Safe and Drug-Free Schools: Balancing Accountability With State and Local
Flexibility (Letter Report, 10/10/97, GAO/HEHS-98-3).

Pursuant to a congressional request, GAO reviewed: (1) the
accountability measures the Safe and Drug-Free Schools and Communities
Act requires at the federal, state, and local levels; (2) the activities
that the Department of Education uses for overseeing state and local
programs; (3) how state education agencies (SEA) ensure local programs'
compliance with the act; and (4) how Safe and Drug-Free Schools funding
is specifically used at the state and local levels.

GAO noted that: (1) the Safe and Drug-Free Schools program is one of
several substance abuse- and violence-prevention programs funded by the
federal government; (2) the act that authorizes the program requires
four major types of actions to ensure accountability on the federal,
state, and local levels: (a) an application process requiring approval
of state and local program plans; (b) monitoring activities by state
agencies; (c) periodic reports and evaluations; and (d) the use of local
or substate regional advisory councils; (3) Education oversees state
programs directly and local programs indirectly through required state
actions; (4) working along with states, Education reviews, helps states
to revise, and approves state plans; (5) Education has issued no
program-specific regulations on the act; (6) Education does require
states to conform to general and administrative regulations and advises
states on program matters, such as allowable expenditures, through
nonbinding guidance; (7) the Department may get involved in resolving
allegations of impropriety in the use of funds; (8) no overall
evaluations of the Safe and Drug-Free Schools program have been
completed; (9) Education conducts evaluation activities designed to
provide both descriptive and evaluative information about the programs;
(10) Education's evaluative activities focus on broader aspects of
program implementation; (11) Education is indirectly gathering
information about the effectiveness of specific state and local programs
through reports states must submit to Education every 3 years; (12) the
lack of uniformity in what states report may create a problem for
federal oversight; (13) nearly all states use the approved local plans
to ensure local programs' compliance with the act's requirements; (14)
states use local compliance with the approved plans as a way of ensuring
that funds are spent on activities permitted under the act; (15) most
states use both on-site visits and local self-reports to oversee local
program activities; (16) local education agencies (LEAs) are also
required to evaluate the effectiveness of their programs; (17) SEAs and
LEAs use Safe and Drug-Free Schools funds for a variety of activities;
(18) states mostly use their 5-percent set-aside for activities such as
training and technical assistance; (19) ninety-one percent of LEAs
provide drug-prevention instruction; and (20) staff training is the next
most offered activity.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-98-3
     TITLE:  Safe and Drug-Free Schools: Balancing Accountability With 
             State and Local Flexibility
      DATE:  10/10/97
   SUBJECT:  Education program evaluation
             Educational grants
             Intergovernmental relations
             Alcohol or drug abuse problems
             Project monitoring
             School districts
             Crime prevention
IDENTIFIER:  Dept. of Education Drug-Free Schools and Communities Program
             
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Cover
================================================================ COVER


Report to Congressional Requesters

October 1997

SAFE AND DRUG-FREE SCHOOLS -
BALANCING ACCOUNTABILITY WITH
STATE AND LOCAL FLEXIBILITY

GAO/HEHS-98-3

Safe and Drug-Free Schools

(104887)


Abbreviations
=============================================================== ABBREV

  ESEA - Elementary and Secondary Education Act of 1995
  IG - Inspector General
  LEA - local education agency
  RESAVIII - Regional Education Service Agency VIII
  SEA - state education agency

Letter
=============================================================== LETTER


B-277093

October 10, 1997

The Honorable J.  Dennis Hastert
Chairman, Subcommittee on National Security, International Affairs,
 and Criminal Justice
Committee on Government Reform and Oversight
House of Representatives

The Honorable Tom Harkin
Ranking Minority Member, Subcommittee on Labor, Health
 and Human Services, and Education
Committee on Appropriations
United States Senate

When the Safe and Drug-Free Schools and Communities Act was enacted
in 1994, about 3 million thefts and violent crimes occurred on or
near school campuses each year--nearly 16,000 incidents per school
day.  About one in five high school students regularly carried a
firearm, knife, razor, club, or other weapon.  After declining in the
eighties, drug use rates among school-age youth increased between
1992 and 1995 for more than 10 different types of drugs.  For
example, one study reported that the rate of marijuana use by eighth
grade students more than doubled--from about 7 to about 16
percent--and the rate for twelfth graders rose from about 22 to about
35 percent.\1

Since 1986, the federal government has awarded over $4 billion to
states for implementing school-based drug- and violence-prevention
programs authorized by the Drug-Free Schools and Communities Act and
its successor, the Safe and Drug-Free Schools and Communities Act of
1994.  One of the purposes of the Safe and Drug-Free Schools and
Communities Act is to help the nation's schools provide a disciplined
environment conducive to learning by eliminating violence in and
around schools and preventing illegal drug use. 

The Safe and Drug-Free Schools and Communities Act authorizes funding
at federal, state, and local levels for programs supporting this
purpose.  Under the largest program funded under the act, the
Department of Education awards grants to state education agencies
(SEA) mainly for further distribution to local education agencies
(LEA).  In school year 1995-96, $350 million of the $466 million
appropriated for expenditure under the act was awarded to SEAs.\2
(See fig.  1.)

   Figure 1:  How Funding Reaches
   States and Local Schools,
   Fiscal Year 1995

   (See figure in printed
   edition.)

Among the changes the Safe and Drug-Free Schools and Communities Act
made to the previous law were changes to increase accountability,
that is, to better ensure that the activities supported by these
funds are consistent with the act's general purposes.  The act and
its legislative history also indicate the importance of acknowledging
local differences in defining measurable goals and
objectives--differences reflecting local needs--and ways progress
toward them will be assessed and reported.  Under the act, SEAs and
LEAs are accountable for progress toward the goals and objectives
they set as well as for the federal dollars they spend.  Increased
accountability was a key issue raised in congressional deliberations
about the act:  critics of programs operated under the previous law
claimed that some of the activities were inappropriate and would not
contribute to accomplishing the goal of reducing student drug use. 

To address these concerns, you asked us to review the following:  (1)
accountability measures the Safe and Drug-Free Schools and
Communities Act requires at the federal, state, and local levels; (2)
activities Education uses for overseeing state and local programs;
(3) how SEAs ensure local programs' compliance with the act; and (4)
how Safe and Drug-Free Schools funding is specifically used at the
state and local levels.  To determine required accountability
measures, we reviewed the act and its legislative history.  To assess
Education's oversight measures, we reviewed documents at Department
headquarters and followed up on allegations of impropriety in three
states (Michigan, Virginia, and West Virginia), reviewing
documentation and interviewing state and local officials involved in
the alleged impropriety and its investigation and resolution (see
app.  I).  To assess compliance and other activities at the state and
local levels, we surveyed the 50 states, the District of Columbia,
and Puerto Rico about their activities and reviewed supporting
documentation, such as report forms and evaluation reports.  (See
app.  II.)


--------------------
\1 Monitoring the Future, National Institutes of Health, National
Institute on Drug Abuse (Rockville, Md.:  1996). 

\2 The remainder of the money under the state grants program is
distributed through the governors' program, which is used for grants
to or contracts with a variety of groups, organizations, and
agencies.  In general, each state's allocation is determined by the
size of its school-age population and the amount of part A, title I
funding the state received in the previous year for providing
supplementary educational services to low-achieving children in
high-poverty areas.  In school year 1995-96, the Safe and Drug-Free
Schools state grant provided $7.90 per student for illegal drug- and
violence-prevention programs. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The Safe and Drug-Free Schools program is one of several substance
abuse- and violence-prevention programs funded by the federal
government.  The act that authorizes the program requires a variety
of federal, state, and local actions to ensure accountability.  These
actions involve four major types of accountability mechanisms:  (1)
an application process, requiring approval of state and local program
plans; (2) monitoring activities by state agencies; (3) periodic
reports and evaluations; and (4) the use of local or substate
regional advisory councils.  In combination, these mechanisms address
accountability for both how funds are spent and progress toward
achieving national, state, and locally defined goals. 

Education oversees state programs directly and local programs
indirectly through required state actions.  Its state oversight is a
combination of activities required by the act and other generally
applicable requirements.  Working along with states, Education
reviews, helps states to revise, and, finally, approves state
plans--which include a description of planned state-level activities,
criteria for selecting high-need districts that will receive
supplemental funds, and plans for monitoring local activities--
before disbursing funds.  In addition, Education conducts on-site
monitoring visits.  To allow states and localities enough flexibility
to meet their needs, Education has issued no program-specific
regulations on the act.  Education does, however, require states to
conform to general and administrative regulations and advises states
on program matters, such as allowable expenditures, through
nonbinding guidance.  In addition, the Department may get involved in
resolving allegations of impropriety in the use of funds.  For
example, Education, in response to allegations about Drug-Free
Schools programs, reviewed programs in West Virginia and participated
in resolving adverse audit findings in Michigan. 

To date, no overall evaluations of the Safe and Drug-Free Schools
program have been completed.  In addition to its activities intended
to ensure that funds are spent appropriately, however, Education
conducts evaluation activities designed to provide both descriptive
and evaluative information about the programs.  The descriptive
information should document the nature and extent of school violence,
as well as the characteristics of federally funded
violence-prevention programs and their activities, including those of
the Safe and Drug-Free Schools program.  Education's evaluative
activities focus on broader aspects of program implementation, such
as promising practices and program improvement processes, but will
not specifically assess the effectiveness of all Safe and Drug-Free
Schools programs nationwide.  Instead, Education is indirectly
gathering information about the effectiveness of specific state and
local programs through reports states must submit to Education every
3 years.  The lack of uniformity in what states report, however, may
create a problem for federal oversight.  A survey of LEAs may provide
additional information on local program effectiveness, but that study
is still in the planning stages. 

Nearly all states use the approved local plans as the primary means
for helping to ensure local programs' compliance with the act's
requirements.  States use local compliance with the approved plans as
a way of ensuring that funds are spent on activities permitted under
the act.  Under the act, each state may establish its own reporting
requirements for LEAs.  Although these requirements have some common
elements--40 states require a program report, and 42 states require a
financial report--state requirements generally vary widely.  Most
states use both on-site visits and local self-reports to oversee
local program activities.  States also resolve allegations of
impropriety, as in the Virginia case we reviewed.  LEAs are also
required to evaluate the effectiveness of their programs, but most
states reported in our survey that they had little specific knowledge
of the content or results of these evaluations. 

SEAs and LEAs use Safe and Drug-Free Schools funds for a variety of
activities, as permitted by the act.  States mostly use their
5-percent set aside for activities, such as training and technical
assistance, although they also use the funds for such activities
related to curriculum development, violence prevention, state-level
evaluations, and demonstration projects.  Services provided by 60
percent or more of LEAs nationwide include drug-
prevention instruction for students; staff training; general
violence-
prevention instruction; special one-time events, such as guest
speakers, drug- and alcohol-free social activities, such as a dance
or picnic; parent education/involvement; student support services,
such as counseling and referral services; and curriculum development
and acquisition.  Ninety-one percent of LEAs provide drug-prevention
instruction.  Staff training is the next most offered activity, with
77 percent of districts reporting such training. 


   BACKGROUND
------------------------------------------------------------ Letter :2

In October 1994, the Improving America's Schools Act, which
reauthorized education programs under the Elementary and Secondary
Education Act of 1965 (ESEA), revised and expanded drug education
under the Safe and Drug-Free Schools and Communities Act of 1994,
which is title IV of ESEA.  The purpose of the Safe and Drug-Free
Schools Act is to create a comprehensive program to support National
Education Goal Seven, which is "by the year 2000, every school in the
United States will be free of drugs, violence, and the unauthorized
presence of firearms and alcohol and will offer a disciplined
environment conducive to learning." School year 1995-96 was the first
school year in which the program was in effect. 

Safe and Drug-Free Schools grants have some of the broad
characteristics of block grants that we have identified in previous
work.\3 For example, the act authorizes federal aid for a wide range
of activities within a broadly defined functional area; recipients
have substantial discretion to identify problems, design programs,
and allocate resources; federally imposed requirements are limited to
those necessary to ensure that national goals are being accomplished;
and federal aid is distributed on the basis of a statutory formula. 
For such grants, accountability plays a critical role in balancing
the potentially conflicting objectives of increasing state and local
flexibility, while attaining certain national objectives. 


