Women's Educational Equity Act: A Review of Program Goals and Strategies
Needed (Letter Report, 12/27/94, GAO/PEMD-95-6).

The Women's Educational Equity Act Program--administered by the
Department of Education--awards grants and contracts to (1) provide
educational equity for women; (2) help educational institutions comply
with the law's requirements prohibiting sex discrimination in
educational institutions receiving federal funds; and (3) provide
educational equity for women and girls suffering multiple discrimination
due to sex, race, ethnic origin, disability, or age.  This report
answers the following four questions: What interventions were
implemented, by whom, for what audiences, and at what costs, and did
these activities continue beyond the grant period? Did these activities
hold promise of promoting educational equity for women, and did they
reflect the requirements of the legislation? How was information about
the interventions disseminated, and what lessons do these activities
hold for future efforts to spread information widely in this field? How
did changes in administration affect the program's ability to achieve
its goals?

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

 REPORTNUM:  PEMD-95-6
     TITLE:  Women's Educational Equity Act: A Review of Program Goals 
             and Strategies Needed
      DATE:  12/27/94
   SUBJECT:  Women
             Educational grants
             Educational programs
             Information dissemination operations
             Sex discrimination
             Aid for education
             Education program evaluation
             Colleges/universities
             Career planning
             Secondary school students
IDENTIFIER:  Women's Educational Equity Act Program
             National Diffusion Network
             
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Cover
================================================================ COVER


Report to Congressional Requesters

December 1994

WOMEN'S EDUCATIONAL
EQUITY ACT - A REVIEW OF PROGRAM
GOALS AND STRATEGIES NEEDED

GAO/PEMD-95-6

Women's Educational Equity Act Program


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

  C.F.R.  - Code of Federal Regulations
  WEEA - Women's Educational Equity Act

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


B-256796

December 27, 1994

The Honorable Edward M.  Kennedy
Chairman, Committee on Labor
 and Human Resources
United States Senate

The Honorable Paul Simon
Chairman, Subcommittee on Employment
 and Productivity
Committee on Labor and Human Resources
United States Senate

This report responds to your request that we review the Department of
Education's Women's Educational Equity Act (WEEA) Program.  First
authorized by Public Law 93-380, the Education Amendments of 1974,
this program awards grants and contracts to eligible recipients for
interventions to (1) provide educational equity for women, (2) help
educational institutions meet the requirements of title IX of the
Education Amendments of 1972 prohibiting sex discrimination in all
educational institutions receiving federal funds, and (3) provide
educational equity for women and girls who suffer multiple
discrimination based on sex and on race, ethnic origin, disability,
or age.  WEEA further authorized the Secretary of Education, through
the Office of Educational Research and Improvement, to evaluate and
disseminate, at low cost, materials and programs developed under this
program. 

You asked us to address four questions:  (1) What interventions were
implemented, by whom, for what audiences, and at what costs, and did
these activities continue beyond the grant period?  (2) Did these
activities hold promise of promoting educational equity for women,
and did they reflect the requirements of the legislation?  (3) How
was information about the interventions disseminated, and what
lessons do these activities hold for future efforts to spread
information widely in this field?  (4) How did changes in program
administration affect the ability of the WEEA Program to achieve its
legislative purpose? 

This study reviews activities funded under WEEA between 1986 and
1991, the period for which agency records were available.  (No grants
were awarded in 1992.) Although the projects we reviewed are
representative of those funded over this 6-year period, they probably
do not greatly resemble those funded before 1986.  For example,
continuation grants (applications funded for 2 or 3 years) were
common in the earlier years (33 of the 55 grants awarded in 1981 were
continuation grants), but there were only three continuations in the
6 years from 1986 to 1991. 

At the end of this report, we discuss changes in the WEEA Program
that were recently enacted as part of the Improving America's Schools
Act of 1994.  We believe that the most significant findings of this
report still apply to the WEEA Program as reauthorized.  Thus, this
report should be useful to the Department of Education as well as
local and state education officials and other potential WEEA
applicants. 


   BACKGROUND
------------------------------------------------------------ Letter :1

When last reauthorized in 1988, WEEA authorized the Secretary of
Education to award (1) general grants for demonstration,
developmental, and dissemination projects of national, statewide, or
general significance and (2) challenge grants (not to exceed $40,000
each) to support comprehensive and innovative approaches to the
achievement of educational equity.  The Secretary was also authorized
to contract for a WEEA Publishing Center to disseminate WEEA
products. 

The WEEA Program was first funded in fiscal year 1976.  Appropriation
levels grew steadily, from $6.3 million at the onset to $10 million
in 1980, but dropped in the following decade.  In the years between
1982 and 1992, successive administrations aimed to end the program by
not including any funds in the President's budget, but some funds
were always reinstated by the Congress.  (See appendix I for
additional information.)

At one end of the spectrum are supporters who credit WEEA as being
responsible for many exemplary projects that have made significant
contributions toward attainment of gender equity.  At the other end
are critics who have described the program as "a money-making machine
for a small network of openly radical feminist groups" and one that
has not positively affected substantial numbers of women and girls.\1

With the advances achieved by women over the last 20 years, some
argue that women's educational equity is no longer an urgent issue. 
They cite facts such as the achievement of higher rates of promotion
and college enrollment by women than by men.  Others maintain that
equity has yet to be achieved; they cite the overparticipation of
women in low-paying jobs, the glass ceiling, and the lack of
attention given girls in comparison to boys by teachers and textbook
publishers.  (See appendix I for a detailed history of WEEA.)


--------------------
\1 See Tom Miraga, "Women's Panel Accused of Abandoning Equity Goal,"
Education Week, Sept.  29, 1982, p.  7, and Theresa Cusick, "A Clash
of Ideologies:  The Reagan Administration Versus the Women's
Educational Equity Act," Peer, Summer 1983. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :2

The scope of our review of WEEA grant activities was limited to the
years 1986 through 1992 because project records for activities funded
before 1986 were unavailable.  There were no general or challenge
grants in 1992.  Our review was further limited to funded activities
because, except for aggregated data, the Department of Education does
not maintain records of unfunded applications.  Aggregated data
include such information as the total number of applications
received, the number of applications received by state and
geographical region, and the number of applications by type of grant
requested.  By contrast, our review of WEEA's Publishing Center
activities and of the administration of the WEEA Program is based
upon information we were able to collect on the program's entire 19
years of experience. 

Information for this study was obtained through interviews and
document review.  We interviewed individuals with current and
previous program responsibility and analyzed information from the
WEEA Program Office, the Department of Education's Grant and Contract
Service Office files, WEEA's Publishing Center, and independent
reviews of the program.  We also conducted telephone interviews with
a random sample of 40 former WEEA grantees.  We reviewed 185
applications (184 of which were funded)\2 and 105 end-of-grant
reports\3 and independently judged

their connection to gender equity,

the statutory priority that appeared to be addressed,

whether the project appeared to be of local or broader significance,
and

whether plans for and results of evaluations were included. 

We performed our work in accordance with generally accepted
government auditing standards. 


--------------------
\2 Of the 185 applications we reviewed, one was not funded because
the applicant refused the grant.  Twenty-one applications were
missing; most of these were eligible for disposition under the
Department's 5-year record retention policy. 

\3 We were able to retrieve 51 percent (105 out of 205) of the
end-of-grant reports.  If one omits reports for 1986-87 grants (which
may have been disposed of by the time of our data collection under
the Department's 5-year record retention policy), the retrieval rate
was 47 percent (50 out of 107).  We were unable to determine if the
missing final reports had not been provided by grant recipients or if
Department officials had received them but were unable to locate
them. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :3


      QUESTION 1
---------------------------------------------------------- Letter :3.1

In answer to your first question about the interventions funded over
the period of this study, we found that the program funded 205
general and challenge grants between 1986 and 1991.  Service
activities of career counseling, remedial academic instruction, and
psychological and supportive counseling were often supported under
WEEA.  Elementary and secondary school students were the most
frequently targeted participants, followed by parents and other
adults from outside the schools.  In terms of the populations
addressed, about half of funded applications were aimed at the needs
of racial and ethnic minorities and other disadvantaged groups. 
Colleges received 36 percent of the grants, nonprofit or community
groups received 32 percent, and local education agencies 15 percent. 

