement. 

States are generally required to allocate 95 percent of the 4 percent 
set-aside to districts for schools identified for improvement. States 
may use the remaining 5 percent of the 4 percent set-aside to carry out 
their responsibilities related to school improvement, including 
creating and maintaining their statewide system of support.[Footnote 
11] (See fig. 2.) NCLBA establishes priorities and requirements for the 
distribution of school improvement funds to districts. Specifically, 
under NCLBA states must give funding preference to districts that serve 
the lowest-achieving schools, demonstrate the greatest need for 
assistance, and demonstrate the strongest commitment to using the funds 
to assist their lowest-performing schools with meeting progress 
goals.[Footnote 12] States may either allocate these funds directly to 
districts for schools identified for improvement to be used for 
activities required under the school improvement section of the law or, 
with the permission of districts, retain funds to provide for these 
activities for schools identified for improvement. [Footnote 13] 

Figure 2: Distribution of Title I Set-aside Funds for School 
Improvement: 

[See PDF for image] 

This figure contains a pie-chart as well as a sub-chart depicting the 
following information: 

Distribution of Title I Set-aside Funds for School Improvement: 
* Set-aside for the School Improvement Fund: 4%; 
- School Improvement Fund for schools identified for improvement: 95% 
of the 4%; 
- School Improvement Fund for the statewide system of support: 5% of 
the 4%; 
* Other Title I Funds: 96%. 

Source: GAO analysis of No Child Left Behind Act. 

[End of figure] 

While NCLBA directs 95 percent of improvement funds to schools through 
districts, some flexibility exists for funds to be used at the state or 
district level for improvement-related activities. For example, NCLBA 
gives states authority to use some of the 95 percent funds at the 
district level if the state determines that it has more funding than 
needed to provide assistance to schools in improvement. In addition, 
states may use some of their 5 percent funds generally retained at the 
state level for districts to support district-level activities. 

Among other requirements regarding the allocation of funds, states are 
required to make publicly available a list of the schools that have 
received funds or services from the school improvement set-aside and 
the percentage of students in each of these schools from families with 
incomes below the poverty line.[Footnote 14] 

Other Funds States May Use for School Improvement Activities: 

In addition to the Title I set-aside, Education officials told us that 
states may use state funds for school improvement or incorporate other 
federal funds to support school improvement efforts, including the 
School Improvement Grant Program under NCLBA,[Footnote 15] 
Comprehensive School Reform, Reading First, and Title II teacher and 
principal quality programs (see table 3). These programs either 
establish funding priorities for schools identified for improvement or 
allow for state flexibility to establish such priorities. 

Table 3: Federal Programs Related to School Improvement: 

Program: School Improvement Grant Program; 
Purpose and connection to school improvement: Authorizes states to make 
grants to school districts for improvement activities. Grants can be 
$50,000-$500,000 for each school. This program received appropriations 
for the first time in 2007; 
Statutory priorities: Districts to address schools identified as being 
in improvement, corrective action, and restructuring. 

Program: Comprehensive School Reform; 
Purpose and connection to school improvement: Provide financial 
incentives for schools to develop comprehensive school reforms based on 
scientifically based research and effective practices that include an 
emphasis on basic academics and parental involvement so that all 
children can meet challenging state academic content and academic 
achievement standards; 
Statutory priorities: Districts that plan to use the funds in schools 
identified as being in need of improvement or corrective action. 

Program: Reading First; 
Purpose and connection to school improvement: To provide assistance to 
states and districts to establish reading programs in grades 
kindergarten through third grade; prepare teachers; administer 
assessments; develop and select materials; programs and strategies; and 
strengthen coordination among schools, early literacy programs, and 
family literacy programs to improve reading achievement; 
Statutory priorities: Districts in which at least 15 percent of the 
children or 6,500 children are from families with incomes below the 
poverty line. 

Program: Title II teacher and principal training programs; 
Purpose and connection to school improvement: To increase student 
academic achievement through strategies such as improving teacher and 
principal quality and increasing the number of highly qualified 
teachers in the classroom and highly qualified principals and assistant 
principals in schools, and to hold districts and schools accountable 
for improvements in student academic achievement; 
Statutory priorities: Schools that have the lowest proportion of highly 
qualified teachers, the largest average class size, or are identified 
for school improvement. 

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

[End of table] 

Education Oversees School Improvement Funds through Compliance 
Monitoring: 

Education oversees how states allocate school improvement funds as part 
of its overall monitoring of state compliance with Title I and NCLBA. 
Education monitors states in two ways: (1) by routinely gathering and 
analyzing data collected from Web-based searches and documents, such as 
the Consolidated State Performance Reports,[Footnote 16] and (2) by 
conducting on-site visits to state educational agencies and selected 
districts and schools within each state to interview officials and 
review relevant documents. Education has a 3-year monitoring cycle for 
visiting each state. During these visits, Education reviews whether 
states provide guidance to districts related to the use of school 
improvement funds and activities and how the state monitors school 
improvement plans. Education's monitoring guide includes specific 
questions about how the state allocated school improvement funds, 
whether all the funds have been spent, and what guidance the state 
provided to districts--and was recently updated to include some 
additional questions on whether states are monitoring expenditures of 
school improvement funds at the school level and assisting schools in 
effectively using their resources to make AYP and exit improvement 
status. 

A Statutory Requirement Limits Some States' Ability to Target Title I 
School Improvement Funds to Lowest-Performing Schools, but Many States 
Have Used Other Resources for School Improvement Efforts: 

The hold-harmless provision, which is designed to protect school 
districts from reductions in their Title I funding, prevented some 
states from being able to target school improvement funds to low- 
performing schools. However, many states have used other federal and 
state funds for school improvement efforts. The hold-harmless provision 
prioritizes maintaining the Title I funding of all eligible districts 
over ensuring that states can set aside the full 4 percent for schools 
identified for improvement--the lowest performing schools. Twenty-two 
states have been unable to set aside the full 4 percent of Title I 
funds for school improvement for 1 or more years since NCLBA was 
enacted because they did not have enough funds to do so after 
satisfying the hold-harmless provision. Schools identified for 
improvement are, by definition, performing worse than other schools-- 
and may be among the neediest. When states cannot set aside the full 4 
percent for school improvement, it is difficult for them to plan and 
provide consistent assistance to these schools. In addition to Title I 
funds for school improvement, many states have dedicated other federal 
funds and state funds to school improvement efforts. In the period 
since NCLBA was enacted, state funds used for this purpose totaled 
almost $2.6 billion, compared to $1.3 billion in federal Title I funds. 

A Statutory Requirement Limits Some States' Ability to Target School 
Improvement Funds to the Lowest-Performing Schools: 

While the hold-harmless provision is designed to protect school 
districts from reductions in their Title I funding, it has prevented 
some states from being able to set aside the full amount of funds for 
school improvement, which are intended for the lowest-performing 
schools. While the total amount of Title I funds a state receives does 
not decrease in any one year as a result of calculating the 4 percent 
set-aside, the hold-harmless provision can affect how those funds are 
allocated within a state.[Footnote 17] Specifically, when states set 
aside funds for school improvement, the hold-harmless provision 
prevents the state from reducing the Title I funding for any school 
district from the previous year. Sometimes, after taking into 
consideration the hold-harmless provision, there are not enough funds 
available from those districts with increasing Title I allocations to 
cover the full 4 percent set-aside. Specifically, 22 states have been 
unable to set aside the full portion of Title I funds for school 
improvement for 1 or more years since NCLBA was enacted because they 
did not have enough left over after satisfying the hold-harmless 
provision.[Footnote 18] Six of these--Florida, Kansas, Kentucky, Maine, 
Massachusetts, and Michigan--have been unable to set aside the full 
amount for 3 or more years. (See fig. 3). Title I allocations are 
distributed through states to school districts based on poverty levels, 
and the hold-harmless provision protects districts from receiving less 
than they received the previous year. In other words, if a district's 
population of low-income students decreases, the hold-harmless 
provision ensures that a district does not receive less Title I funds 
than the previous year as a result of the school improvement set- 
aside.[Footnote 19] Consequently, states can only set aside funds for 
school improvement that would otherwise have been allocated to school 
districts slated for Title I increases. In addition to the 22 states 
affected by the hold-harmless provision, 4 states did not set aside the 
full portion of Title I school improvement funds for other reasons. For 
example, 1 state reported that it did not set aside the entire set- 
aside amount because it had few schools identified for improvement. In 
2006, 12 states were unable to set aside the full 4 percent of Title I 
funds for school improvement due to the hold-harmless provision, with 
set-asides ranging from as little as 0.2 percent in Kansas to 3.75 
percent in Florida. 

Figure 3: States' Title I School Improvement Set-aside Portions since 
2002: 

[See PDF for image] 

This figure is a map of the United States indicating Title I School 
Improvement set-aside portions since 2002. States are indicated as 
being in one of six categories as follows: 

States able to set aside full portion each year: 
Alabama; 
Alaska; 
Arizona; 
Colorado; 
Georgia; 
Hawaii; 
Illinois; 
Indiana; 
Maryland; 
Mississippi; 
Nebraska; 
New Hampshire; 
New York; 
New Jersey; 
North Carolina; 
Pennsylvania; 
South Carolina; 
South Dakota; 
Tennessee; 
Texas; 
Utah; 
Washington; 
Wisconsin; 
Wyoming. 

States unable to set aside funds for 1 year due to hold-harmless 
provision: 
California; 
Louisiana; 
Minnesota; 
Montana; 
North Dakota; 
Ohio; 
Oklahoma; 
Rhode Island; 
Vermont. 

States unable to set aside funds for 2 years due to hold-harmless 
provision: 
Connecticut; 
Delaware; 
Iowa; 
Missouri; 
Oregon; 
New Mexico; 
West Virginia. 