--------------------
\3 Block grants provide significant discretion to states and
localities to define and implement federal programs according to
local needs and conditions.  For a complete list of the
characteristics of block grants as well as the issues involved in
ensuring accountability in block grant programs, see Block Grants: 
Issues in Designing Accountability Provisions (GAO/AIMD-95-226, Sept. 
1, 1995). 


      SAFE AND DRUG-FREE SCHOOLS
      PART OF EDUCATION'S
      STRATEGIC PLAN
---------------------------------------------------------- Letter :2.1

The Safe and Drug-Free Schools program is discussed as part of
Education's strategic plan required by the Government Performance and
Results Act of 1993\4 (the Results Act).  The Results Act requires
executive agencies, including Education, to develop a 5-year
strategic plan that includes long-term strategic goals,\5 establish
annual performance goals, and report on progress toward those goals
and objectives.  Education's draft strategic plan for 1998-2002
includes an objective for safe, disciplined, and drug-free schools.\6
Education's statement of core strategies for achieving this objective
make it clear that Safe and Drug-
Free Schools will play a major role.  In addition, the program is
specifically cited in one of the six performance indicators that
Education has chosen for assessing accomplishment of this objective. 
These indicators are to

  -- slow recently increasing rates of alcohol and drug use among
     school-aged children by 2000;

  -- achieve continuous decreases in criminal and violent incidents
     in schools by students between now and 2002;

  -- realize continuous improvement in the percentage of students
     reporting negative attitudes toward drug and alcohol use between
     now and 2002;

  -- improve prevention programs by having the majority of LEAs
     participating in the Safe and Drug-Free Schools program use
     prevention programs based on Education's principles of
     effectiveness by 1999;\7

  -- ensure, by 1999, that all states collect data statewide on
     alcohol and drug use among students and violence in schools; and

  -- increase significantly by 2000 the number of teachers who are
     appropriately trained to address discipline problems. 


--------------------
\4 The Government Performance and Results Act of 1993 is intended to
improve the efficiency and effectiveness of federal programs by
establishing a system to set goals for program performance and to
measure results.  Specifically, the Results Act requires executive
agencies to prepare multiyear strategic plans and annual performance
plans and reports.  For general information on implementation of the
Results Act, see The Government Performance and Results Act:  1997
Governmentwide Implementation Will Be Uneven (GAO/GGD-97-109).  For
specific information on Education's plan, see The Results Act: 
Observations on the Department of Education's June 1997 Draft
Strategic Plan (GAO/HEHS-97-176R, July 18, 1997). 

\5 The first 5-year strategic plan must be submitted to the Congress
by Sept.  30, 1997. 

\6 See U.S.  Department of Education:  Strategic Plan, 1998-2002,
Draft for Consultation and Review (Washington, D.C.:  June 17, 1997). 

\7 These principles were published in a notice soliciting public
comments in the July 16, 1997, edition of the Federal Register.  The
principles would require LEAs to develop Safe and Drug-Free programs
on the basis of an objective analysis of the need for drug- and
violence-prevention services and to use program approaches whose
effectiveness has been demonstrated through research. 


      OTHER FEDERAL LAWS AND
      REGULATIONS ALSO SET
      ACCOUNTABILITY REQUIREMENTS
      FOR SAFE AND DRUG-FREE
      SCHOOLS PROGRAM
---------------------------------------------------------- Letter :2.2

The Safe and Drug-Free Schools program, like other Education
programs, is subject to other federal laws and generally applicable
regulations in the use of its funds and program operations.  For
example, the Education Department General Administrative Regulations
apply to the Safe and Drug-Free Schools and Communities program as
well as other grant programs.  These regulations establish uniform
requirements for administering Education grants and principles to
determine costs for activities assisted by the Department.  In
addition, the Single Audit Act requires each state to conduct annual
independent audits of programs in the state that receive federal
funds. 

Some aspects of the Safe and Drug-Free Schools program are also
affected by the general provisions of the Improving America's Schools
Act of 1994.  In particular, the Improving America's Schools Act
authorizes states to submit a single application for several federal
education programs rather than separate program-specific
applications.  The new consolidated application process, which began
with school year 1995-96 funds for Education programs, including the
Safe and Drug-Free Schools program, is intended to enhance program
integration and reduce SEAs' administrative burden. 

The Improving America's Schools Act also requires Education to
establish procedures and criteria under which a SEA may submit a
consolidated application or plan.  Education's guidelines state that
the consolidated plan should provide a framework for determining,
within the context of a state's school reform plan and other reform
initiatives, how the federal programs in the consolidated plan will
be used to help all children reach the state's academic achievement
goals.\8

Education's guidance for the consolidated applications requires
states to include some, but not all, of the information required in
comprehensive state plans by the Safe and Drug-Free Schools and
Communities Act.  States must include in their consolidated
application their criteria for selecting LEAs for supplemental
high-need funding, their plans for spending the 5-percent set aside
for state-level program activities, and their process for approving
local plans for funding. 


--------------------
\8 If a state submits and has approved a consolidated application,
rather than a comprehensive one, the state may require LEAs receiving
funds from more than one program to submit consolidated LEA
applications that cover all applicable programs. 


      MANY PROGRAMS SUPPORT
      NATIONAL SAFE AND DRUG-FREE
      SCHOOLS GOAL
---------------------------------------------------------- Letter :2.3

While the Safe and Drug-Free Schools program's explicit goal is to
reduce drug use and violence in schools, other programs are also
likely to influence progress toward this national goal.  The Safe and
Drug-Free Schools program is one of several substance abuse- and
violence-
prevention programs funded by the federal government.  For example,
in fiscal year 1995, 70 federal programs were authorized to provide
either substance abuse-prevention or violence-prevention services or
both to the youth they serve.\9 Thirty-four of these programs could
provide both types of prevention services.  Education, which
administers the Safe and Drug-Free Schools program, along with the
Departments of Health and Human Services and Justice, administered
most of these programs, 48 in all, but the rest of the programs were
disbursed among 10 other federal agencies or entities.  For these 70
programs, the fiscal year 1995 appropriations for services to youth
totaled at least $2.4 billion. 

Multiple programs dispersed among several agencies creates the
potential for inefficient services and ineffective use of funds. 
Although we have not fully examined these multiple programs, the
implications of having multiple, unintegrated substance abuse- and
violence-prevention programs might be like those for employment
training programs--an area we have examined.  In fiscal year 1995, we
identified 163 federal employment training programs located in 15
departments and agencies.  We recently concluded that consolidating
these programs could probably reduce the cost of providing job
training services because of the efficiencies achieved by eliminating
duplicative administrative activities.  Furthermore, consolidating
similar programs could improve opportunities to increase service
delivery and effectiveness.\10


--------------------
\9 See Substance Abuse and Violence Prevention:  Multiple Youth
Programs Raise Questions of Efficiency and Effectiveness
(GAO/T-HEHS-97-166, June 24, 1997). 

\10 See Department of Labor:  Challenges in Ensuring Workforce
Development and Worker Protection (GAO/T-HEHS-97-85, Mar.  6, 1997). 


      QUESTIONS RAISED ABOUT
      PROGRAM EXPENDITURES AND
      ACTIVITIES
---------------------------------------------------------- Letter :2.4

During the past several years, some members of the Congress, in
response to constituents' concerns, have questioned how some states
and localities have used funding under both the Drug-Free Schools and
Communities Act and Safe and Drug-Free Schools and Communities Act
programs.  Allegations about misuse of funds have spanned diverse
areas of program operation, from curriculum content to administrative
expenses.  In particular, questions have been raised about the extent
to which these funds can be used to support programs, such as
comprehensive health education programs, of which drug prevention is
just one part; the types of activities sponsored by schools, such as
alcohol-free dances; and expenditures for materials, such as pencils
and tee-shirts imprinted with drug- and violence-prevention messages
(see app.  I for the results of our examination of some allegations). 


   ACT REQUIRES FEDERAL, STATE,
   AND LOCAL ACTIONS TO ENSURE
   ACCOUNTABILITY
------------------------------------------------------------ Letter :3

The Safe and Drug-Free Schools and Communities Act establishes
accountability mechanisms at the federal, state, and local levels. 
In combination, these mechanisms provide accountability for both
spending funds (financial accountability) and reaching national,
state, and locally defined goals (program accountability).  The act
specifies no mechanisms for direct federal oversight of local
activities.  Rather, the act's mechanisms for federal oversight of
the program focus on state-level programs and activities, while
relying on state actions for local program oversight.  The act
establishes four types of accountability mechanisms:  (1) an
application process that requires approval of state and local plans;
(2) state monitoring of LEAs' programs; (3) reports on national,
state, and local program effectiveness; and (4) LEAs' use of advisory
councils to develop program plans and assist program implementation. 


      FEDERAL REQUIREMENTS FOCUS
      ON STATE PLANS, NATIONAL
      ASSESSMENTS
---------------------------------------------------------- Letter :3.1

Education executes two of the four actions required by the act for
ensuring accountability in the Safe and Drug-Free Schools program: 
approving state plan applications and reporting on national, state,
and local program effectiveness.\11

The act requires Education to review and ensure that state plans for
Safe and Drug-Free Schools programs conform with federal requirements
before providing funding to a state.  The act also directs Education
to use a peer review or similar process in reviewing state plans and
provides detailed requirements for the contents of the state plan. 
For example, under the act, states must include in their plans (1)
measurable goals and objectives for their drug- and violence-
prevention programs, (2) a description of state-level program
activities, (3) their plans for monitoring LEAs' programs, and (4)
the state's criteria for identifying high-need districts that will
receive supplemental funding for drug- and violence-prevention
programs. 

The act also requires Education to gather data about school violence
and drug abuse and to assess the effectiveness of drug- and violence-
prevention activities under the Safe and Drug-Free Schools program
and other recent federal initiatives.  Education expects to report
the results of these assessments, along with its recommendations, to
the Congress by January 1998.  The act also requires, indirectly,
that Education collect data from states on the effectiveness and
outcomes of state and local programs.  That is, under the act, LEAs
must provide the state with information about their programs'
effectiveness, which states must then use in their required reports
to Education. 


--------------------
\11 The application approval action also includes approval of local
plans for which states are responsible. 


      FEDERAL REQUIREMENTS FOR
      STATES FOCUS ON OVERSIGHT OF
      LOCAL PROGRAMS
---------------------------------------------------------- Letter :3.2

Under the act, states must use application approval, program
monitoring, and reporting as accountability mechanisms for ensuring
that Safe and Drug-Free Schools programs conform with federal
requirements.  States must review applications from LEAs to determine
if they are eligible for funding.  Through the application process,
states must ensure that each LEA receiving funds has (1) measurable
goals for its drug- and violence-
prevention program, (2) objectively assessed students' current use of
drugs and alcohol as well as violence and safety problems in its
schools, and (3) developed plans for a comprehensive drug- and
violence-
prevention program.  The comprehensive plan must describe how the LEA
will use its funds; coordinate its efforts with communitywide efforts
and other related federal, state, and local programs under this or
other acts; and report progress toward the LEA's drug- and
violence-prevention goals.  In addition, states may also require the
submission of other necessary information and assurances.  The act
requires each state to monitor local program implementation and
report to Education on its progress toward its drug- and
violence-prevention goals. 

Although the act lists several general oversight responsibilities for
states, it does not clearly specify actions states must take to meet
these responsibilities.  For example, although states must monitor
local program implementation, the act leaves states to determine how
to do this.  In addition, it authorizes states to develop their own
reporting requirements for LEAs and determine when LEAs must report
on their programs. 

The act requires LEAs to consult with local or substate regional
advisory councils in developing applications for state funds.  These
councils also regularly review program evaluations and other relevant
material and make recommendations to LEAs for improving drug- and
violence-
prevention programs.  In addition, these councils distribute
information about drug- and violence-prevention programs, projects,
and activities conducted by LEAs and advise LEAs on coordinating such
agency activities with other related programs, projects, and
activities as well as on the agencies administering such programs,
projects, and activities.  Education's General Administrative
Regulations require the state to oversee the LEA programs to ensure
that such advisory councils are used as intended.  Because the focus
of our analysis was to describe and assess the accountability
measures used at the federal and state levels, we did not assess how
these advisory councils operate at the local level. 