WEEA operated under annual appropriations averaging under $3 million
during the period studied.  General grants averaged $107,344--about
three times the size of the average challenge grant, which was
$32,132.  Utilizing a telephone survey of 40 former grantees, we
estimated that about half of the projects that provided student
services continued after WEEA funding ended, although typically
through the support of other federal and state programs. 


      QUESTION 2
---------------------------------------------------------- Letter :3.2

Did the WEEA activities hold promise of promoting educational equity
for women, and did they reflect the legislative requirements?  The
WEEA Program addressed gender equity primarily by providing direct
services--academic instruction, career counseling, and some personal
support services--to girls and women, apparently to compensate for
past and current inequities.  There was relatively little emphasis in
WEEA projects on identifying gender inequities in the policies and
practices of educational institutions and developing remedies for
them. 

We examined funded projects in light of priorities for "national,
statewide, or general significance" and found about half the projects
of only local significance.  In our view, this is because the
Department of Education regulations define "general significance"
unnecessarily broadly, which has allowed frequent funding of projects
of largely local orientation. 


      QUESTION 3
---------------------------------------------------------- Letter :3.3

How was information disseminated?  What lessons were learned about
dissemination?  The WEEA Publishing Center prepares WEEA products for
publication, publishes them commercially, and provides other
information and coordination functions.  The effectiveness of the
Publishing Center is limited by the local nature of many WEEA
projects, which makes them less amenable to dissemination.  Few WEEA
grantees develop products; only about 15 percent of WEEA projects
result in commercially available products.  Few WEEA projects are
evaluated, which means the Publishing Center must distribute products
that have not been documented as successful in their original sites. 


      QUESTION 4
---------------------------------------------------------- Letter :3.4

With regard to administration of the WEEA Program, changes since the
early 1980s have reduced the program's size, funding, and visibility. 
WEEA's program staff declined from about six to one and one-quarter
positions.  Its appropriation fell from $10 million in 1980 to $1.98
million in 1994.  The position of program director was eliminated,
and the program's reporting level within the Department was dropped
three levels.  One measure of the impact of these changes is the drop
in applications from 955 in 1980 to 247 in 1991. 

Applications for WEEA grants are scored on four dimensions--plan of
operation, impact, need, and staff qualifications--producing possible
scores of up to 100 points.  Several additional funding requirements
have been added over the years.  Only one is incorporated into the
numerical scores:  applicants who have not previously received
funding under WEEA or under part C of title IX receive an additional
10 points.  Other funding requirements include mandating special
consideration for distributing awards geographically, instructing the
Department to consider annual funding priorities, funding specific
recommended activities, and supporting activities at four levels of
education.  These additional requirements may have limited the
capacity to award grants on the basis of merit.  The impact of these
added criteria--which are not unusual legislatively--could be
substantial because of the number of additional requirements and the
small size of the program.  In short, the description of the process
used to select WEEA grantees suggests that the need to consider so
many funding priorities makes the selection process more a mechanical
application of rules than a consideration of the better applications. 


   IMPLICATIONS OF OUR RESULTS
------------------------------------------------------------ Letter :4

A program with no director, with a staff of one and one-quarter
persons located in two different offices of the Department of
Education, and operating under threat of extinction for a decade,
WEEA is now in a growth situation with an increase in appropriations
from $1.98 million in fiscal year 1994 to $3.97 million in fiscal
year 1995.  Our review suggests a need to revisit WEEA's fundamental
goals and strategies if the program is to maximize its effects on
achieving educational equity. 

Activities funded by WEEA are typically not provided in close
association with the schools.  The dominant WEEA activities are for
direct services--academic instruction, counseling, and personal
support services.  Such services are apparently needed because
gender-based discrimination in the schools is still a problem.  Yet
one of the three WEEA objectives is to help educational institutions
meet the requirements of title IX prohibiting sex discrimination in
all educational institutions receiving federal funds.  However, we
found that only 7 percent of WEEA activities concerned title IX
compliance, and we classified only one state or local education
agency grant as having title IX compliance as its primary WEEA
activity.  Further, only 17 percent of WEEA awards were received by
state and local education agencies, and we saw little or no evidence
that other grantees (such as universities) were working in close
partnerships with state agencies or local schools to identify and
remedy sex equity problems in the public schools. 

WEEA activities thus appear to be out of balance in that too many
resources go for direct services to small numbers of persons and too
few resources go to eliminate systemic inequitable policies and
practices that will affect future generations of girls and women. 
Department officials need to consider what the educational
equity-related needs of women and girls in the 1990s are and what
role WEEA should have in meeting them. 

Critics of WEEA may argue that there are few substantial problems of
sex equity in the schools and colleges and that WEEA funding is
unnecessary for either direct service projects or projects aimed at
identifying and remedying sex inequities in educational institutions. 
That debate may be resolved by data to be collected for a mandated
report to the President and the Congress on the status of educational
equity for girls and women.  The reauthorization of WEEA requires
this report by January 1, 1999. 


   PRINCIPAL FINDINGS
------------------------------------------------------------ Letter :5


      QUESTION 1
---------------------------------------------------------- Letter :5.1


         ACTIVITIES FUNDED BY THE
         WEEA PROGRAM
-------------------------------------------------------- Letter :5.1.1

Instruction was the most common class of activity funded in the
1986-91 period, accounting for 30 percent of WEEA activities. 
Supplementary education activities accounted for 28 percent, and
personal support, another 24 percent of activities.  Professional
support accounted for 8 percent of activities, and title IX
compliance for 7 percent.  (See table 1.)



                           Table 1
           
           Frequency of WEEA Support of Activities

Activity\a                                  Number   Percent
----------------------------------------  --------  --------
Instruction                                    120        30
Remedial academic instruction                   50
Teacher and staff training                      16
Instructional materials for students            14
Teacher instruction guides                      13
Vocational instruction                          12
Enrichment activities                            5
Drop-out prevention activities                   4
Research                                         3
Other\b                                          3
Supplementary education                        112        28
Career counseling services                      70
Staff training                                  15
Teacher guides                                  12
Materials for students                           8
Purchase of reference and other                  5
 materials
Other\b                                          2
Personal support                                95        24
Psychological and supportive counseling         32
Allowances for transportation or day            18
 care
Case management services                         9
Staff guides                                     7
Staff training                                   6
Materials for students                           6
Scholarships                                     5
Instruction in parenting skills                  5
Fitness and wellness training                    3
Other\b                                          4
Professional support                            33         8
Professional networking                         11
Professional materials                           6
Research                                         5
Conferences                                      5
Training                                         4
Other\b                                          2
Title IX compliance                             27         7
Research studies                                 9
Teacher and staff training                       8
Teacher and staff guides                         5
Student materials                                3
Other\b                                          2
General\c                                       17         4
============================================================
Total                                        404\d     101\e
------------------------------------------------------------
\a Most common activities within each class are listed with their
corresponding number of projects. 

\b This category combines several separately coded activities, none
of which are as frequently selected as those that are listed
separately. 

\c This category includes public address announcements, posters, desk
placemats. 

\d Omits 21 missing cases. 

\e Does not total 100 percent owing to rounding. 

By far the most frequent activity within the instructional class was
remedial academic instruction.  Other popular instruction activities
included teacher or staff training, developing instructional
materials for students, and teacher instruction guides.  About half
of the remedial activities are in projects oriented to adults outside
the schools and about half are secondary school student projects.\4

The major supplementary education activity was career counseling
services, which was mainly offered to students at secondary schools
and colleges.  The main personal support activities were
psychological and supportive counseling services and allowances or
stipends for transportation or day care.  The most common activity in
the professional support class was networking, while research studies
dominated the title IX compliance class. 

Regarding the 184 funded applications that we reviewed, we found that
38 percent of WEEA projects included career counseling activities, 27
percent included remedial academic instruction activities, and 17
percent included psychological and supportive counseling services. 
These three activities clearly dominate WEEA funding. 


--------------------
\4 The data in table 1 are based on up to three activities that we
derived from the applications.  The analysis on the participants in
different activities is based on the primary activity only.  Primary
activities are those that appeared to account for more of the project
funds than other activities if more than one activity was included in
the application. 


         RECIPIENTS OF AWARDS
-------------------------------------------------------- Letter :5.1.2

WEEA grants were most frequently awarded to colleges and to nonprofit
and community groups as shown in table 2.  Local and state education
agencies received only 15 percent and 2 percent of the awards,
respectively. 