States unable to set aside funds for 3 plus years due to hold-harmless 
provision: 
Florida; 
Kansas; 
Kentucky; 
Maine; 
Michigan; 
Massachusetts. 

States that did not set aside full portion for other reasons for 1 or 
more years: 
Arkansas; 
District of Columbia; 
Idaho; 
Nevada. 

Data not available: 
Virginia. 

Source: GAO survey of states; Copyright ï¿½ Corel Corp. All rights 
reserved (map). 

Note: Virginia did not provide information on the Title I school 
improvement set-aside. 

[End of figure] 

The lowest-performing schools--schools identified for improvement--are 
affected when states cannot set aside the full 4 percent for school 
improvement. These schools--which are the targets of the school 
improvement funding--have failed to meet state performance goals and 
are, by definition, performing worse than other schools. Effectively, 
the hold-harmless provision prioritizes preserving the Title I funding 
of all eligible Title I districts over ensuring that the lowest- 
performing schools receive funds for school improvement. Furthermore, 
schools identified for improvement may be among the neediest. In fiscal 
year 2006, schools identified for improvement in the 12 states that 
were unable to set aside the full 4 percent had higher average 
percentages of students in poverty and minority students compared to 
other Title I schools that were in need of improvement in those states. 
(See table 4): 

Table 4: Characteristics of the 12 States Unable to Set Aside the Full 
4 Percent of Title I Funds for School Improvement, Fiscal Year 2006: 

Selected student characteristics[A]: Poverty status; 
Schools identified for improvement that received Title I school 
improvement funds: Mean percentage of students: 72; 
All other schools identified for improvement that did not receive Title 
I school improvement funds: Mean percentage of students: 62; 
All other Title I schools not identified for improvement: Mean 
percentage of students: 53. 

Selected student characteristics[A]: Minority status; 
Schools identified for improvement that received Title I school 
improvement funds: Mean percentage of students: 64; 
All other schools identified for improvement that did not receive Title 
I school improvement funds: Mean percentage of students: 54; 
All other Title I schools not identified for improvement: Mean 
percentage of students: 30. 

Selected school characteristics: Locale: Urban; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 57; 
All other schools identified for improvement that did not receive Title 
I school improvement funds: Percentage of schools: 64; 
All other Title I schools not identified for improvement: Percentage of 
schools: 22. 

Selected school characteristics: Locale: Suburban; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 19; 
All other schools identified for improvement that did not receive Title 
I school improvement funds: Percentage of schools: 28; 
All other Title I schools not identified for improvement: Percentage of 
schools: 28. 

Selected school characteristics: Locale: Town/rural; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 24; 
All other schools identified for improvement that did not receive Title 
I school improvement funds: Percentage of schools: 8; 
All other Title I schools not identified for improvement: Percentage of 
schools: 50. 

Selected school characteristics: Locale: Total; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 100; 
All other schools identified for improvement that did not receive Title 
I school improvement funds: Percentage of schools: 100; 
All other Title I schools not identified for improvement: Percentage of 
schools: 100. 

Source: GAO analysis of Education data. 

[A] The table shows the mean percentages of students who are members of 
racial or ethnic minority groups (minority status) or who qualified for 
free or reduced price meals (poverty status). 

[End of table] 

When states cannot set aside the full portion of Title I funds for 
school improvement, it is difficult for states to provide consistent 
assistance to schools identified for improvement. States that were 
unable to set aside the full 4 percent for school improvement 
experienced large decreases in their school improvement funds from year 
to year compared to all other states. (See table 5.) For example, Ohio 
officials told us that they experienced a decline of $14 million in 
Title I allocations to districts between fiscal years 2004 and 2005 due 
to a decrease in census estimates of the number of low-income students. 
Since the state still had to provide all districts with no less Title I 
funds than the year before, it set aside 58 percent, or $9.3 million, 
less in school improvement funds than it had in the previous year. An 
Ohio official said this variability made it difficult to commit school 
improvement assistance to districts. To address this issue, Ohio now 
retains a portion of its total Title I school improvement set-aside 
each year to help ensure that school improvement funds will be 
available if there are future decreases in school improvement funds as 
a result of the hold-harmless provision.[Footnote 20] 

Table 5: Changes in Title I School Improvement Set-aside, Fiscal Years 
2005-2007: 

States unable to set aside the full 4 percent for school improvement: 
Number of states: States unable to set aside the full 4 percent for 
school improvement: Median dollar change: States unable to set aside 
the full 4 percent for school improvement: Median percent change: All 
other states: Number of states; All other states: Median dollar change; 
All other states: Median percent change. 

Fiscal year: 2005; 
States unable to set aside the full 4 percent for school improvement: 
Number of states: 12; 
States unable to set aside the full 4 percent for school improvement: 
Median dollar change: Decrease $332,000; 
States unable to set aside the full 4 percent for school improvement: 
Median percent change: Decrease 10%; 
All other states: Number of states: 38[A]; 
All other states: Median dollar change: Increase $304,000; 
All other states: Median percent change: Increase 6%. 

Fiscal year: 2006; 
States unable to set aside the full 4 percent for school improvement: 
Number of states: 12; 
States unable to set aside the full 4 percent for school improvement: 
Median dollar change: Decrease $805,000; 
States unable to set aside the full 4 percent for school improvement: 
Median percent change: Decrease 31%; 
All other states: Number of states: 38; 
All other states: Median dollar change: Increase $73,000; 
All other states: Median percent change: Increase 1%. 

Fiscal year: 2007; 
States unable to set aside the full 4 percent for school improvement: 
Number of states: 11; 
States unable to set aside the full 4 percent for school improvement: 
Median dollar change: Decrease $2.2 million; 
States unable to set aside the full 4 percent for school improvement: 
Median percent change: Decrease 74%; 
All other states: Number of states: 37[B]; 
All other states: Median dollar change: Increase $154,000; 
All other states: Median percent change: Increase 3%. 

Source: Analysis of GAO survey of states. 

[A] One state did not provide information for fiscal years 2005 and 
2006. 

[B] Three states did not provide information for fiscal year 2007. 

[End of table] 

There is also wide variation among states in the average amount of 
school improvement money available per school in improvement. (See fig. 
4).[Footnote 21] The average amount per school in improvement varies 
due to differences in overall Title I allocations as well as the number 
of schools identified for improvement in each state.[Footnote 22] For 
example, Massachusetts received over $200 million in Title I funds in 
fiscal year 2006 and set aside less than $780,000 for its 455 schools 
identified for improvement, for an average of approximately $1,700 
available per school identified for improvement. In contrast, Texas 
received over $1 billion in Title I funds in fiscal year 2006 and set 
aside $47 million for its 291 schools identified for improvement, 
averaging approximately $163,000 per school identified for improvement. 

Figure 4: States' Average Title I Set-aside Amounts Available per 
School Identified for Improvement, Fiscal Year 2006: 

[See PDF for image] 

This figure is a map of the United States illustrating States' Average 
Title I Set-aside Amounts Available per School Identified for 
Improvement, Fiscal Year 2006. The states are indicated by shading as 
being in one of four categories as follows: 

Less than $50,000: 
Alabama; 
Alaska; 
Arkansas; 
California; 
Colorado; 
Connecticut; 
District of Columbia; 
Florida; 
Hawaii; 
Idaho; 
Illinois; 
Indiana; 
Kansas; 
Kentucky; 
Massachusetts; 
Montana; 
Nevada; 
New Hampshire; 
New Mexico; 
New Jersey; 
North Carolina; 
North Dakota; 
Ohio; 
South Carolina; 
South Dakota; 

$50,001ï¿½$100,000: 
Arizona; 
Georgia; 
Michigan; 
Minnesota; 
New York; 
Washington; 
West Virginia; 
Rhode Island; 
Vermont. 

$100,001ï¿½$150,000: 
Mississippi; 
Oregon; 
Pennsylvania; 
Tennessee; 
Maine. 

$150,001ï¿½$200,000: 
Delaware; 
Louisiana; 
Oklahoma; 
Texas; 
Wisconsin; 
Wyoming. 

Greater than $200,000: 
Iowa; 
Nebraska; 
Utah. 

Data not available: 
Missouri; 
Virginia. 

Source: GAO survey of states; Copyright ï¿½ Corel Corp. All rights 
reserved (map). 

[End of figure] 

Education, recognizing challenges associated with the hold-harmless 
provision, has proposed eliminating the provision as part of its 2007 
budget justification and again as part of its proposals for 
reauthorization of NCLBA. In its 2007 budget justification, Education 
estimated states' ability to set aside the full 4 percent of Title I 
funds for school improvement for fiscal year 2005 and contended that 
the hold-harmless provision, in conjunction with Title I funding 
fluctuations, limited many states' ability to reserve these funds. 
Additionally, the department pointed out that districts slated for 
Title I increases disproportionately contribute to the Title I school 
improvement set-aside. Congress has not repealed the hold-harmless 
provision and is currently deliberating the reauthorization of NCLBA. 

Many States Have Dedicated Other Federal Funds and State Funds to 
School Improvement Efforts: 

In addition to Title I funds for school improvement, many states have 
dedicated other federal funds to school improvement efforts. To further 
support school improvement efforts, 38 states targeted funds from other 
federal programs intended to improve student achievement, including the 
Comprehensive School Reform Demonstration Program (CSR), Reading First, 
and teacher and principal quality programs under Title II of NCLBA. 
Several states we visited reported incorporating CSR funds and Reading 
First funds into their school improvement strategies. For example, in 
Ohio, CSR funds were prioritized toward school improvement purposes 
under NCLBA. Ohio's school improvement funding scheme provided Title I 
set-aside funds to schools for up to 3 years, after which schools could 
obtain funds from the CSR program. 