      ACT ALSO SETS REQUIREMENTS
      FOR PROGRAM CONTENT AND
      ACTIVITIES
---------------------------------------------------------- Letter :3.3

The act, in addition to establishing actions federal, state, and
local agencies must take to ensure accountability, has some
requirements for program content and the types of activities
permitted under the law.  These requirements are broadly stated,
permitting significant discretion at the state and local levels.  The
act also includes some prohibitions on how funds may be used and
restricts Education's activities regarding curriculum that may be
used in state and local programs. 


      COMPREHENSIVE PROGRAMS
      MANDATED
---------------------------------------------------------- Letter :3.4

Local drug- and violence-prevention programs under the act must be
comprehensive.  The act requires that comprehensive programs be
designed for all students and employees.  Programs for students must
be designed to prevent use, possession, and distribution of tobacco,
alcohol, and illegal drugs; prevent violence and promote school
safety; and create a disciplined environment conducive to learning. 
For employees, the program must be designed to prevent the illegal
use, possession, and distribution of tobacco, alcohol, and illegal
drugs.  The act also requires these comprehensive programs to include
activities that promote the involvement of parents and coordination
with community groups and agencies. 


         ACTIVITIES ALLOWED
-------------------------------------------------------- Letter :3.4.1

The act identifies a wide range of programs and activities that a LEA
may include in its comprehensive program, though the act does not
limit LEAs to the examples it provides.  For example, programs noted
as permissible include comprehensive drug prevention; comprehensive
health education, early intervention, student mentoring, and
rehabilitation referral programs that promote individual
responsibility and offer techniques for resisting peer pressure to
use illegal drugs; and before- and after-school recreational,
instructional, cultural, and artistic programs in supervised
community settings.\12

Activities allowed for these programs include the distribution of
drug-
prevention information; professional development of school personnel,
parents, and law enforcement officials through activities such as
workshops and conferences; implementation of strategies that
integrate services to fight drug use such as family counseling, early
intervention activities to prevent family dysfunction and enhance
school performance; and activities designed to increase students'
sense of community such as community-service projects.  Funds may
also be used for metal detectors, safe-passage zones--crime- and
drug-free routes students may take to and from school--and security
personnel; such uses, however, are limited to no more than 20 percent
of a LEA's funds and are allowed only if a LEA has not received other
federal funding for these activities.  The law explicitly prohibits
use of program funds for construction (except for minor remodeling),
medical services, or drug treatment or rehabilitation. 


--------------------
\12 The emphasis on a comprehensive program and the wide range of
activities allowed by the act are consistent with the findings of our
previous studies:  see Drug Control:  Observations on Elements of the
Federal Drug Control Strategy (GAO/GGD-97-42, Mar.  14, 1997); School
Safety:  Promising Initiatives for Addressing School Violence
(GAO/HEHS-95-106, Apr.  25, 1995); and Adolescent Drug Use
Prevention:  Common Features of Promising Community Programs
(GAO/PEMD-92-2, Jan.  16, 1992). 


      MATERIALS AND CURRICULA
      ALLOWED
---------------------------------------------------------- Letter :3.5

Materials used in Safe and Drug-Free Schools programs must convey a
clear and consistent message that the illegal use of alcohol and
other drugs is wrong and harmful.  The Secretary of Education may not
prescribe the use of any specific program curricula but may evaluate
the effectiveness of the curricula and strategies used. 


      DISTRIBUTION OF FUNDS
---------------------------------------------------------- Letter :3.6

Most of the funds for state and local drug- and violence-prevention
programs must be distributed to LEAs.  From the funds awarded to SEAs
for state and LEA grant activities, SEAs may reserve no more than 5
percent for statewide activities and no more than 4 percent for
program administration.  The remaining funds (at least 91 percent)
must go to LEAs; in school year 1995-96, this amounted to $313
million.  Thirty percent of this amount, $94 million in school year
1995-96, must go to LEAs that the state has determined have the
greatest need for additional funds to carry out drug- and
violence-prevention programs.  The act requires states to provide
these supplemental funds to no more than 10 percent of the state's
LEAs, or five such LEAs, whichever is greater. 


   EDUCATION USES STATE
   APPLICATION PROCESS,
   MONITORING, AND REPORTS FOR
   PROGRAM OVERSIGHT
------------------------------------------------------------ Letter :4

Education uses several mechanisms to execute its responsibilities for
ensuring program accountability.  Some of these mechanisms are
required by the Safe and Drug-Free Schools and Communities Act;
others are required or permitted under other generally applicable
laws and regulations such as the Single Audit Act and the Education
Department General Administrative Regulations.  Some of these
activities--such as the application review process--are intended to
ensure that program activities and expenditures comply with federal
requirements.  Others seek to determine if programs are addressing
national goals. 


      PLANS FORM BASIS FOR
      ACCOUNTABILITY
---------------------------------------------------------- Letter :4.1

State and local plans form the basis for Safe and Drug-Free Schools
accountability.  States cannot get Safe and Drug-Free Schools funds
without submitting a plan consistent with the act and approved by
Education.  Education reviews states' plans for compliance with the
act and other federal requirements and for program quality.  In
addition, state plans provide Education with detailed information on
what states want to accomplish with their funding and their program
management strategy. 


      EDUCATION PROPERLY REVIEWED
      APPLICATIONS FOR SCHOOL
      YEARS 1995-96 AND 1996-97
---------------------------------------------------------- Letter :4.2

Our review of Education's files on 16 state plans for school years
1995-96 and 1996-97\13 showed that Education, as required by the act,
reviewed state plans and required states to revise plans that did not
conform with the law's requirements before disbursing funding to the
states.  Education reviewed each application to ensure the
completeness and sufficiency of the information provided.  When
reviewers identified missing or inadequate information, they asked
the states to provide additional information, and Education notified
states on time that they would receive their grant awards. 

For school year 1996-97, states submitted their plans on time, and
Education again reviewed the plans for conformity with federal
requirements.  Although Education sometimes requested additional
information from states before awarding Safe and Drug-Free Schools
funding, the Department also approved some state plans conditionally. 
In these cases, Education specified in states' grant award documents
additional time--1 year--for them to revise their plans to conform
with federal requirements. 

Education established procedures for its review of state plans and
provided its staff with checklists and other forms on which to
document the results of these reviews.  These procedures varied
little for the 2 years encompassing our review.  Education documented
the results of its review in departmental records, including at least
a copy of each state's plan, the reviewers' comments, material from
each state responding to Education's request for supplemental
information, and grant award documents. 

In both years, Education's review included checks for compliance with
the act.  For example, Safe and Drug-Free Schools program staff
initially reviewed plans, checking to make sure each state plan had
all of the law's required assurances, signatures, and plan
components.  Education asked states whose plans did not pass this
review to supply the missing information.  Program staff also read
state plans, documenting any planned activities that failed to
conform with or fully satisfy federal requirements.  Program staff
then shared the results of this review with state officials,
requested additional information, or suggested plan revisions. 

Education also reviewed state plans for quality as part of its plan
approval process for the 2 years we reviewed.  For school year
1995-96 plans, Education's Safe and Drug-Free Schools program staff
conducted this review and raised questions with state officials about
a variety of program quality issues such as the planned program's
ability to address assessed needs.  For school year 1996-97 plans,
Education used a peer review process, with program staff from various
Office of Elementary and Secondary Education programs as reviewers
along with external experts.  Education's process for the quality
review was essentially the same for 1996-97 plans as it had been for
1995-96 plans. 


--------------------
\13 We reviewed files for the following states:  Connecticut,
Delaware, Illinois, Indiana, Iowa, Massachusetts, Michigan, Missouri,
Nebraska, Nevada, New York, Rhode Island, Tennessee, Texas, West
Virginia, and Wyoming. 


      EDUCATION CONDUCTS
      MONITORING ACTIVITIES
---------------------------------------------------------- Letter :4.3

Education also monitors states' activities.  Monitoring activities
include state and local visits, reviews of state audit findings, and
investigations by Education's Inspector General (IG).  Each
monitoring visit involves an initial visit to a SEA; subsequent
visits to local school districts may also be a part of the monitoring
visit. 

Until September 1994, Education's on-site monitoring visits were
program specific; that is, they were made only to review Drug-Free
Schools' state and local program activities.  In school year 1993-94,
Education conducted program-specific monitoring reviews in three
states; in school year 1994-95, Education conducted two such reviews. 
The Department used a variety of criteria to select states for
on-site reviews, including complaints. 

In September 1994, however, Education changed the way it conducted
on-site monitoring reviews.  The Department's new process--called an
integrated review process--uses an entire team of Education
officials\14 representing all the federal education programs in which
a state participates to review a state's use of federal aid to reach
its educational goals.  Education piloted this integrated review
process in school year 1994-95, visiting five states.  In school year
1996-97, Education visited 20 states to conduct integrated reviews,
which included reviews of Safe and Drug-Free Schools programs. 

In addition, the Department has in the past visited states to resolve
allegations of impropriety related to the use of funds under the
Drug-Free Schools and Communities Act.  Education did so in West
Virginia in 1992 and in resolving adverse audit findings in Michigan
in 1994.  In West Virginia, Education received a complaint letter
from a parent and directed the state superintendent of education to
investigate.  Education officials twice visited West Virginia--first
in 1992 and again in 1994--in response to complaints about the
curriculum used in one LEA's Drug-Free Schools program.  As part of
their review, federal officials interviewed state and local education
officials and reviewed relevant curriculum materials. 

In Michigan, state auditors questioned some LEA expenditures under
the Drug-Free Schools and Communities Act.  The findings were
reviewed by Education's IG and the program staff.  The Department
sustained some findings but disallowed others.  (See app.  I.)

Education also uses its reviews of state audit findings and on-site
IG reviews to stay informed of state activities.  Each year, states'
federally funded programs must be independently audited as part of
the federally required single state audit process.\15 These
audits--which may include the Safe and Drug-Free Schools
program--identify specific findings, such as expenditures not
allowable under the authorizing legislation.  These findings are
resolved by the Assistant Secretary, Office of Elementary and
Secondary Education, who sustains or rejects the findings after
considering information provided by the auditor and auditee.  The
single state audits have uncovered improper and questionable
expenditures in state and local programs.  For example, state
auditors in Michigan uncovered questionable state expenditures of
federal Drug-Free Schools and Communities Act funding.  Their
findings triggered a state legislative review of the program. 

In the last 3 fiscal years, Education's IG has conducted two studies
of activities under Drug-Free Schools.\16 A citizen's complaint
prompted a 1995 audit of certain financial matters in the
administration of the West Virginia program.  In response to the
complaint, Education's IG sought to determine if one of West
Virginia's regional education service agencies was administering its
Drug-Free Schools program in compliance with applicable federal acts
and regulations.\17

More recently, in February 1996, the IG issued a report describing
the programs offered in nine local Drug-Free Schools programs in
eight states.\18

Although the IG work plan for fiscal years 1996 and 1997 includes no
audits of any Safe and Drug-Free Schools activities, the 1997-98
draft work plan includes two audits of Safe and Drug-Free Schools and
Communities Act activities.  The first audit would examine the use of
Safe and Drug-Free Schools funds and the amount of such funding
reaching the classroom.  The second audit would review program
performance indicators.  In addition, Education issued an audit
supplement in June 1996 providing further guidance that will be used,
for example, when states audit Safe and Drug-Free Schools activities. 
The supplement, which pertains to several Education programs amended
by the Improving America's Schools Act, will be used immediately by
the states to conduct audits of school year 1995-96 program grantee
activities.  Suggested audit procedures include reviews of funded
activities, expenditures, and other related records to determine
whether Safe and Drug-Free Schools funds were used for any prohibited
activities. 


--------------------
\14 The team is called a regional service team and includes staff
from program offices in the Office of Elementary and Secondary
Education.  Education has divided the country into eight regions;
each region has six to eight states.  Each regional service team
oversees the federally funded programs and provides technical
assistance to the states in its region. 

\15 The Single Audit Act requires states and local entities to
undergo a comprehensive single audit of their financial operations. 
Some states and local entities, however, are excluded from the
requirements because the funding is lower than thresholds established
by the law.  States submit their audit reports to the Single Audit
Clearinghouse.  The Clearinghouse sends reports with findings
directly to the Office of the Chief Financial Officer, who then
distributes the appropriate sections of the reports to the relevant
program offices for resolution. 