                           Table 2
           
               Type of Recipient of WEEA Awards

                                   Number of      Percent of
Type of recipient                     awards          awards
----------------------------  --------------  --------------
Colleges                                  74              36
Nonprofit or community                    65              32
 groups
Local education agencies                  30              15
State education agencies                   4               2
Individuals                               12               6
Tribally chartered                         6               3
Other\a                                   14               7
============================================================
Total                                    205           101\b
------------------------------------------------------------
\a Includes municipal agencies, state departments of corrections, and
so forth. 

\b Total exceeds 100 percent owing to rounding. 

The college-run grants look much like the other grants, differing
mainly in that their services are somewhat more likely to be targeted
toward postsecondary students and faculties at the postsecondary
level and below.  We noted earlier that elementary and secondary
school students and teachers are much more often the primary audience
for WEEA projects than are postsecondary audiences. 


         AUDIENCES ADDRESSED
-------------------------------------------------------- Letter :5.1.3

The most frequent level of participants targeted was elementary and
secondary students (about 36 percent of projects), followed by
parents or other nonschool adults (25 percent).  About 14 percent of
the projects were targeted to elementary and secondary school
educators, and about 11 percent to postsecondary students or faculty. 
(See table 3.)



                           Table 3
           
              Primary Audience Addressed by WEEA
                           Awardees

                                                  Percent of
Primary audience          Number of awards            awards
------------------------  ----------------  ----------------
Elementary and secondary                73                36
 students
Parents, adults,                        51                25
 general public
Elementary and                          28                14
 secondary educators
Postsecondary students                  16                 8
Postsecondary                            7                 3
 faculty
Other                                    9                 4
Missing applications                    21                10
============================================================
Total                                  205               100
------------------------------------------------------------
About half of the 51 projects targeting nonschool adults focused
their primary activities on instructional services, typically
remedial academic instruction (15 projects) and some vocational
training (6 projects).  The other most common activity for nonschool
adult programs was personal support, especially psychological and
supportive counseling services (3 projects) and allowances for
transportation or day care (3 projects).  These adult nonschool
projects were primarily serving disadvantaged populations, especially
poor, Native American, and minority women. 

Table 4 shows that about half of all projects were targeted to some
disadvantaged population, often a racial or national origin group. 
This degree of emphasis of WEEA projects upon disadvantaged persons
is surprising in that WEEA can fund projects to provide educational
equity for all population groups.  However, the pattern of
disadvantaged group targets is clearly consistent with one objective
of WEEA, which is to provide educational equity for persons suffering
multiple discrimination. 



                           Table 4
           
             Extent to Which Disadvantaged Groups
           Were a Primary Target Population in WEEA
                            Awards

Primary target
population\a            Number of awards   Percent of awards
--------------------  ------------------  ------------------
Minority total                        56                  27
Unspecified                           19
Native American                       18
African American                       8
Hispanic                               8
Asian                                  3
Non-English-                           2                   1
 speaking
Low socio-economic                    20                  10
 status
Pregnant or                           16                   8
 parenting
Physically or                          5                   2
 mentally
 disabled
Female offenders                       5                   2
Migrants                               3                   1
============================================================
Disadvantaged                        107                  51
 subtotal
No disadvantaged                      77                  38
 primary target
 population
Missing applications                  21                  10
============================================================
Total                                205                99\b
------------------------------------------------------------
\a Some decisions on how to classify the target population were
difficult and may appear to create contradictions. 
"Non-English-speaking" was not included under the Minority category
because some programs were aimed at persons of European origin, a
class not commonly considered a minority status.  Migrants often have
low incomes, but we retain the specific target populations of these
projects by including migrants as a separate class. 

\b Total differs from 100 percent owing to rounding. 


         SIZE AND DURATION OF WEEA
         GRANTS
-------------------------------------------------------- Letter :5.1.4

The average WEEA grant in the period was $76,892, ranging from a low
of $67,422 in 1990 to a high of $87,586 in 1989.  The average general
grant was $107,344, while the average challenge grant was $32,132. 
(See table 5.) Only three applications were funded for more than 1
year, and in some cases, services were provided for only a few weeks. 



                           Table 5
           
                Average Amount of WEEA Grants

Fiscal year           Type of grant           Average amount
--------------------  ------------------  ------------------
1986                                                 $76,502
                      Challenge                       28,046
                      General                         93,664
1987                                                  79,104
                      Challenge                       32,982
                      General                        125,226
1988                                                  70,072
                      Challenge                       33,395
                      General                        104,916
1989                                                  87,586
                      Challenge                       34,480
                      General                        125,072
1990                                                  67,422
                      Challenge                       32,987
                      General                        120,986
1991                                                  84,437
                      Challenge                       30,471
                      General                        106,923
Total                                                $76,892
                      Challenge                      $32,132
                      General                       $107,344
------------------------------------------------------------

         CONTINUATION OF SERVICES
-------------------------------------------------------- Letter :5.1.5

Based on telephone interviews with a random sample of 40 former
grantees, we found service activities funded by WEEA often appeared
to continue beyond the funding period.  However, continuation was
contingent upon the availability of other outside funding. 

The interviewees indicated that almost half of their services funded
totally or partially by WEEA (13 of 29) for the period 1986-91
continued beyond the funding period, largely through the use of funds
from other federal and state programs.  These types of continuations
do not, however, necessarily constitute local institutionalization of
federal seed money initiatives in the usual sense of the term. 
Indeed, we found only two cases where applicants decided to continue
services with their own funds.  (See table 6.) These findings should
be treated as tentative, however, because of the small size of our
sample and because we were unable to verify the information that we
collected. 



                           Table 6
           
             Continuity and Availability of WEEA-
              Supported Services and Products\a

                              Student         Product
WEEA activity                 services        development
----------------------------  --------------  --------------
Number of grants              29              18

Number providing proposed     29              15
activity

Number continued after WEEA   13              13
funding terminated

Source of support for         Funded by       Available
continued services or         other federal   through the
products                      programs--4     WEEA
                                              Publishing
                              Funded by       Center--4
                              multiple
                              (federal,       Published by
                              state, or       other
                              private)        commercial
                              sources--6      publisher--2

                              Funded by the   Disseminated
                              grant           by
                              recipient--2    recipient--7

                              Continued
                              through
                              volunteer
                              efforts--1
------------------------------------------------------------
\a This table was derived from the telephone interview responses of
40 former WEEA grantees.  The number of activities exceeds 40 because
some proposed more than one activity or product.  Three teacher or
staff training activities are omitted. 

About 70 percent of applicants who reported they were funded to
develop materials (13 of 18) did produce a product and continued to
offer the product to interested audiences.  Interviewees reported
that they disseminated many of these materials themselves.  We do not
have data on the quality or utility of these products. 


      QUESTION 2
---------------------------------------------------------- Letter :5.2


         DID WEEA PROMOTE GENDER
         EQUITY? 
-------------------------------------------------------- Letter :5.2.1

The purposes of the act include (1) "to provide educational equity
for women in the United States," (2) "to provide financial assistance
to enable educational agencies and institutions to meet the
requirements of title IX," and (3) "to provide educational equity for
women and girls who suffer multiple discrimination, bias, or
stereotyping based on sex and on race, ethnic origin, disability, or
age" (P.L.  100-297). 

As noted earlier, most WEEA projects provided academic instruction,
career counseling, and personal support services to girls and women
students.  In this way, they apparently hoped to provide girls and
women with services to compensate for past--and possibly
current--educational inequities. 

We identified a group of 46 projects that provided services to
disadvantaged adults outside the schools, which represented about 25
percent of the WEEA projects.\5 We found that 35 of these projects
had primary activities of instruction or personal support.  These
projects were presumably directed toward the third purpose of the
act--services to victims of multiple discrimination.  However, it was
sometimes unclear in both the applications and in the reviewer
comments written on the application review sheets whether the concern
was with multiple discrimination (including gender) or with economic
hardships facing the women.  For example, a WEEA grant helped
establish an educational resource center for adult women,
particularly minority women, to help compensate for educational gaps
associated with the closing of the Prince Edward County, Virginia,
public schools in 1959-63 in protest over school desegregation.  In
this case, both men and women were victims because the discrimination
was based upon race and both men and women faced resulting economic
hardships. 