Additionally, 17 states have contributed almost $2.6 billion in state 
funds for school improvement activities since NCLBA was enacted, nearly 
double the $1.3 billion in federal Title I school improvement funds 
provided over the same period. In 2006, 14 states contributed state 
funds for school improvement under NCLBA. (See table 6.) For example, 
in 2006, Georgia spent $9.5 million of its funds on its statewide 
system of support, nearly as much as it expended in Title I school 
improvement funds. The 5 percent of the Title I school improvement set- 
aside the state of Georgia reserves under NCLBA for its own use 
supports 8 employees in its school improvement division, which 
implements its statewide system of support. The remaining 107 employees 
in the division are supported by Georgia's own state funds. We found no 
relationship between the usage of state funds for school improvement 
and whether a state reserved the full Title I set-aside amount required 
under NCLBA. 

Table 6: State Funds for School Improvement under NCLBA, Fiscal Year 
2006: 

State: Alabama; 
Funds expended for school improvement: Title I funds: $4.9 million; 
Funds expended for school improvement: State funds: $38 million. 

State: Arizona; 
Funds expended for school improvement: Title I funds: $4.6 million; 
Funds expended for school improvement: State funds: $13.7 million. 

State: Arkansas; 
Funds expended for school improvement: Title I funds: $680,000; 
Funds expended for school improvement: State funds: $300,000. 

State: California; 
Funds expended for school improvement: Title I funds: $24 million; 
Funds expended for school improvement: State funds: $174 million. 

State: Delaware; 
Funds expended for school improvement: Title I funds: $68,000; 
Funds expended for school improvement: State funds: $1.5 million. 

State: Georgia; 
Funds expended for school improvement: Title I funds: $10 million; 
Funds expended for school improvement: State funds: $9.5 million. 

State: Illinois; 
Funds expended for school improvement: Title I funds: $20 million; 
Funds expended for school improvement: State funds: $2.8 million. 

State: Massachusetts; 
Funds expended for school improvement: Title I funds: $31,000; 
Funds expended for school improvement: State funds: $5 million. 

State: New Hampshire; 
Funds expended for school improvement: Title I funds: $59,000; 
Funds expended for school improvement: State funds: $62,000. 

State: New Jersey; 
Funds expended for school improvement: Title I funds: $8.3 million; 
Funds expended for school improvement: State funds: $500,000. 

State: Ohio; 
Funds expended for school improvement: Title I funds: $1.1 million; 
Funds expended for school improvement: State funds: $13 million. 

State: Oregon; 
Funds expended for school improvement: Title I funds: $1.3 million; 
Funds expended for school improvement: State funds: $140,000. 

State: Pennsylvania; 
Funds expended for school improvement: Title I funds: $540,000; 
Funds expended for school improvement: State funds: $335 million. 

State: Washington; 
Funds expended for school improvement: Title I funds: $620,000; 
Funds expended for school improvement: State funds: $4 million. 

State: Total; 
Funds expended for school improvement: Title I funds: $76.2 million; 
Funds expended for school improvement: State funds: $597 million. 

Source: GAO survey of states. 

[End of table] 

States Generally Target Funds to the Most Persistently Underperforming 
Schools, However, Some States Did Not Fulfill NCLBA Requirements for 
Allocating or Tracking Funds: 

States generally target improvement funds to the most persistently 
underperforming schools, but some states did not fulfill some NCLBA 
requirements for allocating or tracking funds. On our survey, states 
generally reported that they provided more funds to the most 
persistently underperforming schools, and those schools had higher 
percentages of low-income and minority students than all other Title I 
schools. To allocate school improvement funds, 37 states use state- 
established criteria that include factors such as the number of years 
the school had been identified for improvement, 2 states used a 
competitive grant process, and 8 used some other method. However, 4 
states reported that they allocated funds equally among schools in 
improvement, and may not have taken into consideration factors required 
by NCLBA, such as focusing on the lowest achieving schools. In 
addition, 1 state allocated Title I improvement funds to districts 
without schools in improvement and did not take the required steps to 
do this. Education did not identify these potential compliance issues 
as part of its monitoring efforts. We referred these issues to 
Education, and the department is following up with relevant states. 
Also, 4 states were unable to provide complete information on which 
schools in their state received improvement funds, as required under 
NCLBA. Education has not provided guidance on how states should provide 
this information and does not monitor states' compliance with this 
requirement. 

States Generally Target Improvement Funds to the Most Persistently 
Underperforming Schools: 

Generally, we found that states targeted school improvement funds to 
the most persistently underperforming schools--those that had failed to 
make AYP for several years--and states tended to provide more funds to 
these schools. For example, the median grant amount for schools in 
restructuring nationwide was about $40,000 more than for schools in 
corrective action in 2006. (See fig. 5): 

Figure 5: Median Title I School Improvement Allocations by Improvement 
Status, Fiscal Year 2005: 

[See PDF for image] 

This figure is a vertical bar graph depicting the following data: 

Median Title I School Improvement Allocations by Improvement Status, 
Fiscal Year 2005: 

Improvement Status: School choice; 
Median grant amount: $43,192. 

Improvement Status: Supplemental educational services; 
Median grant amount: $38,201. 

Improvement Status: Corrective action; 
Median grant amount: $55,000. 

Improvement Status: Plan for restructuring; 
Median grant amount: $50,000. 

Improvement Status: Restructuring; 
Median grant amount: $96,442. 

Source: GAO survey of states. 

Note: Three states were unable to provide information on which schools 
received Title I school improvement funds, and one state provided only 
a partial list of schools that received funds. 

[End of figure] 

Overall, schools receiving improvement funds differed from Title I 
schools not in improvement and schools in improvement that did not 
receive funds. For example, schools receiving improvement funds had 
higher percentages of students in poverty and higher percentages of 
minority students compared to Title I schools not identified for 
improvement.[Footnote 23] (See table 7.) In addition, 54 percent of 
schools that received improvement funds were located in urban areas 
compared to 24 percent of all other Title I schools not identified for 
improvement. Nearly half of the schools that received funds were 
primary schools and nearly one-third were middle schools. While schools 
identified for improvement that received funds had similar poverty and 
minority percentages as all other schools identified for improvement, 
there were some differences between these two groups. For example, 26 
percent of schools that received improvement funds were located in 
rural areas, compared to 12 percent of all other schools identified for 
improvement. In the 2005-2006 school year, approximately 71 percent of 
schools identified for improvement received school improvement 
funds.[Footnote 24] 

Table 7: Selected Characteristics of Schools That Received Title I 
School Improvement Funds, Other Schools Identified for Improvement, and 
All Other Title I Schools, Fiscal Year 2006: 

Selected student characteristics[A]: Poverty status; 
Schools identified for improvement that received Title I school 
improvement funds: Mean percentage of students: 74; 
All other schools identified for improvement: Mean percentage of 
students: 73; 
All other Title I schools not identified for improvement: Mean 
percentage of students: 52. 

Selected student characteristics[A]: Minority status; 
Schools identified for improvement that received Title I school 
improvement funds: Mean percentage of students: 76; 
All other schools identified for improvement: Mean percentage of 
students: 79; 
All other Title I schools not identified for improvement: Mean 
percentage of students: 43. 

Selected school characteristics: Locale: Urban; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 54; 
All other schools identified for improvement: Percentage of schools: 
54; 
All other Title I schools not identified for improvement: Percentage of 
schools: 24. 

Selected school characteristics: Locale: Suburban; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 20; 
All other schools identified for improvement: Percentage of schools: 
35; 
All other Title I schools not identified for improvement: Percentage of 
schools: 27. 

Selected school characteristics: Locale: Town/Rural; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 26; 
All other schools identified for improvement: Percentage of schools: 
12; 
All other Title I schools not identified for improvement: Percentage of 
schools: 45. 

Selected school characteristics: Locale: Total; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 100; 
All other schools identified for improvement: Percentage of schools: 
100[B]; 
All other Title I schools not identified for improvement: Percentage of 
schools: 96[B]. 

Selected school characteristics: School level: Primary; 
Schools identified for improvement that received Title I school 
improvement funds: 48; 
All other schools identified for improvement: 61; 
All other Title I schools not identified for improvement: 71. 

Selected school characteristics: School level: Middle; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 29; 
All other schools identified for improvement: Percentage of schools: 
25; 
All other Title I schools not identified for improvement: Percentage of 
schools: 15. 

Selected school characteristics: School level: High; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 16; 
All other schools identified for improvement: Percentage of schools: 
11; 
All other Title I schools not identified for improvement: Percentage of 
schools: 10. 

Selected school characteristics: School level: Total; 
Schools identified for improvement that received Title I school 
improvement funds: Percentage of schools: 93[B]; 
All other schools identified for improvement: Percentage of schools: 
97[B]; 
All other Title I schools not identified for improvement: Percentage of 
schools: 96[B]. 

Source: GAO analysis of Education data. 

[A] The table shows the mean percentages of students who are members of 
racial or ethnic minority groups (minority status) or who qualified for 
free or reduced price meals (poverty status). 

[B] Some percentages do not total 100 due to rounding and the exclusion 
of schools for which demographic information was unavailable. 

[End of table] 

States Use Varying Criteria to Prioritize Schools for School 
Improvement Funds, but Some States Did Not Fulfill NCLBA Requirements 
for Allocating Funds: 

Thirty-seven states established criteria on a state level to determine 
which schools should receive Title I school improvement funds or 
services, and the remaining states used other allocation methods. (See 
fig. 6.) Of the 37 states, 27 used criteria that included the number of 
years the school failed to make AYP, and 21 states used criteria that 
included the number of students in each school. For example, Michigan 
officials told us that their allocation formula includes the year of 
school improvement as well as overall student enrollment. The state 
also differentiates between schools that failed to make AYP for 
academic reasons and those that missed AYP targets for other reasons, 
such as graduation rate or attendance. Of the 14 states that used 
methods other than state-established criteria to allocate funds, 2 
states--Colorado and Idaho--distributed funds through a competitive 
grant process. Eight states used other allocation methods such as 
distributing funds to districts by ranking the schools identified for 
improvement based on school performance and the number of low-income 
students. However, we found that Delaware, New Hampshire, Virginia, and 
the District of Columbia reported they required districts to provide 
each school receiving school improvement funds an equal amount of 
funding, and, thus, may not have prioritized the allocation of funds as 
required under NCLBA.[Footnote 25] In addition to their various 
allocation methods, 9 states gave districts flexibility in determining 
which schools received funds. For example, New York allocates funds to 
districts based on state-established criteria regarding schools in need 
of improvement. However, districts can choose which schools receive 
funds and the amount of funds those schools receive. 