\16 According to Education officials, most IG staff are assigned to
work on the larger Student Financial Assistance programs.  IG staff
in areas not related to the student financial assistance programs
focus on programs scheduled for upcoming reauthorization. 

\17 See app.  I for a more detailed explanation of the allegations
and subsequent investigations. 

\18 Correspondence to the Honorable William H.  Zeliff, Jr.  dated
Feb.  8, 1996, from Steven A.  McNamara, Assistant Inspector General
for Audit, U.S.  Department of Education. 


      EDUCATION TO REPORT ON
      PROGRAM PERFORMANCE AND
      EFFECTIVENESS
---------------------------------------------------------- Letter :4.4

As required by the act, Education is gathering information about the
Safe and Drug-Free Schools program.  Overall, Education's data
collection and evaluation activities comprise a (1) national
evaluation of drug- and violence-prevention activities, including
those funded under the Safe and Drug-Free Schools program;\19 (2)
national data collection on violence in schools; (3) national survey
to gather information about local program improvement activities; and
(4) compilation of state-level reports on program effectiveness and
progress toward state- and locally defined goals for drug and
violence prevention.  Education plans to provide information from
these components, except the survey of LEAs, to the Congress in
January 1998.  No date has been established for reporting results of
the local survey. 


--------------------
\19 Under the previous Drug-Free Schools and Communities Act,
Education sponsored a number of studies on drug-prevention
activities.  These studies included a required biennial survey of
SEAs that obtained information on program characteristics and state
administrative activities, an assessment of student outcomes in
drug-prevention programs, and a longitudinal study of drug-prevention
activities in 19 school districts that provided information on
promising practices and program effectiveness. 


         NATIONAL STUDIES PROVIDE
         INFORMATION ON SCHOOL
         VIOLENCE-PREVENTION
         ACTIVITIES
-------------------------------------------------------- Letter :4.4.1

Education, in collaboration with the National Institute of Justice,
has begun to evaluate the impact of violence-prevention programs as
required by the act.\20

The evaluation is designed to describe the types of activities funded
with federal violence-prevention moneys, including Safe and Drug-Free
Schools funds, and to identify the most promising practices among
these activities.  To acquire this information, the evaluation will
compare matched pairs of schools with similar characteristics, but
dissimilar safety profiles, to determine why the schools differ on
certain safety measures.  The evaluation should provide information
about the effectiveness of specific interventions, officials told us,
such as peer mediation, as well as broader influences on program
effectiveness, such as school order and organization and class size. 
It will not describe the effectiveness of specific Safe and Drug-Free
Schools and Communities programs nationwide. 

In addition to evaluating violence-prevention programs, Education,
through its Center for National Education Statistics, is gathering
descriptive data on violence in the nation's schools.  The data were
obtained by survey from a nationally representative sample of schools
and, in conjunction with existing national databases, will provide
detailed information on the extent and nature of violence in schools. 


--------------------
\20 Education's collaboration with the National Institute of Justice,
a part of the U.S.  Department of Justice, will build on and expand a
National Institute of Justice study.  Education officials say the
collaborative effort will allow the inclusion of more programs in the
study. 


         LOCAL SURVEY ON PROGRAM
         IMPROVEMENT PLANNED
-------------------------------------------------------- Letter :4.4.2

Although not required by the act, Education officials told us they
plan to survey a nationally representative sample of LEAs
participating in the Safe and Drug-Free Schools program to examine
program improvement at the local level.  The survey, designed to gain
information about LEAs' assessment of program effectiveness and their
use of such information in ongoing program implementation, will ask
LEAs to report the goals and objectives established for their Safe
and Drug-Free Schools programs and the measures they use to assess
progress toward these goals.  Though plans for the survey have not
been completed, Education officials report that this survey should be
the first of periodically administered surveys to obtain this
information. 


         STATE TRIENNIAL REPORTS
-------------------------------------------------------- Letter :4.4.3

The state-level reports on program effectiveness required by the act
are likely to be the primary source of information about Safe and
Drug-Free Schools programs' effectiveness, both nationally and
locally.  Education--
though not required to do so--has provided states with suggested
program performance indicators that may be used to assess and report
program effectiveness.  However, it is uncertain to what extent data
from these indicators will provide information about the
effectiveness of Safe and Drug-Free Schools and Communities programs. 
First, states do not have to use Education's indicators but may
develop and use their own indicators.  Second, though the indicators
were made available to states in draft form in August 1996, states
did not receive the completed data collection instrument until
December 1996.  As a result, variability in state data collection
efforts may prevent some states from providing the desired
information, and Education officials acknowledge this.  Expecting
difficulties in aggregating data from the state-level reports, the
Department is working with a private contractor to categorize and
summarize the data.  Education officials expect state data to conform
more closely with Education's performance indicators, they said, as
states become more familiar with the form and have a chance to adjust
their own data collection systems. 

Although the act requires reports every 3 years, Education is
providing states with a mechanism to furnish yearly information. 
Education has no information yet to estimate how many states, if any,
will provide information more often than every 3 years. 


   STATES REVIEW AND APPROVE LOCAL
   PLANS AND MONITOR ACTIVITIES
------------------------------------------------------------ Letter :5

Nearly all states use approved local plans as the primary means for
ensuring a local program's compliance with the act's requirements as
well as a variety of other methods.  States' use of the plans to
ensure compliance often begins when LEAs submit their plans for state
approval, with states using the approval process to ensure that a
LEA's planned program conforms with the act's requirements.  Once
local plans have been approved, state officials monitor local
programs, they said, using site visits, telephone contacts, and
reviews of reports submitted by LEAs of their program activities and
expenditures.  A few states reported using a combination of these
methods to oversee local programs. 


      STATE PRACTICES EMPHASIZE
      PLANNING AND CONFORMANCE TO
      PLANS
---------------------------------------------------------- Letter :5.1

States must approve local plans before a LEA may receive its Safe and
Drug-Free Schools grant.  State approval, however, is not automatic. 
Ninety-six percent of the state officials responding to our survey
said some LEAs had to revise their plans to obtain state approval.  A
plan could be judged unacceptable for minor or rather major reasons,
state officials told us.  For example, a plan lacking all the
appropriate signatures might require only minor revisions.  Other
plans, however, such as those lacking measurable goals and objectives
or those with budgets that were incongruent with the planned program
activities, might require more substantial revision.  Most local
plans, however, are eventually successfully revised and gain state
approval.  In school year 1995-96, only a small percentage of LEAs
did not receive Safe and Drug-Free Schools funding because their
plans were not approved, state officials told us. 


         STATE PROCESS VARIES FOR
         REVIEW OF LEA PLANS
-------------------------------------------------------- Letter :5.1.1

The act requires states to use a peer review or other method of
ensuring the quality of applications.  More than half the states use
a peer review process.  Officials in 29 states told us they use a
peer review process; in 19 of those states, the peer reviewers'
decisions are binding.  The composition of peer review panels varies
by state.  In some states, peer review panel members include
representatives from the LEAs.  Georgia and Virginia, for example,
are among the states that reported using LEA representatives as peer
reviewers.  In other states, such as Colorado, Alabama, and Idaho,
peer reviewers come from diverse groups such as the SEA's staff, Safe
and Drug-Free Schools advisory group, and local drug-prevention
experts.  States that reported using no peer review panel told us
that SEA officials review and approve local plans. 

In the states we visited, officials use their review of local plans
to ensure that LEAs' planned activities conform with the act's
requirements.  West Virginia's coordinator told us that she reviews
each local plan for compliance.  In Michigan, state officials must
certify in writing that each approved local plan conforms with the
act's requirements.  We heard similar anecdotal evidence when we
spoke with our survey respondents.  For example, officials in Arizona
and Nebraska also reported reviewing local plans for compliance as
part of the local plan approval process. 


      STATES USE VARIETY OF
      MECHANISMS TO MONITOR LOCAL
      PROGRAMS
---------------------------------------------------------- Letter :5.2

States reported that they monitor local activities and expenditures,
in accordance with the act, using a variety of mechanisms, such as
site visits and document reviews.  Most state Safe and Drug-Free
Schools officials who use site visits to monitor said site visits are
the most effective method for monitoring LEA activities.  Documents
reviewed by states include program and expenditure reports from LEAs. 
States use the local plan to monitor program compliance as well as to
develop the framework for site visit observations.  A few state
officials also cited several barriers to monitoring local activities. 
The most prominent of these are resource shortages, that is, lack of
staff and time. 

State officials oversee local programs by visiting LEAs, reviewing
LEAs' program and expenditure reports, as well as making phone
contacts.  In school year 1995-96, state officials in 48 states\21
and Puerto Rico reported making more than 1,900 site visits to local
programs; 18 states, Puerto Rico, and the District of Columbia used
site visits more frequently than any other oversight method. 
Although 22 states reported making regular site visits, 12 states
selected the sites they visited randomly.  Nineteen states reported
visiting sites on the basis of LEA requests or complaints.  States
also selected sites to visit on the basis of other criteria such as
the need for technical assistance, the amount of carryover funds, and
whether the LEA had received additional funding because it was
considered "high need."

When asked how often they expected to perform site visits to local
programs, 16 states that performed site visits in school year 1995-96
said they expected to visit each local program once every 3 years. 
Only 3 states, the District of Columbia, and Puerto Rico expected
yearly visits; 19 states said they expected to visit programs every 3
to 4 years.  Site visits include a wide range of activities, from
reviewing program records to on-site observations, state officials
told us.  Most of the states that conducted site visits in school
year 1995-96, however, reported the following common activities: 
examining program and financial records; reviewing the local
curriculum; and interviewing staff, students, and parents. 

In addition to site visits, state officials in 31 states and the
District of Columbia said they oversee local programs by reviewing
documents provided by LEAs.  Nine states reported this as the most
often used monitoring method.  Only five states reported using phone
calls or technical assistance contacts as the most often used method
for monitoring local activities.  (See table III.6 in app.  III.)

The states we visited use most of the mechanisms cited by our survey
respondents to monitor LEAs' program activities and expenditures. 
For example, Michigan and West Virginia use site visits and reviews
of LEAs' program and expenditure reports to ensure that programs are
implemented in compliance with the act.  West Virginia's coordinator
told us she also uses telephone contacts as a monitoring mechanism. 
Virginia's coordinator, citing staff shortages as the reason the
state could not visit sites in school year 1995-96, said the state
relies on its review of LEA expenditure reports to monitor LEA
programs.  Although the three states' local reporting requirements
differ somewhat, each state requires LEAs to submit an annual
progress report, including information on their programs' activities
and expenditures as well as expenditure reports. 

State officials have established standard policies and procedures for
site visits, our research revealed.  Michigan's Office of Drug
Control Policy, for example, has developed a "Local Program Review
Guide" that SEA staff must use when monitoring LEA sites.  The guide
has specific questions about the local program's characteristics,
such as curriculum content, parental involvement, and the local
advisory council.  The state reviewer must document findings for each
characteristic.  The guide also specifies the type of documentation
to be used.  West Virginia has also written policies and procedures
to guide monitoring practices.  In addition to reviewing program
records, West Virginia's State and Drug-Free School coordinator said
she conducts interviews with local program administrators and
actually observes program activities.  Beginning in the 1996-97
school year, she told us, she also plans to include a review of local
vouchers in her site visit activities in response to a recommendation
by the state auditor. 


--------------------
\21 Because Hawaii has only one LEA, it is not a part of these
analyses.  Rhode Island reported that it does not monitor LEAs. 


      PERIODIC FISCAL AND PROGRAM
      REPORTS AND EVALUATIONS
      REQUIRED
---------------------------------------------------------- Letter :5.3


         LOCAL PROGRAM AND
         EXPENDITURE REPORTS HELP
         STATES MONITOR LEA
         PROGRAMS
-------------------------------------------------------- Letter :5.3.1

As permitted under the act, all states we surveyed had established
reporting requirements for LEAs receiving Safe and Drug-
Free Schools funds.  Generally, states most often rely on annual
reporting, although a few states require semiannual or monthly
reporting.  For example, 36 states reported that they require LEAs to
provide an annual progress report.  Three states require more
frequent reports.  Twenty-eight states said they require an annual
expenditure report; 17 states require LEAs to report on their
expenditures more frequently.  In addition, seven reported that they
require monitoring reports of LEAs when the LEAs visit program sites. 