Returning to table 1, we found relatively little emphasis on
identifying gender inequities in schools and colleges and on
developing remedies for these inequities.  That may be the goal of
many of the WEEA activities for teacher or staff training and
activities related to developing instruction materials for students
and teacher guides.  However, those activities were also not very
common, representing 17 percent of the specific activities listed
within table 1.  An additional class of activity aimed at developing
remedies for sex inequities is compliance with title IX, but these
represented only 7 percent of all activities. 

If the focus of the WEEA Program were on identifying gender
inequities and developing remedies, we might expect many awards to be
made to local and state education agencies because they have the
authority to implement procedures and programs that affect present
and future generations of students.  However, as we noted earlier,
state and local education agencies received only 17 percent of the
WEEA awards in this period.  Further, we found only one education
agency project (representing 4 percent of all education agency
grants) in which the primary activity was title IX compliance.  In
fact, education agency recipients of WEEA awards were less likely
than other recipients to have title IX compliance as the primary
activity.  (See table 7.) One possible explanation would be that
there were partnerships of some sort in which universities and
community groups identified problems and helped public schools
institutionalize solutions, but we saw few joint approaches, and the
combined effects of small awards and the small likelihood of
continued WEEA funding seem to make such partnerships unlikely. 



                           Table 7
           
           Primary Activity of WEEA Grants by Type
                         of Recipient


                         Local and state
Primary activity      education agencies          All others
--------------------  ------------------  ------------------
Instruction                          39%                 34%
Supplementary                         32                  22
 education
Personal support                      18                  17
Title IX                               4                  12
Professional support                   0                   9
General                                7                   6
============================================================
Total                               100%                100%
------------------------------------------------------------
In summary, it appears that WEEA promoted gender equity primarily by
providing academic instruction, career counseling, and some personal
support services that were not available or not sufficiently
available in schools and, to a lesser extent, colleges. 


--------------------
\5 We found 25 percent of the projects (46 of 184) targeted
disadvantaged adults outside the schools.  The denominator excludes
the 21 missing applications.  We did not count pregnancy and
parenting activities as directed at disadvantaged adults; some may
have been, but we were unable to determine that. 


         DID WEEA MEET LEGISLATIVE
         REQUIREMENTS? 
-------------------------------------------------------- Letter :5.2.2

We focused our review of legislative requirements on the priority the
WEEA legislation gives to funding projects of "national, statewide,
or general significance" and on the various funding criteria that
emphasize the support of specific types of activities and categories
of applicants. 

As noted earlier, WEEA appropriations have never reached the level
specified in the legislation to allow for funding of projects of
local significance.  Thus, all WEEA projects are to be of "national,
statewide, or general significance." Under the law, presumably,
demonstration, developmental, or dissemination activities would serve
to diffuse the lessons from projects with national, statewide, or
general significance.\6

According to Department of Education regulations, a project of
general significance includes any project whose "potential impact is
not confined to a local area." Since almost any project could have
the potential for some impact outside its local area--if only through
informal discussion with a few people from another state--the
Department's interpretation appears to limit any priority for
projects of national, statewide, or general significance. 

We found only 28 percent of the funded applications we reviewed had
proposed activities that held promise of significance at the national
level.  We considered activities that included demonstration,
developmental, and dissemination components or that provided services
for individuals from several states as having promise of national
significance.  We determined that 20 percent of funded projects were
of potential significance at the state level in that services were
provided in more than one site within a state or some other broad
geographical area. 

The remaining 52 percent of the projects in our review of WEEA awards
(and 58 percent of the projects in our telephone sample) appeared to
be primarily of local significance.  These projects proposed services
for individuals within a given locality and did not include formal
demonstration, developmental, or dissemination components that would
enable the diffusion of project activities and accomplishments.  Such
projects are unlikely to influence practices at external sites and,
therefore, hold little promise of general significance. 

For example, a 1991 grant was awarded to fund continuing education
services, including English and mathematics instruction, instruction
in life skills (for example, balancing a checkbook), and General
Education Diploma tutoring, for 100 Native American women living
within a reservation.  Services were funded for a year, and the
applicant did not propose demonstration, developmental, or
dissemination activities.  This project was typical of many WEEA
projects in terms of its local orientation and targeting of needy
adult clients. 

With regard to the question of the WEEA funding requirements, we
noted earlier that the legislation specifies awards for general and
challenge grants.  Beginning in 1978, the legislation also required
the Secretary to set criteria and priorities for awarding funds. 
Accordingly, the Secretary allocates funds to each priority selected. 
The initial five priorities were title IX compliance, providing
equity for racial and ethnic minorities, providing educational equity
for disabled women and girls, influencing leaders in educational
administration and policy, and eliminating barriers to equity.  From
1991 to 1993, only one priority was selected:  programs to increase
the participation of women in instructional courses in mathematics,
science, and computer science.  (The priorities for each year are
shown in tables I.1 and I.2 in appendix I.)

In addition to the two types of grants and the annual funding
priorities, WEEA calls for the Secretary to make awards to applicants
proposing activities at four levels of education and in six specific
subject areas.  The Department of Education has classified the four
levels of education for funding as preschool, elementary and
secondary, higher education, and adult education.  WEEA identifies
the six specific grant subject areas as (1) the development and
evaluation of educational materials; (2) model training programs for
educational personnel; (3) research and development activities; (4)
guidance and counseling; (5) educational activities to increase
opportunities for adult women, including underemployed and unemployed
women; and (6) educational activities to increase support for women
in vocational education, career education, physical education, and
educational administration. 

The act also mandates "special consideration" be given to grant
applicants "on the basis of geographic distribution throughout the
United States" and to applicants that have not received previous
grants under WEEA or part C of title IX.  The Department of Education
also attempts to ensure that it funds one of each type of grantee
each year. 

In summary, there are many requirements that govern the allocation of
grants besides the merit of the proposals.  We discuss the operation
of these requirements in a later section. 


--------------------
\6 The act does not define what is meant by the phrase "national,
statewide, or general significance," nor does it define
"demonstration, developmental, and dissemination activities."


      QUESTION 3:  PRODUCTS AND
      DISSEMINATION
---------------------------------------------------------- Letter :5.3

Many federal programs like WEEA that must address widespread problems
with only modest funds are often identified as demonstration,
developmental, or dissemination efforts.  That is, ideas and
solutions developed and demonstrated in one WEEA location may do two
things:  help educational equity in the original site (through direct
project activities) and also be useful in other locations if the
projects are sound and transferable.  Such diffusion can happen in
many ways, both informally and through explicit efforts.  Under WEEA,
diffusion efforts are encouraged but not required, and the WEEA
Publishing Center helps grantees bring products to market and
publishes them.  In addition, the Publishing Center produces a
quarterly digest and monographs to spread knowledge of issues and
research in the area of gender equity. 

Two independent estimates suggest that about 15 percent of WEEA
projects resulted in commercially published products.  The first
estimate of the production of commercially published products is from
table 6 and is based on our interviews with 40 grantees.  The second
estimate was derived from our review of the origin of products in the
WEEA Publishing Center catalog. 

The Publishing Center encourages grantees to submit products to the
National Diffusion Network, a program operated by the Department of
Education to disseminate information describing educational programs
documented as exemplary through rigorous evaluation.  However, WEEA
products rarely have such evaluations, and only a few WEEA products
have been submitted to the National Diffusion Network. 

Despite declines in WEEA funding and associated declines in funded
projects, the demand for WEEA products as shown in annual sales has
not decreased proportionally.  (See table 8.) However, each year the
Center has published products from only an average of 7 to 8 projects
since its beginning in 1977 through 1992, and unit sales remain
small. 



                           Table 8
           
              Year-End Sales for WEEA Publishing
                       Center Products

Year\a
-----------------------------  =============================
1978-79                                     $31
1979-80                                     119
1980-81                                     138
1981-82                                     96
1982-83                                     114
1983-84                                     81
1984-85                                     105
1985-86                                     172
1986-87                                     116
1987-88                                     113
1988-89                                     105
1989-90                                     135
1990-91                                     125
1991-92                                     109
Average                                     111
============================================================
Total                                     $1,559
------------------------------------------------------------
\a There were no sales in 1977-78. 