Figure 6: States' Methods for Allocating School Improvement Funds, 
Fiscal Year 2006: 

[See PDF for image] 

This figure is a map of the United States illustrating States' Methods 
for Allocating School Improvement Funds, Fiscal Year 2006, in six 
categories as follows: 

Varying amounts distributed based on state-established criteria: 
Alabama; 
Alaska (Districts have discretion to redistribute funds); 
Arizona; 
California (Districts have discretion to redistribute funds); 
Connecticut; 
Florida (Districts have discretion to redistribute funds); 
Georgia; 
Hawaii; 
Indiana; 
Iowa; 
Kansas; 
Kentucky; 
Louisiana; 
Missouri; 
Maine; 
Massachusetts; 
Michigan; 
Montana; 
Nebraska; 
Nevada; 
New Jersey; 
New York (Districts have discretion to redistribute funds); 
North Carolina (Districts have discretion to redistribute funds); 
North Dakota; 
Oklahoma; 
Oregon; 
Rhode Island; 
South Carolina; 
South Dakota; 
Tennessee (Districts have discretion to redistribute funds); 
Texas; 
Utah; 
Vermont; 
Washington; 
West Virginia; 
Wyoming. 

Equal amount distributed to all schools: 
Delaware; 
District of Columbia; 
New Hampshire; 
Virginia. 

Amounts awarded through a competitive application process: 
Colorado; 
Idaho (Districts have discretion to redistribute funds). 

Other method used to allocate funds: 
Arkansas; 
Illinois; 
Maryland; 
Minnesota; 
Mississippi (Districts have discretion to redistribute funds); 
New Mexico; 
Ohio; 
Pennsylvania; 
Wisconsin. 

Source: GAO survey of states; Copyright ï¿½ Corel Corp. All rights 
reserved (map). 

Note: Missouri did not submit to Education its final list of schools 
identified for improvement in the 2006-2007 school year. In response to 
our survey, Virginia did not report the amount of Title I funds set 
aside for school improvement in fiscal year 2006. 

[End of figure] 

In addition to criteria used to allocate funds, states also varied in 
the proportion of school improvement funds allocated to schools and 
retained by the state. In 2006, 38 states allocated 95 percent of the 
school improvement set-aside funds directly to local school districts 
for schools identified for improvement, as NCLBA requires, with the 
remaining 5 percent retained by states to carry out their 
responsibilities.[Footnote 26] In 2006, 1 state that we visited 
retained less than 5 percent for its statewide system of support and 
distributed more than 95 percent to districts for schools identified 
for improvement. In contrast, some states retained more than 5 percent 
of their school improvement set-aside, as permitted under NCLBA under 
certain circumstances.[Footnote 27] With the approval of districts, a 
state may retain more than 5 percent to directly provide school 
improvement services for schools or arrange for other entities to 
provide these services. In 2006, 10 states retained more than 5 
percent. (See fig. 7.) For example, New Mexico officials told us that 
eligible districts agreed that the state could retain the entire set- 
aside amount to support a systematic reform model for school years 2006-
2007 and 2007-2008. For participating schools, state officials paid a 
contractor to provide leadership and instructional training, reading 
and math interventions, and materials needed to support the 
interventions for schools identified for improvement. 

Figure 7: Number of States That Reserved Less than 5 Percent, 5 
Percent, or More than 5 Percent of School Improvement Funds for Their 
Statewide System of Support: 

[See PDF for image] 

This figure is a multiple vertical bar graph depicting the following 
data: 

Number of States That Reserved Less than 5 Percent, 5 Percent, or More 
than 5 Percent of School Improvement Funds for Their Statewide System 
of Support: 

Fiscal year: 2002; 
Less than 5 percent: 9; 
5 percent: 35; 
More that 5 percent: 2. 

Fiscal year: 2003; 
Less than 5 percent: 9; 
5 percent: 38; 
More that 5 percent: 2. 

Fiscal year: 2004; 
Less than 5 percent: 10; 
5 percent: 33; 
More that 5 percent: 6. 

Fiscal year: 2005; 
Less than 5 percent: 4; 
5 percent: 35; 
More that 5 percent: 10. 

Fiscal year: 2006; 
Less than 5 percent: 1; 
5 percent: 38; 
More that 5 percent: 10. 

Source: GAO survey of states. 

[End of figure] 

While most states retained the allowed 5 percent of the Title I school 
improvement funds to carry out their state responsibilities,[Footnote 
28] 23 states reported that they have fully implemented their statewide 
system of support. Of the remaining 28 states, 18 reported that their 
system was mostly implemented and 10 reported they have partially 
implemented their system. Education officials offered several reasons 
why states may not have fully implemented these systems. For example, 
some states may not have had enough funds to fully implement their 
statewide system of support. In other states, statewide strategies may 
only reach a portion of the schools identified for improvement because 
services are prioritized for the lowest-achieving schools and 
districts. In addition, officials said some states have experienced 
large increases in the number of schools identified for improvement, 
necessitating significant changes to their statewide system of support. 

Additionally, 21 states allocated some of their Title I school 
improvement funds to districts for district-level activities, including 
at least 1 state that may not have met NCLBA requirements for doing 
this. Districts have a major responsibility for providing technical 
assistance to schools identified for improvement. According to 
Education officials, while NCLBA does not explicitly set aside funds 
for district-level activities, it does allow for districts to use 
improvement funds to provide services to these schools. In addition, 
Education officials said that funds can be used for building district 
capacity if the funds are focused on providing services for schools 
identified for improvement. In Massachusetts, for example, some funds 
supported district-level specialists who provided direct assistance to 
schools identified for improvement in areas such as data analysis and 
implementing the school improvement plan. In addition, according to 
Education officials, states have authority to use some of the 95 
percent funds for districts identified for improvement but without 
schools in improvement if the state determines that the amount of 95 
percent funds exceeds the amount needed to provide assistance to 
schools identified for improvement. In this situation, a state may take 
excess funds from one district and give those funds to other districts 
based on state-determined need. Education officials told us that states 
must consult with districts before claiming unused funds and have 
evidence that these discussions took place.[Footnote 29] However, we 
found that 1 state may have allocated Title I improvement funds to 
districts identified for improvement without schools identified for 
improvement without first determining it had excess funds. We 
identified this issue through our site visits and are uncertain if 
other states may have also done this. Education officials said they did 
not identify this issue during their recent monitoring visit. We 
referred this matter to Education, which is following up on it. 

While States Collect Some Information to Track Funds, Many States Are 
Not Able to Provide Information on Which Schools Receive Funds: 

Most states collect and track information on the use of school 
improvement funds. Forty-eight states reported on our survey that they 
collect information on the expenditure of Title I school improvement 
funds at least annually from schools, districts, or other sources. 
Twenty-four states reported collecting expenditure information on each 
school receiving improvement funds. Other states reported collecting 
expenditure information from districts that provide aggregate 
information for all schools that received improvement funds in the 
district, rather than for each school receiving improvement funds. 
Seventeen states reported that district officials monitor school 
improvement funds by comparing activities that were funded to those 
identified in school improvement plans. For example, some district 
officials we visited said they compare school improvement expenditures 
to the school improvement plan before approving disbursements. Forty- 
five states reported that state or district officials conduct visits or 
monitor through other means how school improvement funds were expended 
and what school improvement activities were funded. State officials 
from 14 states reported that monitoring was conducted in multiyear 
cycles rather than annually or that a portion of schools were monitored 
annually. For example, as part of Ohio's monitoring and review process, 
officials said that district cohorts are reviewed every 3 years with on-
site reviews conducted at a minimum of 10 percent of the cohort. 

While most states monitor funds, 4 states were unable to make publicly 
available the complete list of schools receiving improvement funds, as 
required under NCLBA, because these states do not collect information 
on each school receiving improvement funds, and Education has not 
provided guidance on this requirement.[Footnote 30] Almost all states 
were able to provide a list of schools receiving funds to us, but 3 
states--Arkansas, Florida, and North Carolina--provided information on 
districts that received funds, but could not provide information on 
which schools received funds, and California provided a partial list of 
schools that received funds. In a few cases, we found that non-Title I 
schools had inappropriately received Title I school improvement funds. 
State officials said that they would take steps to address this issue, 
and we referred this matter to Education, which is following up on it. 
Though Education monitors the allocation of school improvement funds 
through its 3-year Title I monitoring cycle, Education officials told 
us they had not uncovered these issues. In addition, Education does not 
regularly check when and whether states have made the lists of schools 
receiving improvement funds publicly available, as required, and has 
not provided guidance on how states make lists of schools receiving 
improvement funds publicly available. 

Schools and States Are Engaged in a Variety of Improvement Activities 
and Mainly Assess Them Using Student Achievement Data and Feedback: 

Schools that received funds and states have employed a range of 
improvement activities, and most states assess these activities by 
reviewing trends in student achievement data and obtaining feedback 
from district and school officials. At least 45 states reported that 
schools that received school improvement funds were involved in 
professional development, reorganizing curriculum or instructional 
time, or data analysis. Nearly all states reported that they assisted 
schools identified for improvement with school improvement plans and 
professional development, and officials in 42 states consider this 
assistance key to helping schools improve. To assess school improvement 
activities, 42 states reported that they track student achievement data 
or school performance trends, and 36 of those states also use feedback 
from school and district officials. 