In addition to these requirements, most states require LEAs to submit
a report documenting their expenditures before the state releases
funding to them.  Twenty-six of the states distribute funds on a
reimbursement basis, they said.  LEAs use their own funds to pay
program costs and are later reimbursed for their expenditures by the
state.  The timing and information requirements of these reports
vary, with some states requiring a more detailed explanation of
spending than others.  For example, Michigan Safe and Drug-Free
Schools officials require LEAs to report just the total amount of
money spent as of the date the state requests reimbursement.  In
contrast, South Dakota requires LEAs to send in copies of their
vouchers before being reimbursed for program funds, according to
state officials. 


         EVALUATIONS
-------------------------------------------------------- Letter :5.3.2

States must obtain information from LEAs for the required triennial
reports to Education describing the implementation, outcomes,
effectiveness, and progress of state-level and LEA-operated programs. 
At the time of our survey, however, many states had little
information about the extent and nature of program evaluation
activities at the local level.  For example, of those state officials
who reported local evaluation activities, many did not know the
number of LEAs conducting evaluations or the objectives and
activities of the LEA evaluations.  In addition, we asked state
officials what information they planned to include in their triennial
reports.  Many of the state officials who responded to this question
told us they either had not determined what information they would
include in their report or that they would include whatever
information Education required of them. 


   SEAS AND LEAS REPORT VARIED
   USES OF FUNDS
------------------------------------------------------------ Letter :6

As permitted under the act, SEAs and LEAs use Safe and Drug-Free
Schools funds for a variety of activities.  Although states often
require LEAs to report on their expenditures, the reported data are
seldom routinely aggregated to provide a statewide picture of Safe
and Drug-Free Schools spending.  State officials do not aggregate
expenditure data, they told us, because no reporting requirement
exists for them to do so. 

Although states use their program funds to provide a variety of
services, in most states, training and technical assistance for LEA
staff and others, including parents, is a frequent investment (see
fig.  2 and table III.2 in app.  III).  Forty-five states and Puerto
Rico said they use a portion of their state program funds in this
way.  Other categories of expenditures reported by many states
include curriculum development and acquisition (32 states), violence
prevention (27 states), and state-level program evaluation (22
states).  Other activities reported included demonstration projects
(18 states) or activities to provide cost-effective programs to LEAs
(20 states). 

   Figure 2:  Nationwide, Most
   States Use Safe and Drug-Free
   Schools Money for Staff
   Training

   (See figure in printed
   edition.)

Note:  The state activities categories are those used in the Safe and
Drug-Free Schools and Communities Act to describe allowable
activities. 

LEAs provide a broad range of activities to students with Safe and
Drug-Free Schools program funds, according to state officials (see
fig.  3).  These activities include drug-prevention instruction
(provided by 91 percent of the LEAs) and violence-prevention
instruction (provided by 68 percent of LEAs) and staff training on
new drug-prevention techniques and use of new curriculum materials;
special one-time events, such as a guest speaker, or drug- and
alcohol-free social activities, such as a dance or picnic; parent
education/involvement; student support services, such as counseling
and referral services; and curriculum development and acquisition. 
Ninety-one percent of LEAs provide drug-prevention instruction. 
Staff training is the next most offered activity, with 77 percent of
districts reporting such training. 

   Figure 3:  Most LEAs Provide
   Drug-Prevention Instruction and
   Staff Training With Safe and
   Drug-Free Schools Funds

   (See figure in printed
   edition.)

Note:  The LEA service categories are those used by the U.S. 
Department of Education in its survey of SEAs for school year
1996-97. 


   CONCLUSIONS
------------------------------------------------------------ Letter :7

The Safe and Drug-Free Schools program is one of several substance
abuse- and violence-prevention programs funded by the federal
government.  The major purpose of the programs is to help the
nation's schools provide a disciplined environment conducive to
learning by eliminating violence in and around schools and preventing
illegal drug use.  States and localities have wide discretion in
designing and implementing programs funded under the act.  They are
held accountable for achieving the goals and objectives they set as
well as for the federal dollars they spend. 

As permitted under the act, states and localities are delivering a
wide range of activities and services.  Likewise, accountability
mechanisms have been established and appear to be operating in ways
consistent with the act. 

The lack of uniform information on program activities and
effectiveness may, however, create a problem for federal oversight. 
First, with no requirement that states use a consistent set of
measures, the Department faces a difficult challenge in assembling
the triennial reports so that a nationwide picture of the program's
effectiveness emerges.  Second, although Education provides a
mechanism for states to report information annually, under the act,
nationwide information on effectiveness and program activities may
only be available every 3 years, which may not be often enough for
congressional oversight. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

The Department of Education provided written comments on a draft of
this report, and we incorporated, where appropriate, technical
clarifications it suggested.  In addition, the Department expressed
concern about our observations on the multiple programs designed to
address youth violence and drug abuse.  In the Department's view,
"the discussion of the numerous Federal programs designed to reduce
or eliminate youth drug use or violence treats the topic too
generally.  While other Federal programs may address various aspects
of these two very serious problems, we know of no other Federal
program that provides widely available, sustained support to schools
to prevent or reduce youth drug use or violence.  The draft fails to
provide detailed information about these other, numerous Federal
programs, and reaches a tentative conclusion about duplication and
effectiveness that is not supported by this draft report."

We did not revise our reference to the multiple programs in response
to this comment because (1) we state only that the potential for
duplication exists among these multiple, nonintegrated programs and
(2) we also state that we did not fully examine these programs to
document the extent to which this may be true for drug and violence
programs.  In addition, this background information provides what we
consider to be an important general context for considering the Safe
and Drug-Free Schools program.  The additional detail about the other
programs has been reported in our other products cited in the
footnotes. 


---------------------------------------------------------- Letter :8.1

We are sending copies of this report to appropriate House and Senate
committees and other interested parties.  Please call me at (202)
512-7014 or Eleanor L.  Johnson on (202) 512-7209 if you or your
staff have any questions.  Major contributors to this report are
listed in appendix IV. 

Carlotta C.  Joyner
Director, Education and
 Employment Issues


SITE VISIT REPORTS
=========================================================== Appendix I


   MICHIGAN
--------------------------------------------------------- Appendix I:1

The key issue in this allegation--that the state improperly used
federal drug education funding to implement a comprehensive health
curriculum--resulted from a state legislative review of the Michigan
Department of Education's implementation of a comprehensive school
health curriculum.  The state review, which had been prompted by
parents' concerns about the curriculum content, uncovered
questionable expenditures of federal drug-prevention funding under
the Drug-Free Schools and Communities Act for curriculum materials
not related to drug education as well as questionable fiscal
practices.  In addition to the legislative review, Michigan's
Director of Drug Control Policy conducted his own investigation.  His
review and that of the state auditor concluded that many of the
expenditures for the comprehensive school health curriculum violated
federal requirements for federal drug-prevention funding. 

As a result of the state auditor's adverse audit findings, the U.S. 
Department of Education became involved.  Federal officials reviewed
the audit findings and issued final rulings on whether the
expenditures under question violated federal requirements.  Although
state auditors questioned the expenditures for the comprehensive
health curriculum, upon obtaining further information from state
officials,\22 Education found these expenditures acceptable. 
Education, however, did find that the Michigan Department of
Education had violated other federal requirements in managing federal
drug-prevention funding.  The 1994 passage of the Safe and Drug-Free
Schools and Communities Act contained an administrative provision
that authorized the use of Safe and Drug-Free Schools funding and,
retroactively, the use of Drug-Free Schools and Communities Act
funding for comprehensive health programs. 


--------------------
\22 Education questioned Michigan Department of Education officials
about the proportion of the comprehensive health curriculum devoted
to drug education and the proportion of federal drug-prevention
funding spent for the curriculum. 


      THE FACTS REVIEWED
------------------------------------------------------- Appendix I:1.1

Between 1992 and 1994, members of the state legislature and the
director of Michigan's Office of Drug Control Policy charged Michigan
state education officials with improperly using federal Drug-Free
Schools and Communities Act funding to implement a statewide
comprehensive school health program.  The program, called the
Michigan Model for Comprehensive School Health Education, sought to
educate students about maintaining health and included a drug
education component.  The program sparked controversy when parents
statewide expressed opposition to their state representatives. 

In response to these complaints, state legislators launched their own
inquiry.  During their investigations, legislators came to question
the appropriateness and legality of using federal Drug-Free Schools
funding to implement a comprehensive health education program.  In
addition, they uncovered questionable administrative practices and
expenditures made with Drug-Free Schools funding. 

In 1994, the Family Law, Mental Health and Corrections Committee of
the Michigan State Legislature released a report of its investigation
into the Michigan Department of Education's management of federal
Drug-Free Schools funding.  The Committee examined seven issues,
concluding that the Michigan Department of Education (1)"diverted"
federal Drug-Free Schools funds "to activity not related to drug
prevention" and (2) illegally restricted local school districts'
discretion in using their drug education funds.  The Committee also
concluded that "a history of poor grant management and oversight by
the department of education" had occurred and found that greater
accountability was needed to ensure the proper uses of public
funds.\23 Among its recommendations, the Committee called for
performance audits of Drug-Free Schools grantees and state-level
agencies involved with Drug-Free Schools program expenditures. 

The Committee's findings echoed the findings of earlier
investigations by the state's Office of Drug Control Policy.  Calling
the Michigan Model's implementation the "Michigan Morass," the
Director of the Michigan Office of Drug Control Policy asserted that
the problem rested in "how funds diverted to it were obtained and
administered," especially federal Drug-Free Schools funds.\24 The
many problems cited by the director included questionable bidding
practices on competitive contracts, potential "double-dipping" by
state employees who served as both program coordinators and paid
consultants, and the purchase of curriculum materials not directly
related to the drug education components of the Michigan Model. 
According to him, these purchases included giant toothbrushes, a
human torso model, dog bone kits, and bicycle pumps. 

Because of the state audit findings, the issue of the use of
Drug-Free Schools funds for delivering a drug education program
through a comprehensive school health curriculum came before the U.S. 
Department of Education for resolution.  Specifically, state auditors
had found that (1) the Michigan Department of Education failed to
"appropriately document to what extent Drug-Free Schools and
Communities Act (Drug Free Schools) funds could be used to fund
comprehensive health education programs in accordance with statutory
and regulatory requirements," and (2) "the level of funding provided
by [the act] to support the Michigan Model exceeds the relative
weight of drug abuse education and prevention criteria contained in
the Michigan Model."\25 Federal education officials did not sustain
these findings. 

Education's rejection of these findings rested on its analysis of the
federal law, provisions of nonregulatory guidance, and a 1991 ruling
by Education's Assistant Secretary for Elementary and Secondary
Education on the issue.  Citing federal nonregulatory guidance on
this issue, Education pointed out that LEAs may include drug abuse
education and prevention in a comprehensive health education program,
but the expenditure of Drug- Free Schools funds is limited to the
drug abuse education and prevention program components.  Education
also noted that the guidance did not "specify particular methods to
be used in determining the proportionate share of a comprehensive
health education program to be funded by the Drug Free Schools
Act."\26 Referring to its previous ruling, Education said the
Michigan Department of Education had demonstrated through an analysis
of the Michigan Model's curriculum content that the level of
Drug-Free Schools funding for the Model was consistent with the
Model's level of drug abuse education and prevention content. 

Though the state auditor challenged the Michigan Department of
Education's methodology for determining program content, Education
ruled that "the auditors provided no evidence to demonstrate that the
methods used by the subcommittee were in violation of any statutory
or regulatory requirements."\27 Education concluded, "Consequently,
there is insufficient information to establish that the [Michigan
State Department of Education] has violated the requirements
contained in the [Drug-Free Schools and Communities Act] and other
applicable regulations related to the proportionate use of these
funds for the Michigan Model."

Though Education officials rejected auditors' findings on the uses of
Drug-Free Schools funds for implementation of the Michigan Model, it
sustained audit findings on several other points.  In brief,
Education sustained audit findings that the Michigan Department of
Education failed to (1) respect the broad discretion granted local
grantees in developing their drug education programs, (2) ensure that
LEA grant application requirements were fulfilled, and (3) evaluate
programs in accordance with federal requirements.  The Department
required the state to take appropriate corrective actions. 