\b In thousands of dollars. 

The Publishing Center's ability to disseminate information gained
through WEEA-funded interventions has been limited by the fact that
WEEA does not require applicants to produce materials and by the
focus of WEEA funding on service activities and on activities of
local significance that are not easily adapted to dissemination.  The
lack of sound evaluations of WEEA interventions means the Publishing
Center must distribute products that have not been documented as
successful in their original sites. 


      QUESTION 4:  CHANGES IN
      PROGRAM ADMINISTRATION
---------------------------------------------------------- Letter :5.4

WEEA's survival was in doubt throughout the 1980s.  In 1981, the
Reagan administration asked the Congress to eliminate the program by
folding it into an educational block grant.  When this request was
unsuccessful, the administration, beginning in 1981, requested no
appropriations for the program.  The Congress appropriated funds each
year, but below the 1980 level.  These years were also marked by
personnel decisions that downsized the professional staff of the WEEA
Program from six (in 1981) to one and one-quarter (in 1988 through
the present) and downgraded the reporting level of the program. 
Until the early 1980s, WEEA had a director who reported to the
Assistant Secretary for Elementary and Secondary Education.  At the
time of our data collection, there was no director and the program
was three organizational levels below the Assistant Secretary.\7

Attempts to eliminate the WEEA Program continued under the Bush
administration, and it appeared that the program would be phased out
by 1993.  The Congress accepted the Department's fiscal year 1992
funding request of $500,000 to support the Publishing Center only. 
(No new grants were awarded that year.) The administration requested
no funds for WEEA for fiscal year 1993.  Again, however, an
appropriation was restored by the Congress at the level of $1.98
million. 

The Clinton administration requested and received an increase in the
WEEA appropriation from $1.98 million in each of fiscal years 1993
and 1994 to $3.97 million in fiscal year 1995.  No changes in the
reporting level or the personnel resources for the program were
requested or received.\8 Some programmatic changes will be required
owing to the recent legislation reauthorizing WEEA, but it is not
clear whether the Department will make fundamental changes in the
design and implementation of the program. 


--------------------
\7 WEEA is located in the National Programs and Activities Branch,
Equity and Educational Excellence Division, Office of School
Improvement Programs.  Seven offices report to the Assistant
Secretary for Elementary and Secondary Education. 

\8 The reauthorization of WEEA does require cooperation between staff
of the WEEA Program and the Office of Educational Research and
Improvement on research activities. 


         CURRENT PROGRAM
         ADMINISTRATION
-------------------------------------------------------- Letter :5.4.1

The WEEA Program is currently administered by two mid-level
professionals.  One is assigned to the Department of Education's
Office of School Improvement Program, with full-time responsibility
for grant solicitation, awards, and project oversight.  The other is
assigned to Education's Office of Educational Research and
Improvement and spends an average full- time-equivalency of 25
percent administering the Publishing Center contract and overseeing
the operations of the Center. 

WEEA's project-to-program officer ratio has increased over the past
decade, and present staffing is insufficient to provide much
technical assistance to grantees.  When the WEEA Program had a
professional staff of six, one program officer staffed about 15-16
projects.  In the period 1988-91, the project-to-program officer
ratio was about one program officer for every 22 projects.  Yet over
the later period, many grantees were newcomers to WEEA (because of
the special consideration for new applicants) and thus were more
likely to need help than more experienced applicants.  Further, the
large number of missing end-of-grant reports (and the missing
evaluation material that these reports should have included)
indicates lapses in project oversight. 


         PROCESS OF SELECTING WEEA
         AWARDEES
-------------------------------------------------------- Letter :5.4.2

As part of our examination of WEEA program administration, we
reviewed the process by which WEEA applications were scored and
funding decisions made.  We based this analysis on a sample of
original project applications and related information on those
applications from WEEA files, including reviewer comments and
scoring.  We also discussed the process of application review in
detail with program officials. 

In an earlier section, we noted the two types of grants (challenge
and general) and the provisions to ensure that awards are made to
various categories of applications.  At the beginning of each funding
cycle, the Secretary selects one or more funding priorities.  The
Secretary approves an initial allocation of funds for each priority
and for "other authorized activities" as well as an estimate of funds
available for challenge and general awards.  This information and the
estimated number of awards for each type of grant are made public. 

In a year in which there is one priority, there would be four
competition groups (priority area challenge, priority area general,
"other" challenge, and "other" general).  Applicants indicate the
competition group for which they are applying.  When applications are
received, a panel of two or three reviewers is set up for each
competition group.  The panel assigns scores to each application
received in the competition group.  Department officials are present
at each panel and seek to standardize the review and scoring across
the panels. 

Applications are scored on four dimensions (and subscores within each
dimension).  The four dimensions with maximum total points are:  plan
of operation (40), impact (24), need (20), and staff qualifications
(16).  In addition to these 100 possible points, challenge
applications receive up to 5 points on extent of innovation.  For
both classes of award, applicants who have not previously received
funding under WEEA or under part C of title IX receive an additional
10 points. 

After the applications are scored, a list of applicants for each
competition is produced, as is a consolidated list of all applicants. 
Department officials select for funding the highest rated application
from each of the 10 Department of Education regions.  The remaining
applications are arrayed against the various requirements, as
summarized in table 9. 



                           Table 9
           
                    WEEA Award Priorities

Funding
criterion     Definition                            Target
------------  ------------------------------------  --------
Selected      Initial dollar allocation by          Determin
funding       priority                              ed by
priority      Initial estimate of number of awards  the
              by priority                           Secretar
                                                    y

Type of       Initial dollar allocation by type of  Determin
award         grant                                 ed by
(general,     Initial estimate of number of awards  the
challenge)    by type                               Secretar
              of grant                              y

Geographical  One award for each of 10              10
region        geographical regions                  awards

Level of      One award each for preschool,         4 awards
education     elementary and secondary,
addressed     postsecondary, and adult education

Classes of    One award each for education          6 awards
activities    materials; model training projects;
proposed      research and development activities;
              activities for underemployed and
              unemployed women; and programs and
              activities for women in vocational,
              career and physical education, and
              educational administration

Type of       One award each for local education    5 awards
grantee       agencies,
              state education agencies,
              postsecondary education
              institutions, nonprofit
              organizations, and individuals
------------------------------------------------------------
The initial selection of the 10 regional awards meets the geographic
distribution requirement, but arraying the remaining requirements
against the ranked applications calls for a complex selection
process.  (See table 9.) According to Department officials, there is
no standard approach after the selection of the 10 regional awards. 
Even the separation of the competitions may or may not be retained as
the selection proceeds. 

Table 10 shows the number of general and challenge grant applications
and awards for a 5-year period (with no breakdown by priority funding
areas, which vary in number). 



                           Table 10
           
            Number of WEEA Applications Submitted
                          and Funded

Applications        1987     1988     1989     1990     1991
---------------  -------  -------  -------  -------  -------
Submitted
------------------------------------------------------------
Challenge             72       71       20       26       38
General              313      278      181      240      209

Funded
------------------------------------------------------------
Challenge             16       19       12       14        5
General               16       20       17        9       12
------------------------------------------------------------
Only between 5 and 20 applications were funded each year for each
grant type.  Given the small number of actual awards, it appears that
more funding criteria were established than could have been
meaningfully met if the Department were to limit awards to higher
scoring applicants.  Another way of viewing the results of this
process is to subtract the 10 regional awards from the total number
of funded awards shown in table 10.  In the 1988-91 period, that left
a range of 7-29 remaining awards to be determined after the regional
selections.\9

The Department of Education takes these various requirements
seriously.  Lists with categories similar to table 9 are prepared
each year for the actual awards, showing the extent to which the
various targets are met.  But there are so many requirements that
they cannot be achieved with uniformity.  For example, with regard to
the initial allocations estimating the number of awards of each type,
we found a median difference of 25 percent between the projected and
actual number of general and challenge grants.  We also found some
evidence to question the meaning of at least one of the
requirements--funding priorities.  Based on our interviews with
Department officials, we understand that the applicants' decision to
apply under the selected priorities or "other" class is not
questioned.  However, in reviewing a sample of proposals for priority
and other awards, we were often unable to see differences between the
activities proposed under the two groups. 