Schools That Received Funds Have Undertaken a Variety of Improvement 
Activities, and States Have Provided Support for Many of These 
Activities: 

Nearly all states reported on our survey that schools that received 
improvement funds in school year 2006-2007 were engaged in activities 
such as professional development and data analysis, and districts and 
schools we visited also cited these and other activities. Forty-seven 
states reported that schools receiving improvement funds were taking 
part in professional development, 46 states said schools were 
reorganizing curriculum or instructional time, and 45 states reported 
that schools were using data analysis from the state's assessment 
system or other assessments. School officials in each state we visited 
also cited using school improvement funds for professional development 
activities. For example, at one school in California, staff received 
intensive training in instructional strategies and data analysis 
software, which was designed to help teachers analyze instructional 
practices and provided teachers with specific steps to increase student 
achievement. In addition, schools and districts in every state we 
visited mentioned using coaches who are generally former principals, 
teachers, or other subject area specialists who work with school 
administrators or teachers. School officials in Michigan noted that 
coaches had served as a key resource in the development of school 
improvement plans. In some of the schools and districts we visited, 
officials pointed to the importance of examining test scores and 
student data in helping schools improve. For example, a school district 
in Ohio provided school leaders and teachers immediate access to test 
scores and other information such as curriculum, professional 
development resources, and student records online to help track student 
achievement. 

While over 40 states reported that they assisted schools identified for 
improvement with the school improvement plan, professional development, 
and data analysis, or provided help from school support teams, states 
generally reported providing more assistance to schools in later stages 
of improvement (See fig. 8). In New Mexico, for example, all schools 
identified for improvement are required to conduct certain activities 
such as short cycle assessments several times a year, while schools in 
restructuring are also required to send staff to training in areas such 
as principal leadership. As another example, 44 states reported that 
they provided assistance from school support teams to schools in 
corrective action and restructuring, compared to 34 states that 
reported providing this assistance to schools in earlier stages of 
improvement. The only area in which states said they provided slightly 
more assistance to schools in earlier stages of improvement was helping 
with the school improvement plan. 

Figure 8: Differences in Types of Assistance States Provided to Schools 
in Different Stages of Improvement: 

[See PDF for image] 

This figure is a multiple horizontal bar graph depicting the following 
data: 

Differences in Types of Assistance States Provided to Schools in 
Different Stages of Improvement: 

Type of assistance: School improvement plans; 
Number of states, schools offering public school choice and SES: 50; 
Number of states, schools in corrective action and restructuring: 47. 

Type of assistance: Professional development; 
Number of states, schools offering public school choice and SES: 41; 
Number of states, schools in corrective action and restructuring: 46. 

Type of assistance: Data analysis; 
Number of states, schools offering public school choice and SES: 44; 
Number of states, schools in corrective action and restructuring: 44. 

Type of assistance: School support teams; 
Number of states, schools offering public school choice and SES: 34; 
Number of states, schools in corrective action and restructuring: 44. 

Type of assistance: Instructional experts; 
Number of states, schools offering public school choice and SES: 34; 
Number of states, schools in corrective action and restructuring: 40. 

Type of assistance: Curriculum and instructional alignment with state 
standards; 
Number of states, schools offering public school choice and SES: 32; 
Number of states, schools in corrective action and restructuring: 36. 

Type of assistance: Curriculum and assessment materials; 
Number of states, schools offering public school choice and SES: 35; 
Number of states, schools in corrective action and restructuring: 35. 

Source: GAO survey of states. 

[End of figure] 

Forty-two states considered helping schools identified for improvement 
with the school improvement plan and professional development to be 
somewhat to very effective forms of state support. For example, many 
states provided schools and districts a template for improvement plans, 
which can help ensure some consistency in plans across the state. In 
Ohio, state officials showed us an electronic tool that they developed 
for both district improvement plans and school improvement plans that 
they said have been useful in aligning district and school improvement 
plans. 

States Primarily Use Student Achievement Data and Feedback from 
Districts and Schools to Assess Improvement Activities: 

Forty-two states reported that they tracked changes in student 
achievement data or school performance trends, and 36 of those states 
also used feedback from district and school officials to assess 
improvement activities. For example, Michigan officials said they 
require schools to provide student achievement data annually and to 
describe which improvement activities were working as well as what 
changes they planned to make. We also found that some states we visited 
conduct more extensive reviews of schools in corrective action and 
restructuring that include site visits, assessments, and observation of 
staff and leadership. Most districts and schools we visited also focus 
on student achievement data to assess activities. One school in Georgia 
has students take interim practice tests using questions similar to 
those of the state's annual assessment to track students' progress. The 
school has a "data room" that has test scores and other data by grade 
level and subgroups displayed in lists, graphs, and charts to track 
progress and serve as a visual reminder of its overall goals. (See fig. 
9.) At the district and school levels, officials in every state we 
visited emphasized the importance of using the school improvement plans 
to identify specific actions and goals, and many use the plan to 
monitor progress and make adjustments as needed. 

Figure 9: Example of a Middle School's Data Room to Track Students' 
Progress: 

[See PDF for image] 

This figure is a photograph of a wall display in a middle school's data 
room used to track students' progress. 

Source: GAO. 

[End of figure] 

Twenty-four states reported that they conduct evaluations, either on 
the state, district, or school level to assess activities. Based on 
information provided by some states, these assessments were not in line 
with Education's definition of high-quality reviews of educational 
effectiveness but included approaches to assess activities and track 
school improvement.[Footnote 31] In some cases, states we visited told 
us they are working with or plan to work with an independent evaluator 
or other entity to conduct a more formal evaluation of school 
improvement activities. 

Education Provides a Range of Support for School Improvement, Including 
Some New Efforts Aimed at Areas in Which States Want More Help: 

Education directly supports states with school improvement through 
written guidance, staff assistance, policy letters, and information 
provided at national conferences. In July 2006, Education published 
nonregulatory guidance on district and school improvement that updated 
and expanded its earlier guidance in this area.[Footnote 32] Education 
staff also provide direct assistance by responding to states' 
questions. In some cases, Education officials said they send policy 
letters to individual states to address state-specific questions and 
post the letters on its Web site. For example, one state requested 
clarification from Education on allocating Title I school improvement 
funds to districts, and Education responded with a policy letter. In 
addition, Education also provides guidance and disseminates information 
through national conferences such as the annual Title I National 
Conference. 

In addition to direct support, Education provides a number of technical 
assistance and research-related resources to assist states, districts, 
and schools in their school improvement efforts. These include the 
Comprehensive Centers Program, Regional Education Laboratories, the 
Center for Comprehensive School Reform and Improvement, the What Works 
Clearinghouse, and a new Doing What Works Web site. (See fig. 10). 

Figure 10: Education's Technical Assistance and Research-Related 
Resources That Support School Improvement Efforts: 

[See PDF for image] 

This figure is an illustration of Education's Technical Assistance and 
Research-Related Resources That Support School Improvement Efforts. 

States, Districts, and Schools receive support from the following: 

National content centers: 
* Assessment and accountability; 
* High schools; 
* Innovation and improvement; 
* Instruction; 
* Teacher quality. 

Regional comprehensive assistance centers: 
* Alaska; 
* Appalachia; 
* California; 
* Florida and islands; 
* Great Lakes East; 
* Great Lakes West; 
* Mid-Atlantic; 
* Mid-Continent; 
* New England; 
* New York; 
* North Central; 
* Northwest; 
* Pacific; 
* Southeast; 
* West/Southwest; 
* Texas. 

Region educational laboratories: 
* Appalachia; 
* Central; 
* Mid-Atlantic; 
* Midwest; 
* Northeast and islands; 
* Northwest; 
* Pacific; 
* Southeast; 
* Southwest; 
* West. 

Center for Comprehensive School Reform and Improvement: 

What works clearinghouse (Web-based): 

Doing What works (web-based): 

Source: GAO analysis of Education information; images, Art Explosion. 

Note: While Education has some additional efforts to support student 
achievement, the resources shown above represent those most related to 
school improvement. 

[End of figure] 

* Education provides a number of services to states through its 
Comprehensive Centers Program--consisting of 16 regional centers and 5 
content centers.[Footnote 33] The regional centers are located across 
the country and provide training and technical assistance to address 
state needs and priority areas, which largely focus on school 
improvement. Each of the 5 content centers focuses on one of the 
following areas: accountability, instruction, teacher quality, 
innovation and improvement, or high schools. The content centers 
provide expertise, analysis, and research in the five content areas. 
According to an Education official, a key focus of the comprehensive 
centers is helping states build their statewide systems of support. 
Currently, the comprehensive centers have 8 regional initiatives and 35 
individual state initiatives related to this topic. In addition, there 
are 2 regional initiatives and 26 individual state initiatives to 
address district and school improvement. 

* One content center, the Center on Innovation and Improvement, 
provides a variety of services related to school improvement. The 
center gathers data and information on districts and schools making 
sustained gains to identify successful improvement strategies. It has 
developed two guides on this topic, a Handbook on Restructuring and 
Substantial School Improvement and a Handbook on Statewide Systems of 
Support, which it has distributed to regional centers, state 
educational agencies, and other organizations.[Footnote 34] The center 
also facilitates information sharing on school improvement topics 
through its annual 2-day training for representatives of the regional 
centers and additional workshops throughout the year. In addition, the 
center collaborates with the Council of Chief State School Officers to 
issue monthly School Improvement e-newsletters, which focus on school 
improvement efforts at the state and district levels. 