--------------------
\23 Final Report, Michigan Department of Education's Management of
Federal Drug-Free Schools and Communities Act Funds, Family Law,
Mental Health and Corrections Committee, Michigan State Legislature
(Lansing, Mich.:  Dec.  29, 1994). 

\24 Senate Testimony and Final Drug Education Report, Office of Drug
Control Policy (Lansing, Mich.:  Oct.  12, 1993). 

\25 Letter of Determination dated Sept.  28, 1995, from Thomas W. 
Payzant, Office of Elementary and Secondary Education, U.S. 
Department of Education, to Arthur Ellis, Superintendent of Public
Instruction, Lansing, Michigan. 

\26 Determination Letter dated Sept.  28, 1995, from Office of
Elementary and Secondary Education, U.S.  Department of Education. 

\27 Determination Letter dated Sept.  28, 1995, from Office of
Elementary and Secondary Education, U.  S.  Department of Education. 


   VIRGINIA
--------------------------------------------------------- Appendix I:2

A LEA's use of Drug-Free Schools funding to provide out-of-town
training for members of its school/community coalitions led to
concerns that these expenditures did not meet federal criteria. 
Although the Drug-Free Schools Act permitted a wide range of
activities, state and local education agencies were also required to
adhere to the Education Department's General Administrative
Regulations.  These regulations include a requirement that costs be
"necessary and reasonable" and discuss the allowability of certain
kinds of costs. 

The state learned of the allegation when a caller reported the
alleged misuse of funds to the Governor's Fraud Hotline.  The
complaint was forwarded to the Virginia Department of Education's
internal auditor for an investigation, which included interviews with
local officials and a review of county auditors' report on the LEA's
expenditures.  Ultimately, state officials concluded the expenditures
were allowable under federal requirements but expressed concern about
the appearance of fiscal impropriety.  The entire matter was resolved
without federal intervention. 


      THE FACTS REVIEWED
------------------------------------------------------- Appendix I:2.1

In 1995, the Governor's Office, through its fraud hotline, received
an allegation charging the Fairfax County Public Schools with the
misuse of Drug-Free Schools funds.  An anonymous caller to the
hotline alleged that Fairfax County school district officials were
using federal Drug-Free Schools and Communities Act (Drug-Free
Schools) funds for staff training sessions at an expensive summer
resort.  The call was referred to the Virginia State Department of
Education's internal auditor for investigation. 

State officials learned that the Fairfax County Public Schools had
sponsored a total of 11 training sessions--each for 2-1/2
days--between March 1994 and April 1995 in St.  Michael's, Maryland. 
The sessions, designed to facilitate the formation of
school-community coalitions to support and enhance school-based drug
use prevention activities, trained community representatives,
business owners, school board members, alternative school staff, and
members of the Fairfax County Board of Supervisors.  In all, the
district trained 876 individuals at a total cost of $181,397.71, or
$207 per participant, according to Fairfax County public school
officials. 

In the course of their investigation, state officials also learned
that the district's fiscal year 1994 expenditures had been audited to
determine if Fairfax County Public Schools' Drug-Free Schools and
Communities grant was being administered in compliance with federal
and state requirements.  The subsequent audit report discussed the
expenditures for the district's training sessions in St.  Michael's. 
Auditors concluded that federal statutes had not been violated but
stated the training sessions could be seen as excessive, unnecessary,
and social in nature and cited Education Department General
Administrative Regulations requirements that expenditures be
"necessary and reasonable for proper and efficient administration of
the grant." The auditors cited the Regulations' requirements that the
grant not authorize expenditures for entertainment or social
activities, including "costs for amusements, social activities,
meals, beverages, lodging, rentals, transportation and gratuities."
Although the auditors concluded that the training expenses had been
reasonable--the room expenses were no more than an average hotel room
in the Washington, D.C., metropolitan area, and meals had been
reasonably priced--they questioned the need to hold the training
sessions out of state. 

On the basis of the local auditor's findings and information obtained
from district officials, Virginia State Department of Education
officials concluded the costs for the St.  Michael's training
sessions were reasonable.  Though commending the LEA's
"School/Community Action Team" concept, state officials cautioned the
district to take special precautions in guaranteeing that the
district's activities and expenditures were viewed by the school as
necessary, reasonable, and consistent with the purposes of the
Drug-Free Schools grant.  The state fully reimbursed the district for
each training session after the audit findings were discussed, and
the state made procedural changes to avoid a similar incident in the
future. 


   WEST VIRGINIA
--------------------------------------------------------- Appendix I:3

The key issue in this allegation--that the state failed to ensure
that local programs deliver a clear "no use" message and that locals
comply with federal requirements for expenditures and financial
management--has been addressed by federal reviews of state and local
activities under the Drug-Free Schools Act.  Regarding the lack of a
"no use" message, federal officials found that insufficient evidence
existed to support this claim.  As noted previously, federal
officials did observe instances of noncompliance with financial
management requirements.  However, both the SEA and the LEA have
taken steps to correct these problems. 


      THE FACTS REVIEWED
------------------------------------------------------- Appendix I:3.1

In March 1995, the Chief Counsel of the House Subcommittee on
National Security, International Affairs, and Criminal Justice met
with a West Virginia parent to discuss her concerns about drug
education and prevention programs.  In subsequent correspondence with
the Chief Counsel, the parent reiterated her concerns, charging a
lack of accountability on federal officials' part in ensuring state
and local compliance with the Drug-Free Schools Act.  Local
officials, she said, implemented a curriculum teaching "that only
abuse of a drug is harmful, leading our youth to believe and implying
that moderation and occasional use of cocaine, marijuana, or alcohol
might be an acceptable choice for themselves." The parent also said
she had withdrawn her children from her district's drug-education
program but expressed concern for children still enrolled in the
program. 

The parent's letter to the Chief Counsel was not the first expression
of her concern about West Virginia's implementation of the Drug-Free
Schools Act.  For example, she asked federal officials in the U.S. 
Department of Education in 1991 to conduct a formal investigation of
the QUEST curriculum used by her West Virginia school district,
Jefferson County.\28 Characterizing the curriculum as
"non-directive," she said she objected to the curriculum's lessons in
self-esteem and values clarification.  The concerns she raised
ultimately resulted in a program review by Education's Drug-Free
Schools officials and a limited-scope audit by Education's Inspector
General (IG).  In addition, the Office of National Drug Control
Policy, at this same parent's request, reviewed the QUEST curriculum
to assess its compliance with federal statutes.  Both entities
concluded that the curriculum violated no federal statutes. 

Federal officials performed two site reviews of Drug-Free Schools
programs in West Virginia.  The first, conducted in 1992, was
performed in response to allegations that the county violated federal
requirements when it failed to adopt and implement a program to
prevent students' use of illicit drugs and alcohol.\29 As part of
their review, federal officials interviewed appropriate state and
local educational agency personnel and examined relevant texts and
other materials.  As a result of this review, a Department official
concluded in September 1992 "that there is sufficient evidence to
indicate that Jefferson County does offer a drug prevention program
for students in all grades."

Education officials conducted another review of West Virginia's
Drug-Free Schools program, focusing on SEA activities, in 1994.\30
The review uncovered several problems with administrative practices,
including the following: 

  -- The West Virginia Department of Education incorrectly calculated
     LEA awards in fiscal years 1993 and 1994. 

  -- LEA applications failed to require all the information and
     assurances specified by the federal statute. 

  -- LEA applications did not, but should, include information that
     allowed the SEA to assess the use of Drug-Free Schools funds at
     the local level. 

  -- The West Virginia Department of Education failed to separately
     account for program activities and expenditures versus
     administrative activities and expenditures. 

  -- The West Virginia Department of Education may wish to require
     receipts or other evidence from LEAs before reimbursing funds
     for program activities. 

The report also noted significant improvements in the state's
monitoring of and technical assistance to LEAs.  In addition, federal
officials commended the West Virginia Department of Education on its
peer review process. 

In 1995, Education's IG performed a limited-scope audit of selected
aspects of Regional Education Service Agency VIII's (RESA VIII)
administration of the federal Drug-Free Schools and Communities Act
programs to determine if the agency was administering the federal
Drug-Free Schools program in compliance with applicable statutes and
regulations.  Overall, the IG found the agency's internal controls
for providing management with reasonable assurance that assets are
safeguarded against loss from unauthorized use or disposition and
that transactions are executed in accordance with management's
authorization and recorded properly to permit correct financial
reporting--sufficient for the Drug-Free Schools program.\31

The IG cited two cases of material noncompliance with federal laws
and regulations, however.  First, RESA VIII had failed to fulfill
requirements of the federal Single Audit Act of 1984 by not
conducting annual audits.  Second, RESA VIII used an inappropriate
indirect cost rate during fiscal years 1992, 1993, and 1994 when it
based its indirect cost on that of its fiscal agent, Berkeley County. 
The IG's recommendations included instructions to both the RESA and
the state.  Recommendations to RESA VIII included (1) that the agency
develop appropriate, reasonable indirect cost rates for fiscal years
1992 through 1994 and (2) obtain audits for all years required in
accordance with the federal Single Audit Act and applicable
regulations.  The IG also recommended that the West Virginia
Department of Education (1) cease requiring grantees of federal funds
to use inappropriate indirect cost rates, (2) require RESA VIII to
develop and submit to the West Virginia Department of Education its
own indirect cost rate in accordance with federal requirements, and
(3) require RESA VIII and all other RESAs to report to the Department
their indirect cost rate audit results. 

METHODOLOGY

To address your concerns about Safe and Drug-Free Schools'
accountability provisions and their implementation, we asked four
questions:  (1) What accountability measures are required under the
act at the federal, state, and local levels?  (2) What activities are
used by Education for overseeing state and local programs?  (3) How
do SEAs ensure local programs' compliance with the act?  and (4) What
specific uses are made of Safe and Drug-Free Schools funding at the
state and local levels? 

To determine what is required under the act, we reviewed relevant
documents, such as the act and its legislative history, relevant
sections of the Code of Federal Regulations, and other related
legislation. 

To assess what actions Education is taking, we followed up on
allegations of impropriety in three states (Michigan, Virginia and
West Virginia), reviewing documentation and interviewing state and
local officials involved in the original incident and in the
investigation and resolution (see app.  I for a description of each
of these site visits).  We also reviewed documents at Education's
headquarters in Washington, D.C., and interviewed Department
officials. 

In addition, we reviewed Department of Education state files for 16
states:  Connecticut, Delaware, Illinois, Indiana, Iowa,
Massachusetts, Michigan, Missouri, Nebraska, Nevada, New York, Rhode
Island, Tennessee, Texas, West Virginia, and Wyoming.  These state
files included documentation, such as a copy of the state's plan, the
reviewers' comments, materials from the state responding to
Education's request for supplemental information, and grant award
documents.  States were selected using a stratified, random sample. 

To select states for site visits, we used two main techniques to help
identify allegations.  First, we followed up on leads provided by
correspondence to a member of the Congress.  For example, a set of
seven letters given to us alleged improper use of funds.  We reviewed
these letters and called all seven authors to clarify their
complaints.  On the basis of the letters and phone calls, we
eliminated six of these allegations from our investigation because
they concerned curriculum issues.  Because the Safe and Drug-Free
Schools Act makes curriculum a state and local issue--
the Secretary of Education is specifically prohibited from
prescribing or proscribing specific materials or
approaches--curriculum could not be used as a basis for inappropriate
use of federal funds.  We did visit the site of the seventh
allegation--West Virginia.  We also chose the West Virginia program
because it had been audited by the Inspector General (IG) of the
Department of Education and was the subject of other Department of
Education reviews, providing us with much information that could be
reviewed in a relatively short time.  Second, in reviewing the
legislative history, we found that a floor debate in the House had
mentioned a number of other allegations.  One, the alleged misuse of
funds in Virginia for training retreats held in a resort location in
Maryland, had been the subject of investigations, giving us ample
data to review.  Therefore, we chose Virginia for a site visit. 
Finally, the use of Drug-Free Schools and Communities Act program
funds in Michigan for a comprehensive health program had already
prompted a large state-level investigation.  We chose Michigan for a
site visit because of the importance of this investigation. 