It appears that the Department limited the number of new grantees
more through a substantial reduction in the number of multiyear (or
continuation) awards than through rejection of applications by former
grantees.  We noted earlier that there were only 3 continuation
awards out of 205 awards, or 1.5 percent, in the period of our study. 
In comparison, 125 of the 383 awards made between 1977 and 1982 (33
percent) were continuations.\10 We also looked at the number of new,
noncontinuation grants awarded to individuals who had been funded
previously during each of these two 6-year periods.  In both periods,
about 14 percent of awards were to recipients who had been previously
funded.\11 Of course, applicants may have anticipated a low
likelihood of repeat funding, and few may have applied.  The practice
favoring one-time funding of single-year awards allows more
applications to be funded, but it discourages the development of
expertise and the refinement of approaches. 

The many funding requirements, when applied to the WEEA Program
during a period of modest appropriations and diminishing pools of
applicants, may have limited the capacity to award grants on the
basis of merit.  Although we did not conduct a statistical analysis
of the relative influence of total score and the additional
requirements (shown in table 9) in determining which applications are
funded, it appears that the Department gives serious attention to the
additional requirements.  The impact of these added criteria--which
are not unusual legislatively--could be substantial owing to their
large number and the small size of the WEEA Program.  The description
of the process for selecting WEEA grantees suggests that the need to
consider so many funding priorities makes the selection process more
a mechanical application of rules than a consideration of the better
applications. 


--------------------
\9 This range is derived by adding the challenge and general awards
and subtracting 10.  The results, starting with 1988, are 29, 19, 13,
and 7.  We omit the year 1987 from this analysis because the
legislation mandating the special consideration for geographic
distribution was enacted in spring 1988. 

\10 We used the years 1977 through 1982 for comparison because data
were not available for the years 1983 through 1985. 

\11 For this analysis, a continuation grant counted as one award. 
From 1986 to 1991, 28 of 203 new grants (14 percent) went to former
recipients for the same period.  From 1977 to 1982, 37 of 258 new
grants (14 percent) were awarded to previous grantees during those 6
years.  It would have been preferable to examine repeat funding for
the entire duration of the WEEA Program, but we did not have the
resources to do the extensive data collection and aggregation that
such an analysis would have required. 


   IMPLICATIONS AND CONCLUSIONS
------------------------------------------------------------ Letter :6

A program with no director, a staff of one and one-quarter persons
located in two different offices of the Department of Education, and
operating under threat of extinction for a decade, WEEA now has a
substantial appropriation increase.  Our review suggests a need to
revisit WEEA's fundamental goals and strategies. 

WEEA was enacted 20 years ago out of a concern that girls and women
were being subjected to fundamental institutional discrimination
including school counseling that steered girls away from higher
paying "male" careers, sex biases in textbooks and other curriculum
materials, and discrimination in admissions by postsecondary
institutions.  In the 1986-91 period, we found WEEA provided
relatively little funding of activities to eliminate such problems in
educational institutions.  Instead, projects typically provided
short-term direct services, often career counseling, remedial and
other academic instruction, and personal support services, such as
psychological counseling, that were not integrated with on-going
school-based activities. 

Activities funded by WEEA are typically not provided in close
association with the schools.  The dominant WEEA activities--academic
instruction, counseling, and personal support services--are
apparently needed because gender-based discrimination in the schools
is still a problem.  Yet one of the three WEEA objectives is to help
educational institutions meet the requirements of title IX
prohibiting sex discrimination in all educational institutions
receiving federal funds.  However, we found that only 7 percent of
WEEA activities concerned title IX compliance, and we classified only
one state or local education agency grant as having title IX
compliance as its primary WEEA activity.  Further, only 17 percent of
WEEA awards were received by state and local education agencies, and
we saw little or no evidence that other grantees (such as
universities) were working in close partnerships with state agencies
or local schools to identify and remedy sex equity problems in the
public schools. 

WEEA activities appear to be out of balance in that too many
resources go for direct services to small numbers of persons and too
few resources go to eliminate systemic inequitable policies and
practices that will affect future generations of girls and women. 
Department officials need to consider what the educational
equity-related needs of women and girls in the 1990s are and what
role the WEEA Program should have in meeting them. 

Critics of WEEA may argue that there is another possibility, that
there are few substantial problems of sex equity in the schools and
colleges and that WEEA funding is unnecessary for either projects
like those we examined or projects aimed at identifying and remedying
sex inequities in educational institutions.  That debate may be
resolved by data to be collected for a mandated report to the
President and the Congress on the status of educational equity for
girls and women.  The reauthorization of WEEA requires this report by
January 1, 1999. 

We noted earlier that the legislation sets a priority for projects of
"national, statewide, or general significance," but that only 28
percent of the funded applications we reviewed had proposed
activities that held promise of significance at the national level. 
One consequence of this finding is that the pool of WEEA projects
available as good candidates for dissemination through the WEEA
Publishing Center is very restricted.  The Department of Education
argued that the act does not define these terms, and the Department
considers any project whose "potential impact is not confined to a
local area" as a project of general significance.  One result is that
the legislative priority on disseminating effective practices in
promoting sex equity in education has been limited. 

The absence of evaluation information on past WEEA projects means
that the program is left with little evidence of their effectiveness
in eliminating sex bias in education.  If the program is redirected,
it should collect such information as a guide toward funding more
successful programs.  One result should be that WEEA would build up a
base of projects with some documented effectiveness in eliminating
sex bias in education. 

We discussed our findings and their implications for the then-pending
reauthorization of WEEA with your Committee staff.  In October 1994,
the Congress passed this reauthorization as part of the Improving
America's Schools Act of 1994 (commonly referred to as the
reauthorization of the Elementary and Secondary Education Act).  The
President signed this as Public Law 103-382 on October 20, 1994. 

The structure of general and challenge grants along with a
dissemination function implemented through the WEEA Publishing Center
appear to be substantially changed by the act.  Two program types are
specified:  (1) awards to develop and implement model equity programs
and (2) awards for support and technical assistance.  At least
two-thirds of funds appropriated each year must be for the first type
of award, which may be similar to the general grants we studied. 

The legislative language on dissemination and the priority for
funding projects of national and statewide significance that had
applied to the WEEA Program are gone.  It appears that the
dissemination approach--relying upon WEEA projects as a source of
information on effective gender equity practices and in turn
packaging and disseminating that information--has been replaced (or
at least modified) by an emphasis on technical assistance and
research and development.  One form of support and technical
assistance is awards "to implement effective gender-equity policies
and programs at all educational levels." The second form is research
and development awards "designed to advance gender equity nationwide
and to help make policies and practices in educational agencies and
institutions, and local communities, gender equitable." Research
activities are to be coordinated with the Office of Educational
Research and Improvement.  The act provides separate extensive lists
of specific examples of each of these two forms of support and
technical assistance.  Among its other requirements, the act mandates
that the activities "are administered within the Department by a
person who has recognized professional qualifications and experience
in the field of gender equity education."


   MATTERS FOR CONGRESSIONAL
   CONSIDERATION
------------------------------------------------------------ Letter :7

The Congress should weigh whatever benefits it perceives from the
various funding requirements--such as the special consideration for
applicants who have not received assistance under WEEA or under part
C of title IX of the Elementary and Secondary Education Act and the
requirements for a geographical distribution of awards--against any
drawbacks of those provisions.  In this small program, the
multiplicity of funding requirements may make the grant award process
too mechanistic and may reduce the likelihood that higher scoring
applications would be funded. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :8

We recommend that the Secretary of Education revisit the fundamental
goals and strategies of the WEEA Program.  The doubling of the WEEA
appropriation makes it particularly important to steer resources away
from local delivery of direct services and toward the broader
elimination of inequitable policies and practices that may otherwise
affect future generations of girls and women.  Finally, the Secretary
should take steps to ensure that the program is supported by adequate
evaluation of funded projects and sufficient administrative support. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :9

We requested and received comments on a draft of this report from the
Department of Education, which generally reaffirmed its belief in the
WEEA activities and projects it has funded over the years.  The full
text of their comments and our response to them

We will be sending copies of this report to the Secretary of
Education and to other interested parties.  Copies will also be made
available to others upon request.  If you have any questions or would
like additional information, please call me at (202) 512-5885.  Other
major contributors to this report are listed in appendix III.