* Education also compiles and disseminates relevant research on 
effective educational interventions. Education operates 10 Regional 
Education Laboratories to provide research on a variety of topics, such 
as statewide systems of support and factors that have helped schools 
make AYP. The laboratories are also available to provide assistance to 
any entity, such as school districts or schools, if they request 
assistance. Education also funds the Center for Comprehensive School 
Reform and Improvement to assist schools and districts in implementing 
comprehensive school reform and improvement by providing information 
about research-based strategies and assistance in using that 
information to make changes. In addition, 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. In November 2007, 
Education implemented a Doing What Works Web site to help educators 
adapt and use the research-based practices identified by the What Works 
Clearinghouse. 

State officials reported that Education's written guidance, national 
meetings or conferences, and comprehensive centers were the most 
helpful forms of assistance and the What Works Clearinghouse was 
relatively less helpful (See fig. 11.) For example, in several states 
we visited, state officials told us that comprehensive centers have 
been helpful in areas such as building state school improvement 
capacity and facilitating discussions with other states. Although 15 
states reported that the What Works Clearinghouse was moderately to 
very helpful, 20 states reported that it provided some to no help. 
District officials said that it has not been useful for reasons such as 
it is difficult to figure out how to translate the research on the What 
Works Clearinghouse into practical application at the classroom level. 

Figure 11: Extent to Which States Found Assistance from Education 
Helpful: 

[See PDF for image] 

This figure is a multiple horizontal bar graph depicting the following 
data: 

Extent to Which States Found Assistance from Education Helpful: 

Type of assistance: Written guidance on school improvement; 
Number of states, some to no help: 9; 
Number of states, moderately to very helpful: 42. 

Type of assistance: Center for Comprehensive School Reform and 
Improvement; 
Number of states, some to no help: 5; 
Number of states, moderately to very helpful: 31. 

Type of assistance: Regional and comprehensive centers; 
Number of states, some to no help: 11; 
Number of states, moderately to very helpful: 33. 

Type of assistance: National conferences; 
Number of states, some to no help: 13; 
Number of states, moderately to very helpful: 34. 

Type of assistance: Technical assistance from Department of Education 
staff; 
Number of states, some to no help: 12; 
Number of states, moderately to very helpful: 28. 

Type of assistance: What Works Clearinghouse; 
Number of states, some to no help: 22; 
Number of states, moderately to very helpful: 19. 

Source: GAO survey of states. 

[End of figure] 

Almost all states also reported that they could benefit from additional 
assistance from Education. Fifty states reported that they could 
benefit from more tool kits and sample documents, and 48 states said 
they could benefit from more national or regional conferences to share 
lessons learned and promising practices. Education officials said that 
they have also heard that states want more opportunities to share 
information and are looking for ways to do this. Forty-three states 
also reported that they could use additional assistance in evaluating 
the effectiveness of school improvement activities, and 42 states said 
they could benefit from more help with monitoring and assessing school 
improvement activities. 

Education has taken steps to address concerns about the What Works 
Clearinghouse and to provide additional resources aimed at addressing 
areas in which states want more help. An Education official told us 
that the recently implemented Doing What Works Web site is aimed at 
helping educators adapt and use the research-based practices on the 
What Works Clearinghouse. To do this, the Doing What Works Web site 
provides the following: (1) information to help make the research on 
effective practices more understandable for educators, (2) links to 
real-life examples such as interviews with teachers and pictures from 
classrooms to help show the practices in action, and (3) tools and 
resources that educators can use in their own planning and training 
efforts. As far as providing more help on monitoring and evaluating 
school improvement activities, Education officials told us that they 
plan to collect additional information about successful school 
improvement practices as part of the new school improvement grants-- 
authorized under NCLBA and funded for the first time in 2007. States 
receiving these grants will be required to track and report outcomes 
such as increased student proficiency and how school improvement 
activities helped schools improve. Education plans to compile this 
information and discuss this topic at a meeting of state Title I 
directors in early 2008. In addition, the Administration, as part of 
its proposed revision to the school improvement section of NCLBA, is 
recommending that Education be allowed to reserve up to 1 percent of 
Title I funds to conduct research, evaluation, and dissemination 
activities related to effective school and district school improvement 
activities. 

Conclusions: 

While the hold-harmless provision is intended to shield districts from 
receiving less in Title I funds than in the previous year as a result 
of the school improvement set-aside, we found some evidence that it may 
be preventing some of the neediest schools that face the most 
challenges to improving the academic achievement of their students from 
obtaining these funds. When states cannot set aside the full 4 percent 
of Title I for school improvement, their ability to target funds at the 
lowest-performing schools is diminished. Effectively, the hold- 
harmless provision prioritizes preserving the Title I funding of all 
eligible Title I districts over ensuring that the lowest-performing 
schools receive funds for school improvement. Furthermore, the 
variability from year to year in state Title I funds can affect some 
states' ability to sustain a steady stream of support for low- 
performing schools. Removing the hold-harmless provision, as Education 
has proposed, would clearly increase states' ability to target 
improvement funds to the lowest-performing schools. However, while 
Education points out that set-aside funds come from districts with 
increasing Title I allocations, it is still not known how removing the 
hold-harmless provision would affect those districts protected by it. 
It would be helpful for Congress as it deliberates reauthorization of 
NCLBA to know the characteristics of districts that contribute to the 
set-aside compared to those that are protected by the hold-harmless 
provision, particularly in terms of student characteristics and school 
performance. 

Thousands of schools have received Title I school improvement funds 
intended to help schools raise student achievement, and states have 
generally targeted these funds to schools with the most persistent 
achievement problems. However, without additional monitoring steps by 
Education to ensure that states are appropriately allocating funds for 
district-level activities and prioritizing funds to the lowest- 
achieving schools, some schools most in need of assistance may not 
receive funding. While Education monitors every state's improvement 
program every 3 years, it has not uncovered several compliance issues 
that we identified. Further, because some states do not track which 
schools receive improvement funds and could not make this information 
publicly available, as required under NCLBA, Education and others have 
not been in the best position to ensure that school improvement funds 
are used only for Title I schools and targeted to the lowest-performing 
schools. Ensuring that states track which schools receive improvement 
funds and can make this information publicly available enhances 
transparency and accountability, and better enables the public, 
Education, and states to track compliance and progress. 

Recommendations for Executive Action: 

To enhance state efforts to target improvement funds to schools most in 
need of assistance, we are making the following three recommendations 
to the Secretary of Education: 

* To further support the department's proposal to eliminate the hold- 
harmless provision, develop an analysis comparing the characteristics 
of districts that contribute to the set-aside with those protected by 
the hold-harmless provision. Such an analysis could identify 
differences in school performance or student characteristics. 

* Review the Title I monitoring process to ensure that steps are in 
place to ensure that states comply with NCLBA requirements for 
allocating school improvement funds to districts for district-level 
activities and prioritizing funds to the lowest performing schools. 

* Ensure that states track which schools receive improvement funds and 
can comply with the requirement to make a list publicly available of 
all schools receiving Title I improvement funds by providing guidance 
to clarify when and how this information is to be made available and by 
monitoring state compliance. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Education for 
review and comment. In its written response, included as appendix II, 
Education agreed with our three recommendations. Specifically, 
Education agreed to explore options to determine the types of analyses 
that would be helpful to inform the debate on eliminating the hold- 
harmless provision. Education also agreed to review its monitoring 
process and consider changes to gather additional evidence on whether 
school improvement funds are being allocated and prioritized as 
required by statute. In addition, Education agreed that it will explore 
options for providing guidance to states on the NCLBA requirement that 
states make publicly available a list of all schools receiving Title I 
school improvement funds. Education also identified some of the steps 
it has taken to collect additional information on the allocation and 
use of school improvement funds and to identify successful school 
improvement strategies. 

Copies of this report are being sent to the Secretary of Education, 
relevant congressional committees, and other interested parties. We 
will also make copies available to others upon request. In addition, 
the report will be made available at no charge on GAO's Web site at 
[hyperlink, http://www.gao.gov]. Please contact me at (202) 512-7215 if 
you or your staff have any questions about this report. Other contacts 
and major contributions are listed in appendix IV. 

Sincerely yours, 

Signed by: 

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

[End of section] 

Appendix I: Scope and Methodology: 

To address the objectives of this study, we used a variety of methods. 
To obtain nationally representative information on states' school 
improvement funding, types of activities being funded, and federal 
assistance, we administered a survey to state education agency 
officials in all 50 states and the District of Columbia. To get a 
national perspective of schools in improvement, we conducted 
descriptive analyses of characteristics of schools that received 
improvement funds and compared them to all schools identified for 
improvement and all other Title I schools nationwide. We also conducted 
site visits during which we interviewed state, district, and school 
officials representing 5 states and 12 school districts within these 
states. We spoke with officials at Education involved in oversight and 
distribution of school improvement funds and reviewed Education's data 
on schools identified for improvement. We also interviewed several 
experts in the field of school improvement. We reviewed relevant 
federal laws, regulations, and agency guidance. We conducted our work 
from January 2007 through February 2008 in accordance with generally 
accepted government auditing standards. Those standards require that we 
plan and perform the audit to obtain sufficient, appropriate evidence 
to provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. 

Survey of States: 

To better understand states' school improvement efforts, particularly 
how states are allocating and tracking school improvement funds and 
activities, we designed and administered a survey to state education 
agency officials in all 50 states and the District of Columbia between 
July and October 2007 and had a 100 percent response rate. 

The survey included questions on the amount of Title I improvement 
funds states have reserved and expended, what other federal or state 
funds are being used, what types of improvement activities are being 
funded, how activities are being monitored and assessed, and assistance 
received from Education. 

Because this was not a sample survey, there are no sampling errors. 
However, the practical difficulties of conducting any survey may 
introduce nonsampling errors, such as variations in how respondents 
interpret questions and their willingness to offer accurate responses. 
We took steps to minimize nonsampling errors, including pretesting 
draft instruments and following up with states to discuss questionable 
responses. Specifically, during survey development, we pretested draft 
instruments with officials in Rhode Island, Ohio, Illinois, Montana, 
and Florida between May and June 2007. 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 that 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 were 
appropriate. On the basis of the pretests, the survey instrument 
underwent some slight revision. A second step we took to minimize 
nonsampling errors was contacting state officials via phone and e-mail 
to follow up on obvious inconsistencies, errors, and incomplete 
answers. We also performed computer analyses to identify 
inconsistencies in responses and other indications of error. In 
addition, a second independent analyst verified that the computer 
programs used to analyze the data were written correctly. 