To determine what oversight was required and assess accountability
activities at the state and local level, we surveyed the 50 states,
the District of Columbia, and Puerto Rico about their activities,
receiving information from all 50 states, Puerto Rico, and the
District of Columbia.\32

Although we did not verify the data the states supplied us, we did
review supporting documentation they provided and used our site
visits to Michigan, Virginia, and West Virginia to collect examples
of how the law was being implemented and to observe accountability
practices at the state and local level.  Most information about state
accountability, however, collected through the questionnaire and
follow-up phone calls was reported by SEAs.  Our work was conducted
from February 1996 to May 1997 in accordance with generally accepted
government auditing standards. 

Appendix III DATA ON SAFE AND DRUG-FREE SCHOOLS

The tables in this appendix provide information, by state, on
selected aspects of states' Safe and Drug-Free Schools and
Communities programs.  Table III.1 provides the amount of each SEA's
school year 1995-96 allocation; tables III.2, III.3, III.4, and III.5
provide information on the activities funded by Safe and Drug-Free
Schools grants.  Information about state accountability mechanisms,
such as methods used for monitoring and distributing funds, appears
in tables III.6 and III.8.  Table III.7 provides information on
private school participation in the Safe and Drug-Free Schools
program.  Table III.9 provides information on how states selected
their neediest districts. 



                              Table III.1
                
                   Safe and Drug-Free Schools Funding
                  Amount by State, School Year 1995-96

                         (Dollars in millions)

                                                                 State
                                                                 grant
State                                                           amount
--------------------------------------------------------------  ------
Alabama                                                           $5.8
Alaska                                                             1.7
Arizona                                                            5.1
Arkansas                                                           3.5
California                                                        38.4
Colorado                                                           4.1
Connecticut                                                        3.2
Delaware                                                           1.7
District of Columbia                                               1.7
Florida                                                           14.8
Georgia                                                            8.6
Hawaii                                                             1.7
Idaho                                                              1.7
Illinois                                                          15.1
Indiana                                                            6.2
Iowa                                                               3.1
Kansas                                                             2.9
Kentucky                                                           5.5
Louisiana                                                          7.7
Maine                                                              1.7
Maryland                                                           5.1
Massachusetts                                                      6.4
Michigan                                                          13.6
Minnesota                                                          5.1
Mississippi                                                        5.0
Missouri                                                           6.3
Montana                                                            1.7
Nebraska                                                           1.9
Nevada                                                             1.7
New Hampshire                                                      1.7
New Jersey                                                         8.4
New Mexico                                                         2.7
New York                                                          26.0
North Carolina                                                     7.4
North Dakota                                                       1.7
Ohio                                                              14.4
Oklahoma                                                           4.3
Oregon                                                             3.5
Pennsylvania                                                      14.7
Puerto Rico                                                        9.3
Rhode Island                                                       1.7
South Carolina                                                     4.6
South Dakota                                                       1.7
Tennessee                                                          6.2
Texas                                                             27.4
Utah                                                               2.5
Vermont                                                            1.7
Virginia                                                           6.4
Washington                                                         5.8
West Virginia                                                      2.7
Wisconsin                                                          6.3
Wyoming                                                            1.7
----------------------------------------------------------------------


                                                                     Table III.2
                                                       
                                                          Percent of Funds Used for Various
                                                       Activities by SEAs, School Year 1995-96

                                                                                                       Violence training/                  Evaluation
                                                                             LEA cost-                          technical                   at state-
                                  Staff training/technical                   effective  Demonstratio          assistance/   Special LEA         level
State                                           assistance    Curriculum      programs    n projects            prejudice        grants    activities
----------------------------  ----------------------------  ------------  ------------  ------------  -------------------  ------------  ------------
Alabama                                                 55            10             5             5                   20             0             5
Alaska                                                  80             8             0             0                   12             0             0
Arizona                                                 70            20            10             0                    0             0             0
Arkansas                                                15             5             0            80                    0             0             0
California                                              34             8             9             5                    8             0            36
Colorado                                                50             0             0             4                   25            20             1
Connecticut                                             65            10             0             0                   25             0             0
Delaware                                                25            35            10            15                    5            10             0
District of Columbia                                     0             0             0           100                    0             0             0
Florida                                                 70             1             1             4                    0            23             1
Georgia                                                 90             0             0             0                    0             8             2
Hawaii                                                  40            20             5            15                   10             5             0
Idaho                                                   70             0             0             0                    5             0            25
Illinois                                                20            10             0            50                    0            10            10
Indiana                                                 70            10            10             5                    0             5             0
Iowa                                                    19             0             0             0                    0             0            81
Kansas                                                  59             2            35             0                    4             0             0
Kentucky\a
Louisiana                                               97             3             0             0                    0             0             0
Maine                                                   40            30            20             0                   10             0             0
Maryland                                                98             0             2             0                    0             0             0
Massachusetts                                           80             0             0             0                   20             0             0
Michigan                                               100             0             0             0                    0             0             0
Minnesota                                               60            10             0             0                   30             0             0
Mississippi                                             65            15            10             5                    5             0             0
Missouri                                                27             4            69             0                    0             0             0
Montana                                                 55            10             0             0                   20            10             5
Nebraska                                                55             9             5            12                    5             9             5
Nevada                                                  35            25            25             5                    5             0             5
New Hampshire                                           50            10            30             5                    5             0             0
New Jersey\a
New Mexico\b                                             0             0             0             0                    0            96             0
New York                                                75             0             0             0                   25             0             0
North Carolina                                          80            10             0             0                    0             0            10
North Dakota                                            54             0             0             0                   44             2             0
Ohio\a
Oklahoma                                                90             2             2             2                    2             1             1
Oregon                                                  50            10             2             3                   25             5             5
Pennsylvania                                           100             0             0             0                    0             0             0
Puerto Rico                                             20            17             0             0                   20            40             3
Rhode Island                                            37            15             0            22                   16             0            10
South Carolina\a
South Dakota                                            80             1             0             0                    5             0            14
Tennessee                                               60             0            10            30                    0             0             0
Texas\c
Utah                                                    35            60             0             0                    0             0             5
Vermont                                                100             0             0             0                    0             0             0
Virginia                                                95             5             0             0                    0             0             0
Washington                                              85             0             0             0                    0            10             5
West Virginia                                           29            17            23             0                   20             1            10
Wisconsin                                               75            10             0             0                   10             0             5
Wyoming                                                 40            20            10             0                   10            10            10
-----------------------------------------------------------------------------------------------------------------------------------------------------
\a No data available. 

\b The remaining 4 percent of the funds were carried over to 1996. 

\c All funds were provided to Educational Service Centers to fund
Safe and Drug-Free Schools Education Service Center contact
positions. 



                                   Table III.3
                     
                     Percent of LEAs in Each State Providing
                     Selected Services, School Year 1995-96-
                          -Teacher/Staff Training, Drug-
                        Prevention Instruction, Violence-
                        Prevention Instruction, Curriculum
                      Development/Acquisitions, and Student
                                 Support Services

            Teacher/          Drug-      Violence-     Curriculum        Student
State          staff     prevention     prevention   development/        support
\a          training    instruction    instruction   acquisitions       services
-----  -------------  -------------  -------------  -------------  -------------
Alaba             90            100            100            100             80
 ma
Alask             30             95             45             60             20
 a
Arizo             80             80             50             30             70
 na
Arkan             95             99             98             10             60
 sas
Calif             50             95             60             50             50
 ornia
Color            100            100            100             75             70
 ado
Conne             65            100             70             85             60
 ctic
 ut
Delaw            100            100            100             80            100
 are
Flori
 da\b
Georg             98            100             75             60             60
 ia
Idaho            100            100             75            100            100
Illin             80             80             90             50             60
 ois
India            100            100             80             80            100
 na
Iowa              50             68             36             50              0
Kansa             93            100              0             86            100
 s
Kentu            100            100            100             90             45
 cky
Louis            100            100            100            100              5
 iana
Maine             45             95             55             15             55
Maryl             95            100              0             87            100
 and
Massa             70             90             60             60             30
 chus
 etts
Michi            100            100             50            100             40
 gan
Minne             90            100             85             50             75
 sota
Missi             80             97             80             90             75
 ssip
 pi
Misso             95            100             90             70             60
 uri
Monta             85            100             85             85             85
 na
Nebra             96            100            100             96             91
 ska
Nevad             82             82             70             50             60
 a
New               75             98             50             60             40
 Hamp
 shir
 e
New
 Jers
 ey\b
New               70            100             60             15             85
 Mexi
 co
New
 York
 \c
North            100            100            100             95            100
 Caro
 lina
North             78             77             77             64             38
 Dako
 ta
Ohio              74             92             58             62             56
Oklah             80            100             40             30             50
 oma
Orego             85            100             80             50             95
 n
Penns             60             80             40             30             95
 ylva
 nia
Rhode             63            100             55             72             83
 Isla
 nd
South            100            100             70             85             80
 Caro
 lina
South            100            100             50             85             80
 Dako
 ta
Tenne             70             80             40             30             30
 ssee
Texas             80             88             \b             69             61
Utah             100            100            100            100            100
Vermo             90            100             60            100             90
 nt
Virgi             75             80             80             63             62
 nia
Washi             70             80             80             60             80
 ngton
West              59            100             \d             43            100
 Virg
 inia
Wisco             15             40              5             10              5
 nsin
Wyomi             40             30              5             40             70
 ng
--------------------------------------------------------------------------------
\a The District of Columbia, Hawaii, and Puerto Rico are not included
because they each have one LEA.  See app.  I. 

\b Data were collected by state but were not available at the time of
our survey. 

\c LEAs provided this information to the state; however, the data
were not aggregated at the state level. 

\d No knowledge. 



                                   Table III.4
                     
                     Percent of LEAs in Each State Providing
                     Selected Services, School Year 1995-96-
                     -Alternative Education Programs, Parent
                     Education/Involvement, After-or Before-
                        School Programs, Community Service
                        Projects, and Out-of-School Youth
                                     Services

                                          After-or
         Alternative         Parent        before-      Community        Out-of-
State      education     education/         school        service   school youth
\a          programs    involvement       programs       projects       services
-----  -------------  -------------  -------------  -------------  -------------
Alaba             70            100             70             80             25
 ma
Alask              5             15              0              5             10
 a
Arizo             35             80             40             40             \b
 na
Arkan             50             50             10             20             10
 sas
Calif             70             90             60             30             \b
 ornia
Color             50             80             25             40             60
 ado
Conne             25             35             50             15              0
 ctic
 ut
Delaw            100            100             80             90              0
 are
Flori
 da\b
Georg             25             50             15             15             10
 ia
Idaho             40            100             25             20             40
Illin              0             90             10             10              0
 ois
India             35            100            100             30             \b
 na
Iowa               0              0             46              0              0
Kansa             40             82             34             34             10
 s
Kentu             60             65             25             10              5
 cky
Louis              3             60              0              0              0
 iana
Maine              5             28              8              2              2
Maryl             75            100             87             87             75
 and
Massa             10             50             20              0              0
 chus
 etts
Michi             20             32             57             58              0
 gan
Minne             10             50             10             33             10
 sota
Missi            100             50             15             20              1
 ssip
 pi
Misso             40             30             55             95              5
 uri
Monta             35             75             40             50             15
 ta
Nebra             33             81             37             51             11
 ska
Nevad             70             70             50             40             25
 a
New               10             75             10             10              1
 Hamp
 shir
 e
New
 Jers
 ey\b
New               25             40             25             25              5
 Mexi
 co
New
 York
 \c
North             90             95             60             90             15
 Caro
 lina
North              4             62              5             41              1
 Dako
 ta
Ohio              19             58             24             30              2
Oklah              5             80             10              5              5
 oma
Orego             30             60             25             15              5
 n
Penns             20             25             15             15             10
 ylva
 nia
Rhode              8             55              3              0              1
 Isla
 nd
South             35            100             33             25              0
 Caro
 lina
South              8             60             20             20              0
 Dako
 ta
Tenne              5             25              5             10              5
 ssee
Texas             28             64             24             26              7
Utah             100            100             80            100             70
Vermo              5             90             25             10              2
 nt
Virgi             22             50             16             28              8
 nia
Washi             20             40             40             60             20
 ngton
West               2             48             43             16             36
 Virg
 inia
Wisco              1              1              1              0              0
 nsin
Wyomi             10             60              5             10              2
 ng
--------------------------------------------------------------------------------
\a The District of Columbia, Hawaii, and Puerto Rico are not included
because they each have one LEA.  See app.  I. 