Robert L.  York
Director of Program Evaluation
 in Human Services Areas


HISTORY OF THE WEEA PROGRAM
=========================================================== Appendix I


   LEGISLATIVE HISTORY
--------------------------------------------------------- Appendix I:1


      SPECIAL PROJECTS ACT OF THE
      EDUCATION AMENDMENTS OF 1974
------------------------------------------------------- Appendix I:1.1

Under the sponsorship of Representative Patsy T.  Mink and
then-Senator Walter F.  Mondale, the Congress enacted WEEA in 1974 as
part of the Special Projects Act included in the Education Amendments
of 1974.  The WEEA legislation authorized the Commissioner of
Education (later, with the creation of the Department of Education,
the Secretary) to award funds by grants and contracts to individuals,
public agencies, and nonprofit organizations for an extremely broad
range of activities to provide educational equity for women.  The act
specified that these activities include

the development, evaluation, and dissemination of curricula,
textbooks, and other educational material;

preservice and in-service training for educational personnel;

research, development, and other activities designed to advance
educational equity;

guidance and counseling activities, including the development of
bias-free tests;

educational activities to increase opportunities for adult women; and

the expansion and improvement of educational programs and activities
for women in vocational education, career education, physical
education, and education administration. 

The authorization included several stipulations: 

All projects receiving grants must fall into one of two categories: 
one was a general range of activities including the six areas
described above and the other was small grants (not to exceed
$15,000) that funded "innovative approaches" for the achievement of
educational equity for women and girls. 

Applicants were required "to set forth policies and procedures which
ensure adequate evaluation of the activities intended to be carried
out under the application."

All supported activities had to be administered or supervised by the
applicant. 

All supported activities had to show promise of making substantial
contribution toward attaining the purposes of the act. 

WEEA established a National Advisory Council on Women's Education
Programs within the Office of Education.  The Council consisted of: 
17 members appointed by the President and confirmed by the Senate for
terms of 3 years; the Chairman of the Civil Rights Commission; the
Director of the Women's Bureau of the Department of Labor; and the
Director of the Women's Action Program of the former Department of
Health, Education, and Welfare.  The Council was responsible for
advising the Commissioner of Education on general matters regarding
gender equity, recommending how funds be allocated, and developing
criteria for the establishment of program priorities. 


      EDUCATION AMENDMENTS OF 1978
------------------------------------------------------- Appendix I:1.2

WEEA was reauthorized in 1978 as title IX, part C of the Elementary
and Secondary Education Act.  The amendments included several notable
changes.  First, language describing the purpose of the act was
expanded to include providing financial assistance to enable
educational agencies and institutions to meet the requirements of
title IX of the Education Amendments of 1972.  Second, the
Commissioner was directed to establish funding priorities.  Third,
the ceiling for the small grant program was raised to $25,000. 
Fourth, prior language stipulating that funds shall be used for the
six activities listed above was broadened with new language stating
that funding may be used for activities in these areas.\1 Finally,
priority was given to demonstration, developmental, and dissemination
activities of national, statewide, or general significance. 


--------------------
\1 In addition, the law authorized grants of local significance to
assist school district and other institutions in meeting title IX
requirements.  The implementation of this program was dependent upon
the level of WEEA's appropriation.  Once WEEA's funding reached $15
million, all money beyond this amount was to be directed for projects
of local significance.  (Although the triggering funding level was
reduced in subsequent reauthorizations, WEEA's funding never reached
the level required to implement this provision.  A high of $10
million was reached in 1980, and funding declined steadily
thereafter.)


      WEEA AMENDMENTS OF 1984
------------------------------------------------------- Appendix I:1.3

The 1984 WEEA amendments included two changes.  First, the stated
purpose of the act was expanded with the following language: 

"it is also the purpose of this part to provide educational equity
for women and girls who suffer multiple discrimination, bias, or
stereotyping based on sex and on race, ethnic origin, disability, or
age."

Second, the small grant program was replaced with a challenge
provision, which authorized the Secretary to award grants of up to
$40,000 to activities

"to develop comprehensive plans for the implementation of equity
programs; innovative approaches to school community partnerships; new
dissemination and replication strategies; and other innovative
approaches to achieving the purposes of WEEA."

Finally, the act required the Secretary to ensure that at least one
grant or contract was available during each funding year to support
each of six activities authorized in the 1974 amendments. 


         HAWKINS-STAFFORD
         AMENDMENTS OF 1988
----------------------------------------------------- Appendix I:1.3.1

The Hawkins-Stafford Elementary School Improvement Act of 1988
further amended WEEA.  First, the act abolished the National Advisory
Council on Women's Educational Programs.  Second, it required
"special consideration" for applicants who had not received previous
funding under the WEEA Program or under part C of title IX of the
Elementary and Secondary Education Act of 1965 and for proposals from
applicants on the basis of geographic distribution.  Third, the act
emphasized that activities be funded at all levels of education,
including preschool, elementary and secondary education, higher
education, and adult education.  Finally, the act transferred
responsibility for publication and dissemination of WEEA products
from the Office of Elementary and Secondary Education to the Office
of Educational Research and Improvement. 


   REGULATORY DEVELOPMENTS
--------------------------------------------------------- Appendix I:2


      THE 1980 WEEA REGULATION
------------------------------------------------------- Appendix I:2.1

In response to the new statutory requirement that the Secretary set
funding priorities, the Department of Education issued regulations in
1980 that established five priorities and a sixth category:  "other
authorized activities."\2 Under the rules, the Secretary would select
one or more of these priorities and allocate funds to each. 
Remaining funds would be allocated to the "other" category. 
Applicants would compete only against others who chose to compete
under the same selected priority.  Applicants who did not indicate a
priority or who addressed a priority that was not selected by the
Secretary competed in the "other" category.  Thus, several
competitions were conducted annually, one for each of the announced
priorities and one for applicants competing under "other."

Beginning in 1982, small grant applicants also were required to
select a priority, resulting in separate competitions for each
priority area and "other" for both general and small grants.  Table
I.1 displays the announced and established priorities for the years
1981-88. 



                                    Table I.1
                     
                       WEEA Funding Priorities From 1981 to
                                      1988\a

Model
projects     1981     1982     1983     1984     1985     1986     1987     1988
--------  -------  -------  -------  -------  -------  -------  -------  -------
Title IX        X        X        X        X        X        X        X
 complia
 nce
Providin        X        X        X        X        X
 g
 educati
 onal
 equity
 for
 racial
 and
 ethnic
 minorit
 ies
Providin        X        X        X        X        X
 g
 educati
 onal
 equity
 for
 disable
 d women
 and
 girls
Influenc        X        X
 ing
 leaders
 in
 educati
 onal
 policy
 and
 adminis
 tration
Eliminat        X        X        X        X        X                          X
 ing
 persist
 ent
 barrier
 s to
 educati
 onal
 equity
 for
 women
--------------------------------------------------------------------------------
\a An "X" denotes the annual priorities selected by the Secretary. 


--------------------
\2 45 C.F.R.  part 1601. 


      THE 1989 WEEA REGULATION
------------------------------------------------------- Appendix I:2.2

In 1989, the Department published a new regulation with six new
priorities that replaced the 1980 priorities.\3 The "other authorized
activities" category was retained.  As before, the Secretary was to
select one or more priorities from this list and conduct various
competitions for each priority selected and for those classified as
"other" for both challenge and general grants.  Table I.2 displays
priorities announced for 1989 through 1994. 

A comparison between the funding priorities established by the 1980
WEEA Regulation and the 1989 WEEA Regulation indicates a change in
the Department's goals for the WEEA Program.  The 1980 funding
priorities emphasized the development of model programs to provide
educational equity for women and girls, including those who are
members of minority groups or disabled.  The funding priorities
established by the 1989 regulations call for the development and
expansion of programs that increase opportunities for women,
including those who experience multiple discrimination, and tend to
narrow WEEA's focus to specific curricular areas such as mathematics
and career education. 