Education and State Data: 

For our analysis, we used data from three sources--state-provided data 
on schools that received Title I improvement funds in each state, 
Education's Common Core of Data (CCD), and Education's Consolidated 
State Performance Reports (CSPR). For comparison, we created three 
discrete groups of schools: (1) schools identified for improvement that 
received funds and services, (2) schools identified but not receiving 
funds and services, and (3) all other Title I schools that were not 
identified for improvement for school year 2005-2006. 

To obtain information on the characteristics of schools receiving 
school improvement funds, we requested information from each state on 
the schools identified for school choice, supplemental educational 
services, corrective action, or restructuring in their respective state 
that received Title I set-aside school improvement funds or services 
pursuant to ï¿½1003(a) of the No Child Left Behind Act (NCLBA) during the 
2004-2005, 2005-2006, and 2006-2007 school years. We also asked states 
to indicate the percentage of students from families with incomes below 
the poverty line for each school that received improvement funds during 
the 3 school-year time frame. In addition, we asked states to provide 
information on each school that included (1) the school's full name; 
(2) the school's address, city, and state; (3) the school's district 
name; and (4) the school's National Center for Education Statistics 
(NCES) school identification; (5) the school's year of improvement 
under NCLBA: first year of improvement (school choice), second year of 
improvement (school choice and supplemental educational services), 
third year of improvement (school choice, supplemental educational 
services, and corrective action), fourth year of improvement (school 
choice, supplemental educational services, and plan for restructuring), 
or fifth year of improvement (school choice, supplemental educational 
services, and implementing a restructuring plan); and (6) we asked 
states, if possible, to provide the amount of Title I set-aside funds 
(and any other federal/state improvement funds, if applicable) that 
each school received. 

Three states were unable to provide this information, and 1 state 
provided partial information, so our data on school characteristics are 
presented only for those states that provided this information. 
[Footnote 35] We reviewed the lists of schools receiving improvement 
funds for obvious inconsistencies, errors, and completeness. When we 
found discrepancies, we brought them to the attention of state 
officials and worked with them to correct the discrepancies before 
conducting our analyses. On the basis of these efforts, we determined 
that the data were sufficiently reliable for the purposes of this 
report. 

Our other two data sources were data from Education's CCD and CSPR. The 
CCD is a program of Education's National Center for Education 
Statistics that annually collects data from state education agencies 
about all public schools, public school districts, and state education 
agencies in the United States. At the time we began our analysis, the 
latest CCD data available were from the 2005-2006 school year. Although 
we based our analysis on schools in improvement in 2006-2007, the 
characteristics were based on those of the prior year. To compare the 
characteristics of schools that received improvement funds to those of 
all schools in improvement and all Title I schools for 2005-2006, we 
used data from CSPR, which is the required data tool for each state, 
the District of Columbia, and Puerto Rico and contains lists of schools 
identified for improvement by state. The CSPR also provides each 
school's nationally unique identification number, allowing us to link 
data on these schools with data provided in the CCD. For our analysis, 
we excluded Puerto Rico, Arkansas, Florida, and North Carolina because 
they could not provide information on which schools received funds. In 
addition, we did not have complete information from California because 
state officials provided a partial list of schools that received funds. 
We compared schools in improvement from the CCD for school year 2005- 
2006 with all other Title I eligible schools not identified for 
improvement. We also compared states' lists of schools in improvement 
that received funds or services from the 2005-2006 CSPR with lists of 
schools that were in improvement but did not receive funding or 
services. 

We performed a series of tests and took additional steps as needed to 
assess the reliability of the data used. Specifically, we assessed the 
reliability of the data by (1) examining the data for obvious 
inconsistencies, (2) reviewing existing information about the data and 
the system that produced them, and (3) interviewing agency officials 
knowledgeable about the data. We determined that the data were 
sufficiently reliable for the purposes of this report. 

Site Visits: 

To understand school improvement funding and implementation at the 
local level, we conducted site visits to 5 states and 12 districts and 
22 schools within these states between April and October 2007. The 
states we chose were California, Georgia, Michigan, New Mexico, and 
Ohio, which were selected based on having high percentages of schools 
identified for improvement, variation in Title I set-aside funding 
allocation methods and administrative structures, and geographic 
diversity. We interviewed state officials on states' efforts to 
allocate federal and state school improvement funds, provide assistance 
to schools identified for improvement, and Education's assistance to 
states. 

Within each of the 5 states, we met officials from 2 school districts, 
and in Michigan, we met with officials from 4 school districts for a 
total of 12 school districts, as shown in table 8. The 12 districts 
were selected to provide variety in demographics, geographic location, 
and stages of improvement. 

Table 8: School Districts Selected for Site Visits: 

School district: Albuquerque Public Schools; 
City, state: Albuquerque, New Mexico. 

School district: Columbus City Schools; 
City, state: Columbus, Ohio. 

School district: DeKalb County School System; 
City, state: Decatur, Georgia. 

School district: Detroit Public Schools; 
City, state: Detroit, Michigan. 

School district: Grand Rapids Public Schools; 
City, state: Grand Rapids, Michigan. 

School district: Hall County Schools; 
City, state: Gainesville, Georgia. 

School district: Kent Intermediate School District; 
City, state: Grand Rapids, Michigan. 

School district: Lodi Unified School District; 
City, state: Lodi, California. 

School district: Portsmouth City School District; 
City, state: Portsmouth, Ohio. 

School district: Roswell Independent School District; 
City, state: Roswell, New Mexico. 

School district: Wyoming Public Schools; 
City, state: Wyoming, Michigan. 

School district: Yuba City Unified School District; 
City, state: Yuba City, California. 

Source: GAO. 

[End of table] 

During the site visits, we interviewed state and district officials as 
well as officials representing 22 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 represented 
varying stages of improvement, grade levels served, and locales. While, 
in many cases, district officials selected the schools we visited, we 
instructed state and district officials to consider each school's stage 
of improvement and percentage of economically disadvantaged students, 
among other characteristics. Through our interviews with state, 
district, and school officials, we collected information on school 
improvement funding, school improvement activities being undertaken, 
and state and district assistance to schools identified for 
improvement. 

Education and Expert Interviews and Studies: 

To learn more about Education's oversight of Title I school improvement 
funds and efforts to assist states in implementation of school 
improvement provisions, we conducted interviews with representatives of 
the offices of Student Achievement and School Accountability Programs; 
Planning, Evaluation, and Policy Development; Institute of Education 
Sciences; Office of School Support and Technology Programs; and the 
Office of General Counsel. 

In addition, we interviewed experts on school improvement, including 
those at the American Institutes for Research, Center on Education 
Policy, Council of Chief State School Officers, and the National 
Governors Association. We also reviewed several studies on school 
improvement funding and activities. 

[End of section] 

Appendix II: Comments from the Department of Education: 

United States Department Of Education: 
Office Of Elementary And Secondary Education: 
The Assistant Secretary: 
600 Independence Ave., SW: 
Washington, D.C. 20202-6100: 
Our mission is to ensure equal access to education and to promote 
educational excellence throughout the nation. 

February 21, 2008: 

Ms. Cornelia M. Ashby: 
Director, Education, Workforce and Income Security Issues: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Ashby: 

I am writing in response to your request for comments on the Government 
Accountability Office (GAO) draft report (GAO 08-380), dated February 
2008, and entitled "No Child Left Behind Act: Education Actions Could 
Improve the Targeting of School Improvement Funds to Schools Most in 
Need of Assistance." I appreciate the opportunity to comment on the 
draft report. 

The following are responses to the specific recommendations in the 
report calling for the Department to take actions to enhance State 
efforts to target school improvement funds to schools most in need of 
assistance: 

Recommendation 1. To further support the department 's proposal to 
eliminate the hold-harmless provision, develop an analysis comparing 
the characteristics of districts that contribute to the set-aside with 
those protected by the hold-harmless provision. Such an analysis could 
identify differences in school performance or student characteristics. 

The Department agrees with the importance of identifying additional 
data to inform the debate on eliminating the hold-harmless provision in 
section 1003(e) of Title I of the Elementary and Secondary Education 
Act and will explore multiple options to determine the types of 
analyses that may be helpful in this regard. 

Recommendation 2. Review the Title I monitoring process to ensure that 
steps are in place to ensure that states comply with NCLBA requirements 
for allocating school improvement, funds to districts for district-
level activities and prioritizing funds to the lowest performing 
schools. 

The Department agrees with this recommendation. The Department will 
review its monitoring process and consider changes that we might make 
in order to gather additional evidence on whether school improvement 
funds are being allocated and prioritized as required by the statute. 
Additionally, as part of the application package for fiscal year 2007 
school improvement funds provided under section 1003(g), we notified 
States that they will be expected to report annually to the Department 
the amount of school improvement funds allocated to local educational 
agencies (LEAs) on behalf of eligible schools under both section 
1003(a) and section 1003(g). 

In addition, we required States, as part of their application, to 
include the criteria they will use to prioritize those funds to LEAs 
with the lowest-achieving schools that demonstrate the greatest need 
for the funds and the strongest commitment to ensuring that the funds 
are used to provide adequate resources for the lowest-achieving schools 
to meet the goals for improvement under section 1116. States also 
indicated how they define "greatest need" and "strongest commitment." 
Further, they indicated their criteria for determining grant award 
amounts to LEAs to ensure that each grant is of sufficient size and 
scope to support the activities required under sections 1116 and 1117 
and is not less than $50,000 or more than $500,000 for each 
participating school. We will monitor to ensure that States have 
implemented these requirements consistent with their applications. 