\b Data were collected by state but were not available at the time of
our survey. 

\c LEAs provided this information to the state; however, the data
were not aggregated at the state level. 



                                   Table III.5
                     
                     Percent of LEAs in Each State Providing
                     Selected Services, School Year 1995-96-
                       -Special, One-Time Events, Conflict
                       Resolution/Peer Mediation, Security
                       Staff, Security Equipment, and Other

                           Conflict
                        resolution/
State  Special, one-           peer       Security       Security
\a       time events      mediation          staff      equipment          Other
-----  -------------  -------------  -------------  -------------  -------------
Alaba            100             50             15              5              0
 ma
Alask             60             40              0              0              0
 a
Arizo             80             60              3             16              2
 na
Arkan             20             20              1              5              0
 sas
Calif            100             72             30             50              0
 ornia
Color             50             60             15             15              0
 ado
Conne              3             65             17              3              0
 ctic
 ut
Delaw             25             90              0              0              0
 are
Flori
 da\b
Georg             75             50             15              5              0
 ia
Idaho            100             80             10              2              0
Illin             20             30             10              0             \c
 ois
India            100             80             \b             \b             35
 na
Iowa               0              0              0              5             \c
Kansa             80             55             22             19             \c
 s
Kentu             80             45              1              1              0
 cky
Louis             98            100             10             10             \c
 iana
Maine             15             40              1              1              0
Maryl             91              8             16              8            100
 and
Massa             30             50              5              0              0
 chus
 etts
Michi            100             25              3              3              0
 gan
Minne             50             85              5             10              0
 sota
Missi             90             50             10             50              0
 ssip
 pi
Misso             75             65             30             20              0
 uri
Monta             95             85              2              0            100
 na
Nebra             82             19              4              0              0
 ska
Nevad             82             50             25             12              0
 a
New               80             45              1              1              0
 Hamp
 shir
 e
New
 Jers
 ey\b
New               50             65             30             10              0
 Mexi
 co
New
 York
 \d
North             95             90              0              0              0
 Caro
 lina
North             56              0              1              0             14
 Dako
 ta
Ohio              84             61              7              5             \c
Oklah            100             40              5              5              0
 oma
Orego              5             75             10              5              0
 n
Penns             15             45             15              5              0
 ylva
 nia
Rhode             14             42              0              3             \c
 Isla
 nd
South            100             40             10             40              0
 Caro
 lina
South            100             40              0              0              0
 Dako
 ta
Tenne             30             30              5             15              0
 ssee
Texas             73             40             \b             \b             \c
Utah             100             80             50             10              0
Vermo             20             80              0              0              0
 nt
Virgi             42             42              1              3             \c
 nia
Washi             85             60              5              5             \c
 ngton
West               5             78              0              2              2
 Virg
 inia
Wisco              5             15              1              1              0
 nsin
Wyomi             80             20              5              2              0
 ng
--------------------------------------------------------------------------------
\a The District of Columbia, Hawaii, and Puerto Rico are not included
because they each have one LEA.  See app.  I. 

\b Data were collected by state but were not available at the time of
our survey. 

\c Some LEAs provided more than one other type of service. 

\d LEAs provided this information to the state; however, the data
were not aggregated at the state level. 



                                       Table III.6
                         
                           States' Most Often Used Methods for
                                     Monitoring LEAs

                                                        Telephone                     Did
                               Review of                    calls                     not
                      Site  documentatio   Technical  (monitoring          Multip  monito
State               visits             n  assistance            )   Other      le       r
------------------  ------  ------------  ----------  -----------  ------  ------  ------
Alabama                                                                                 X
Alaska                                 X
Arizona                  X
Arkansas                                           X
California               X
Colorado                                                                        X
Connecticut\a
Delaware                 X
Florida                                                                         X
Georgia                                X
Idaho                                                                   X
Illinois                 X
Indiana                  X
Iowa                                   X
Kansas                                                          X
Kentucky                 X
Lousiana                                                                                X
Maine                                  X
Maryland                 X
Massachusetts            X
Michigan                               X
Minnesota                X
Mississippi              X
Missouri                 X
Montana                                                                         X
Nebraska                                                        X
Nevada                                                                                  X
New Hampshire                                                                   X
New Jersey               X
New Mexico               X
New York                 X
North Carolina                                                                  X
North Dakota                                                            X
Ohio                                                                    X
Oklahoma                 X
Oregon                                 X
Pennsylvania                           X
Rhode Island                                                                            X
South Carolina                                                  X
South Dakota             X
Tennessee                              X
Texas                                                                           X
Utah                                   X
Vermont                  X
Virginia                                                                X
Washington                                                                      X
West Virginia                                                   X
Wisconsin                                                               X
Wyoming                  X
-----------------------------------------------------------------------------------------
Note:  Hawaii is not included in this table because it has only one
LEA. 

\a Missing data. 



                        Table III.7
          
          Private School Participation in Safe and
                 Drug-Free Schools Program

                                   Number of
                                private not-
                     Number of    for-profit     Number of
                  private not-       schools      students
                    for-profit  participatin  participatin
State                  schools             g             g
----------------  ------------  ------------  ------------
Alabama                    225            \a        27,800
Alaska                      \a            \b            \b
Arizona                     \a            75        15,100
Arkansas                    \a            35        10,200
California               4,158            \b            \a
Colorado                   384            90        48,800
Connecticut                337            \b            \b
Delaware                   164            85        15,000
District of                 61            36            \a
 Columbia
Florida                  1,168            \a            \b
Georgia                    521            \a            \a
Hawaii                      63            34        10,100
Idaho                       80            17           500
Illinois                 1,380            \a            \a
Indiana                    961           307        69,700
Iowa                       204           204        44,800
Kansas                     152            \a        28,000
Kentucky                   300           199        49,400
Lousiana                   392            \a       113,300
Maine                      103            42        10,500
Maryland                 1,113           209        57,400
Massachusetts              176            \a            \a
Michigan                 1,067           800       176,700
Minnesota                  543           407        62,600
Mississippi                 45            67        18,500
Missouri                   445           400        95,000
Montana\                    \a            \a        11,300
Nebraska                   224           219        40,700
Nevada                      99            \a            \a
New Hampshire              150           110        16,800
New Jersey               1,006           886       205,000
New Mexico                 142            51        11,900
New York                 2,142            \b            \b
North Carolina             545            28         4,900
North Dakota                65            65         8,000
Ohio                       878            \b            \b
Oklahoma                   200           200            \b
Oregon                     335            \a            \a
Pennsylvania             2,179          1107       278,100
Puerto Rico                532             8         3,000
Rhode Island               170           126        21,500
South Carolina             380            \b            \b
South Dakota               167            92        11,800
Tennessee                   \a            \a            \a
Texas                       \a           867       165,600
Utah                        54            36         2,100
Vermont                    103            40         6,500
Virginia                    \a            \a        32,300
Washington                  48           125         5,000
West Virginia              662           104         4,300
Wisconsin                  980           490           100
Wyoming                     31             4           200
----------------------------------------------------------
\a Missing data. 

\b Data were collected by state but were not aggregated at the state
level. 



                        Table III.8
          
          Method Used to Distribute Funds by State

                                   Basis
                  ----------------------------------------
                  Reimbursem   Forward       LEA
State                    ent   funding   request     Other
----------------  ----------  --------  --------  --------
Alabama                    X
Alaska                     X
Arizona                              X
Arkansas                             X
California                           X
Colorado                   X
Connecticut                X
Delaware                   X
Florida                                                  X
Georgia                                        X
Idaho                      X
Illinois                   X
Indiana                    X
Iowa                                 X
Kansas                     X
Kentucky                                                 X
Lousiana                   X
Maine                                X
Maryland                                                 X
Massachusetts                        X
Michigan                   X
Minnesota                  X
Mississippi                X
Missouri                   X         X
Montana                                                  X
Nebraska                   X                             X
Nevada                                                   X
New Hampshire              X
New Jersey                           X
New Mexico\a                                   X
New York                   X
North Carolina                                 X
North Dakota               X
Ohio                                                     X
Oklahoma                   X
Oregon                     X
Pennsylvania                         X
Rhode Island               X
South Carolina             X
South Dakota                                             X
Tennessee                                      X
Texas                                                    X
Utah                       X
Vermont                                                  X
Virginia                   X
Washington                                               X
West Virginia              X
Wisconsin                  X
Wyoming                                                  X
----------------------------------------------------------
Note:  Hawaii is not included in this table because it has only one
LEA. 

\a Missing data. 



                        Table III.9
          
          Method Used to Select Neediest Districts
                          by State

                               Selection method
                    --------------------------------------
State                      Application             Formula
------------------  ------------------  ------------------
Alabama                              X
Alaska                               X
Arizona                              X
Arkansas                             X
California                                               X
Colorado                             X
Connecticut\                         X
Delaware                             X
Florida                              X
Georgia                              X                   X
Idaho                                X
Illinois                                                 X
Indiana                                                  X
Iowa                                 X
Kansas                               X
Kentucky                             X
Lousiana                             X
Maine                                X
Maryland                             X
Massachusetts                        X
Michigan                             X
Minnesota                            X                   X
Mississippi\a
Missouri\a
Montana                              X
Nebraska                                                 X
Nevada                               X
New Hampshire                        X
New Jersey                           X
New Mexico\a                         X
New York                                                 X
North Carolina                       X                   X
North Dakota                         X
Ohio                                                     X
Oklahoma                             X                   X
Oregon                               X
Pennsylvania                         X                   X
Rhode Island                         X
South Carolina                                           X
South Dakota                         X
Tennessee                            X                   X
Texas                                X                   X
Utah                                                     X
Vermont                              X
Virginia                             X
Washington                           X
West Virginia                        X
Wisconsin                            X
Wyoming                              X
----------------------------------------------------------
Note:  Hawaii is not included in this table because it has only one
LEA. 

\a Missing data. 

GAO CONTACTS AND STAFF ACKNOWLEDGMENTS

GAO CONTACTS

Eleanor L.  Johnson, Assistant Director, (202) 512-7209
Sandra L.  Baxter, Evaluator-in-Charge, (202) 512-7053

STAFF ACKNOWLEDGMENTS

In addition to those named above, the following individuals made
important contributions to this report:  John Carney helped design
the questionnaire, gather survey information from states, reviewed
Department of Education files, wrote summaries of those reviews, and
drafted sections of the report; D.  Catherine Baltzell, Dianne Murphy
Blank, and Deborah Edwards helped design the study and advised on
methodology; Edward Tuchman helped gather survey data from states
and, with Wayne Dow, provided survey analyses; and Linda Stokes and
Sheila Nicholson helped gather survey information from states.  In
addition, Robert Crystal and Julian Klazkin performed the legal
analysis and provided ongoing legal advice. 


--------------------
\28 QUEST is a commercially developed and marketed curriculum used by
many school districts nationwide. 

\29 The full requirement of the law was that districts adopt and
implement a program to prevent the use of illicit drugs and alcohol
by students that, at a minimum, includes age-appropriate,
developmentally based drug and alcohol education and prevention
programs (which address the legal, social, and health consequences of
drug and alcohol use and which provide information about effective
techniques for resisting peer pressure to use illicit drugs or
alcohol) for students in all grades of the schools operated or served
by the LEA from early childhood level through grade 12. 

\30 This review included activities funded under the Governor's
Program of Drug-Free Schools.  Since activities under the Governor's
Program are beyond the scope of our review, findings pertaining to it
are excluded from the discussion in this site report. 

\31 Audit Results of RESA VIII's Administration of the Federal
Drug-Free Schools Program, Office of the Inspector General, U.S. 
Department of Education (Washington, D.C.:  Sept.  1995), p.  4. 

\32 Puerto Rico provided draft responses to our survey, but we could
not obtain a final official response from Puerto Rico before
completing our analysis.  We have included these draft responses as
applicable. 


*** End of document. ***