                                    Table I.2
                     
                       WEEA Funding Priorities From 1989 to
                                      1994\a

Projects                            1989    1990    1991  1992\b    1993    1994
--------------------------------  ------  ------  ------  ------  ------  ------
Develop and test model programs                                                X
 and materials that could be
 used by local educational
 agencies and other entities in
 meeting title IX requirements
Develop new educational                                X               X       X
 programs, training programs,
 counseling programs, or other
 programs designed to increase
 the interest and participation
 of women in instructional
 courses in mathematics,
 science, and computer science
Develop new educational                        X
 programs, training programs,
 counseling programs, or other
 programs, or expand existing
 model educational programs,
 designed to enhance educational
 achievement for women who are
 economically disadvantaged
Develop or expand guidance and
 counseling programs designed to
 increase the knowledge and
 awareness of women regarding
 opportunities in careers in
 which women have not
 significantly participated
Develop new educational                        X
 programs, or expand existing
 model programs, designed to
 reduce the rate at which women
 drop out of formal education
 and encourage women dropouts to
 resume their education
Develop new educational                X       X
 programs, or expand existing
 model educational programs,
 designed to enhance
 opportunities for educational
 achievement by women who suffer
 multiple discrimination on the
 basis of sex and race, ethnic
 origin, age, or disability
--------------------------------------------------------------------------------
\a An "X" denotes the annual priorities selected by the Secretary. 

\b No priorities were selected in 1992 because grants were not
awarded that year. 


--------------------
\3 34 C.F.R.  parts 245, 246, 247, and 745. 


   FUNDING HISTORY
--------------------------------------------------------- Appendix I:3

Historically, the WEEA Program has been funded at very low levels. 
It was funded first in 1976 with an appropriation of $6.27 million. 
Its appropriation grew steadily through 1980 to a high of $10 million
in that year.  Support for the WEEA Program declined in the 1980s. 
These years witnessed several attempts by successive administrations
to devolve the program through zero budgeting.  The Congress restored
funding during the appropriation process, but WEEA appropriations
fell steadily.  The level of WEEA's authorizations and appropriations
by fiscal year is listed on table I.3. 



                          Table I.3
           
             WEEA Authorization and Appropriation
                            Levels

Fiscal year             Authorization \a    Appropriation \a
--------------------  ------------------  ------------------
1976                             $30,000              $6,270
1977                              30,000               7,270
1978                              30,000               8,085
1979                              30,000               9,000
1980                              80,000              10,000
1981                              80,000               8,125
1982                               6,000               5,760
1983                               6,000               5,760
1984                               6,000               5,760
1985                              10,000               6,000
1986                              12,000               5,740
1987                              14,000               3,500
1988                              16,000               3,351
1989                               9,000               2,949
1990\b                                                 2,098
1991\b                                                 1,995
1992\b                                                   500
1993\b                                                 1,984
============================================================
Total                                                $94,147
------------------------------------------------------------
\a In thousands of dollars. 

\b The 1988 amendments did not establish authorization levels for
fiscal years 1990-93. 




(See figure in printed edition.)Appendix II
COMMENTS FROM THE DEPARTMENT OF
EDUCATION
=========================================================== Appendix I



(See figure in printed edition.)

 See comment 1. 



(See figure in printed edition.)

 See comment 2. 

 See comment 3. 

 See comment 4. 



(See figure in printed edition.)


The following are GAO's comments on the June 13, 1994, letter from
the Department of Education. 


   GENERAL COMMENTS
--------------------------------------------------------- Appendix I:4

The Department of Education, commenting on a draft of this report,
reaffirmed its belief in the WEEA activities and projects it has
funded.  The Department states, first, that success in generating and
testing new strategies for gender equity is more important than
whether projects result in systemic, institutionwide change.  Second,
they maintain that projects "properly authorized by a statute, by
definition, are carrying out the purpose of the statute." Third, the
Department concludes that GAO's "evidence shows that WEEA-funded
projects do serve the purposes of the legislation." Fourth, they
argue that the statute requires funding of direct services and
activities as a means for providing gender equity. 

We agree that WEEA has funded useful activities and projects;
however, our report questions the pronounced past emphasis in WEEA on
providing services to compensate for past and possibly current
educational inequities.  The result is that relatively few WEEA
resources are directed at identifying sex inequities in schools and
colleges and developing remedies for those inequities.  On the
Department's first point, we saw no evidence to suggest that WEEA is
generating and testing new strategies for gender equity. 

Second, our point is that while the activities funded by WEEA are
authorized by the statute, the mix of projects funded is such that
issues of identifying and removing systemic barriers to sex equity
are receiving much less emphasis under WEEA than those of providing
services to a small number of persons.  The result is that WEEA
projects do little to reduce the negative impact of sex inequities in
education for future generations of girls and women.  We have
expanded our discussion of these findings in the Implications and
Conclusions section of the report.  (See pp.  23-26.)

Third, the Department argues that the fact that over 70 percent of
applicants funded to develop educational materials produced products
and continued to offer them is evidence that WEEA projects serve the
purposes of the legislation.  We agree that this finding represents
an accomplishment of the program, although we think that more than 15
percent of WEEA projects would result in commercially published
products if they had the potential for replication and dissemination. 
The Department also cites our finding that almost half of projects
providing student services continue beyond the WEEA funding period as
evidence of success.  However, we also noted that these continuations
were largely sponsored by state or other federal grants rather than
being adopted as regular programs of local government agencies or the
institutions receiving the WEEA grants. 

Fourth, the act authorizes direct services such as instruction,
counseling, day care, and transportation, but we see no basis for the
Department's statement that the act "requires funding of direct
services and activities." We believe the question of whether or not
WEEA overemphasizes direct service activities deserves thoughtful
consideration. 

The Department also argues that our report provides little discussion
of WEEA products and WEEA's dissemination efforts.  We agree that
there are strengths in the WEEA dissemination efforts:  the WEEA
Publishing Center actively seeks products to disseminate, works with
grantees to make products marketable, publishes products
commercially, and also performs useful coordination and technical
assistance services.  The dissemination effort would be improved if
WEEA supported more projects with a favorable dissemination potential
(supporting demonstration, developmental, and dissemination
activities of national significance).  Few new products have been
developed for dissemination each year.  Further, the value of
Publishing Center products is uncertain because of the fact that WEEA
grantees rarely submit products for dissemination that have been
evaluated for their effectiveness in providing gender equity. 

We recommended that the Department revisit the fundamental goals and
strategies of the WEEA Program.  In response, the Department stated
that it had requested reauthorization of WEEA and increased funding
and has determined that curriculum development and "implementation of
effective gender equity strategies" are desirable.  This does not
appear to change the fundamental goals and strategies of the existing
program.  After years of reacting to a variety of external pressures,
WEEA would benefit from a broader, constructive effort to determine
how it can more effectively promote gender equity in education. 


   SPECIFIC COMMENTS
--------------------------------------------------------- Appendix I:5

1. The Department sent a description of projects, noting that they
had provided this to us earlier but we did not include it in our
report.  We had reviewed this list earlier and found that many of the
projects had been funded a decade ago and were thus outside the time
period of our study.  For the more recent projects, when we matched
these descriptions with the information from project records, we
decided to rely upon the information in project records and from our
telephone survey, both of which appeared to be the best sources of
information on the nature and scope of the projects. 

2. The Department argues that the application ranking process has
produced the current balance of awards to nonprofit organizations and
to state and local educational agencies.  That may be true; however,
our concern is that the application ranking process as it now works
is not producing a set of funded projects that share a clear
potential for reducing future gender inequities.  There are too many
factors to consider besides the merit of the application. 

3. The Department requests that we explain how we determined the
"national or general significance" of projects and how we determined
that most challenge grants were "`conventional' and not innovative."
We have expanded the text to clarify how the national or general
significance categorizations were made.  (See p.  16.) We have
deleted the discussion about the extent of innovation among challenge
grants. 

4. The Department maintains that it provided all records us in a
timely manner.  Although we found the Department reluctant at first
to allow us direct access to project records, we agree that this
problem was resolved and did not result in substantial delays.  We
have deleted the comment concerning timely access from the report. 
However, the Department is not correct in stating that the only
records it was unable to provide us were those that were destroyed
under the Department's 5-year record retention policy.  As we note on
page 3, the Department was able to provide us with only about half of
the end-of-grant reports that were less than 5 years old at the time
of our data collection. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III


   PROGRAM EVALUATION AND
   METHODOLOGY DIVISION
------------------------------------------------------- Appendix III:1

Kathleen D.  White, Project Manager
Frederick V.  Mulhauser
George H.  Bogart
Venkareddy Chennareddy
Jennifer Salzman