Recommendation 3. Ensure that states track which schools receive 
improvement funds and can comply with the requirement to make a list 
publicly available of all schools receiving Title I improvement funds 
by providing guidance to clarify when and how this information is to be 
made available and by monitoring state compliance. 

The Department agrees with this recommendation. In addition to the 
monitoring review described above, the Department will explore a range 
of options for providing guidance to States concerning the requirement 
that States make publicly available a list of all schools receiving 
Title I school improvement funds. 

I would also like to take this opportunity to indicate that, in 
addition to addressing the issues you have identified, the Department 
is very interested in acquiring more information on the uses of school 
improvement funds. This includes information on how State educational 
agencies are identifying effective strategies for improving student 
achievement supported with these funds and on how they are 
disseminating this information to other LEAs in the State. To this end, 
the application process for fiscal year 2007 school improvement funds 
authorized under 1003(g) required States to identify how they will 
assess the effectiveness of activities carried out with school 
improvement funds and disseminate information on what works. We are 
also requiring States to identify for the Department those school 
improvement strategies that have effectively contributed to increased 
student achievement and to schools' making adequate yearly progress. 

We appreciate the opportunity to share our comments and plans. 

Please let me know if you need additional information regarding 
activities underway at the Department to ensure the effective targeting 
and use of Title I school improvement funds. 

Sincerely, 

Signed by: 

Kerri L. Briggs Ph.D. 

[End of section] 

Appendix III: GAO Contacts and Acknowledgments: 

GAO Contact: 

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

Acknowledgments: 

Bryon Gordon, Assistant Director, and Laura Heald, Analyst-in-Charge, 
managed the assignment. Cheri Harrington, Cara Jackson, Charlene 
Johnson, and Nathan Myers made significant contributions to this report 
in all aspects of the work. Shannon Groff and Ayeke Messam provided 
assistance in data collection; Cathy Hurley, Stuart Kaufman, and Jean 
McSween provided analytical assistance; Charlie Willson provided 
assistance on report preparation; Sheila McCoy provided legal support; 
Tina Cheng and Mimi Nguyen developed the report's graphics; and Lise 
Levie verified our findings. 

[End of section] 

Related GAO Products: 

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. Washington, D.C.: September 5, 2007. 

Teacher Quality: Approaches, Implementation, and Evaluation of Key 
Federal Efforts. 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. 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. 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. 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. 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. GAO-06-758. Washington, D.C.: August 4, 2006. 

No Child Left Behind Act: States Face Challenges Measuring Academic 
Growth. 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. 
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. 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. 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. GAO-05-879. Washington, D.C.: Sept. 20, 2005. 

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

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

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

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

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

[End of section] 

Footnotes: 

[1] Pub. L. No. 107-110. 

[2] 20 U.S.C. ï¿½ 6303(c). 

[3] 20 U.S.C. ï¿½ 6303(e). Title I allocations are made by formula to 
districts based in large part on the number of children from families 
below the poverty line in a district and thus may vary from year to 
year. The hold-harmless provision protects school districts from 
resulting declines when states calculate Title I set-asides for school 
improvement. As a result, after district allocations are determined, 
only district funding increases are available for the 4 percent set - 
aside. Thus, the effect of the set-aside and the hold-harmless 
provision is to reduce Title I funds for some districts but not others. 

[4] S.Rep. 109-103, at 229 (2005). 

[5] Arkansas, Florida, and North Carolina provided information on 
districts that received funds, but could not provide information on 
which schools received funds, and California provided a partial list of 
schools that received funds. 

[6] In each state, we met with officials in at least two districts and 
at least four schools. In one state we met with officials from four 
districts, and in several states, we met with officials from additional 
schools to gain perspective from a broad range of schools identified 
for improvement. 

[7] In this report, we refer to Title I, Part A of the ESEA, as 
amended, as "Title I." Other parts of Title I (Parts B through I) are 
targeted at specific populations or purposes and are commonly referred 
to by their program names, such as Even Start or Comprehensive School 
Reform. 

[8] States set their own academic standards for what constitutes 
proficiency. NCLBA does, however, require states to set two standards 
for high achievement--"advanced" and "proficient," to reflect a degree 
of mastery--and to set another standard for "basic" achievement to 
indicate the progress of the lower-achieving children toward mastering 
their state standards. 

[9] Students in grades 3 to 8 must be annually assessed in mathematics 
and reading or language arts, 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 5, grades 6 to 9, and grades 10 
to 12. In addition to annual assessments, high schools must include 
students' graduation rate, and elementary and middle schools must 
include one other academic indicator determined by the state to assess 
whether they made AYP. 

[10] 20 U.S.C. ï¿½ 6303(e). 

[11] 20 U.S.C. ï¿½ 6303(b)(1). 

[12] 20 U.S.C. ï¿½ 6303(c). 

[13] 20 U.S.C. ï¿½ 6303(b)(2). 

[14] 20 U.S.C. ï¿½ 6303(f). 

[15] In 2007, Congress appropriated $125 million for awards under 20 
U.S.C. ï¿½ 6303(g). States must apply for these grants, and the amount 
allocated to each state will be in proportion to elements in their 
fiscal year 2007 Title I funding allocation. 

[16] States 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. 

[17] Funds not used for the set-aside for school improvement would 
still be distributed to Title I schools in that state. 

[18] NCLBA generally requires states to set aside 2 percent of their 
Title I allocation in fiscal years 2002 and 2003 and 4 percent in 
fiscal years 2004 through 2007. 

[19] However, changes in a district's population of students living in 
poverty do not indicate the extent of poverty in the district: A 
district with a small population of students living in poverty may 
experience an increase in that population in a given year, while a 
district with a high percentage of students living in poverty may lose 
some of that population. The opposite could also occur. 

[20] Title I funds are appropriated on a forward-funded basis, and 
states and districts have a total of 27 months to obligate and expend 
these funds. For example, for fiscal year 2005, Title I appropriations 
were made available to schools on July 1, 2005, for obligation and 
expenditure through September 30, 2007. 

[21] These amounts represent the average amounts of school improvement 
funds available for schools identified for improvement based on the 
Title I set-aside amount and the number of schools identified for 
improvement in each state. These amounts do not represent the actual 
amount of funds schools received. 

[22] The number of schools identified for improvement in a state can be 
affected by state policies. Under NCLBA, states are required to develop 
academic standards and tests, measure student proficiency, and 
determine whether schools are meeting proficiency goals. Because these 
definitions can vary from state to state, the number of schools in 
improvement can also vary. 

[23] Our prior work has documented that 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. See GAO, No Child Left Behind Act: Education Should Clarify 
Guidance and Address Potential Compliance Issues for Schools in 
Corrective Action and Restructuring, GAO-07-1035 (Washington, D.C.: 
Sept. 5, 2007). 

[24] This figure is based on our data analysis, which excluded schools 
for which information was not available. In addition, this figure does 
not include data from three states that were unable to provide a list 
of schools that received Title I school improvement funds and includes 
information from one state that provided only partial data. 

[25] NCLBA requires that states, in allocating school improvement 
funds, give priority to districts that (1) serve the lowest-achieving 
students, (2) demonstrate the greatest need for such funds, and (3) 
demonstrate the strongest commitment to ensuring that such funds are 
used to enable the lowest-achieving schools to meet the progress goals 
in the school improvement plans. 20 U.S.C. ï¿½ 6303(c). 

[26] Under NCLBA, states are generally required to allocate at least 95 
percent of the school improvement set-aside to districts for schools 
identified for improvement to carry out activities described in the 
statute. The state may retain up to 5 percent to carry out its 
responsibilities, including implementing its statewide system of 
support. 

[27] States may either allocate these funds directly to districts for 
schools identified for improvement to be used for activities required 
under the school improvement section of the law or, with the approval 
of districts, retain funds to provide for these activities for schools 
identified for improvement 20 U.S.C. ï¿½ 6303(b). 

[28] NCLBA requires states to create and maintain a statewide system of 
support designed to increase the opportunity for all students and 
schools to meet the state's academic content and achievement standards. 

[29] Districts may also be designated for improvement if the district 
fails to make AYP for 2 consecutive years for all students or for any 
subgroup that misses its proficiency goals or participation rates. AYP 
for districts is based on aggregating the results of each school's 
academic achievement and other measures. In some cases, districts 
without any schools identified for improvement may themselves be 
identified for improvement when the minimum group size at individual 
schools was too small to identify the schools for improvement but was 
large enough on an aggregate level for the district to be identified 
for improvement. 

[30] 20 U.S.C. ï¿½ 6303(f). 

[31] On its What Works Clearinghouse, Education defined high-quality 
reviews as those that include randomized controlled trials and quasi- 
experimental designs, among others. Randomized controlled trials are 
studies in which participants are randomly assigned to an intervention 
group that receives or is eligible to receive the intervention and a 
control group that does not receive the intervention. Quasi- 
experimental designs are primarily designs in which participants are 
not randomly assigned to the intervention and comparison groups, but 
the groups are compared to each other. 

[32] See Education's LEA and School Improvement: Non-Regulatory 
Guidance (Washington, D.C.: July 21, 2006). 

[33] Education replaced its 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 with its 
Comprehensive Centers Program. 

[34] See Herbert J. Walberg, editor. Handbook on Restructuring and 
Substantial School Improvement (Center on Innovation and Improvement, 
Lincoln, Illinois: 2007), and Sam Redding and Herbert J. Walberg, 
editors. Handbook on Statewide Systems of Support (Center on Innovation 
and Improvement, Lincoln, Illinois: 2007). 

[35] Arkansas, Florida, and North Carolina provided information on 
districts that received funds, but could not provide information on 
which schools received funds, and California provided a partial list of 
schools that received funds. 

[End of section] 

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