No Child Left Behind Act
More Information Would Help States Determine Which Teachers Are Highly Qualified Gao ID: GAO-03-631 July 17, 2003In December 2001, Congress passed the No Child Left Behind Act (NCLBA). The act required that all teachers of core subjects be highly qualified by the end of the 2005-06 school year and provided funding to help states and districts meet the requirement. In general, the act requires that teachers have a bachelor's degree, meet full state certification, and demonstrate subject area knowledge for every core subject they teach. This report focuses on the (1) number of teachers who met the highly qualified criteria during the 2002-03 school year, (2) conditions that hinder states' and districts' ability to meet the requirement, and (3) activities on which states and districts were planning to spend their Title II funds. GAO surveyed 50 states and the District of Columbia and a nationally representative sample of districts about their plans to implement the requirement. GAO also visited and interviewed officials in 8 states and 16 districts to discuss their efforts to implement the law.
GAO could not develop reliable data on the number of highly qualified teachers because states did not have the information needed to determine whether all teachers met the criteria. Officials from 8 states visited said they did not have the information they needed to develop methods to evaluate current teachers' subject area knowledge and the criteria for some teachers were not issued until December 2002. Officials from 7 of 8 states visited said they did not have data systems that could track teacher qualifications for each core subject they teach. Both state and district officials cited many conditions in the GAO survey that hinder their ability to have all highly qualified teachers. State and district officials reported teacher pay issues, such as low salaries and lack of incentive pay, teacher shortages, and other issues as hindrances. GAO's survey estimates show that significantly more high-poverty than low-poverty districts reported hindrances, such as little support for new teachers. Rural district officials cited hindrances related to their size and isolated locations. State officials reported they needed assistance or information from Education, such as in developing incentives to teach in high-poverty schools, and Education's strategic plan addresses some of these needs. To help meet the requirement for highly qualified teachers, state survey respondents reported they planned to spend about 65 percent of their Title II funds on professional development activities authorized under Title II, and districts planned to spend an estimated 66 percent on recruitment and retention. Both state and district officials planned to spend much larger amounts of funds from sources other than Title II funds on such activities. High-poverty districts planned to spend more Title II funds on recruitment and retention than low-poverty districts. State and district officials visited said that most activities were a continuation of those begun previously.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-631, No Child Left Behind Act: More Information Would Help States Determine Which Teachers Are Highly Qualified
This is the accessible text file for GAO report number GAO-03-631
entitled 'No Child Left Behind Act: More Information Would Help States
Determine Which Teachers Are Highly Qualified' which was released on
July 17, 2003.
This text file was formatted by the U.S. General Accounting Office
(GAO) to be accessible to users with visual impairments, as part of a
longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
Report to Congressional Requesters:
United States General Accounting Office:
GAO:
July 2003:
No Child Left Behind Act:
More Information Would Help States Determine Which Teachers Are Highly
Qualified:
GAO-03-631:
GAO Highlights:
Highlights of GAO-03-631, a report to Congressional Requesters
Why GAO Did This Study:
In December 2001, Congress passed the No Child Left Behind Act (NCLBA). The act required that all teachers of core subjects be highly qualified by the end of the 2005-06 school year and provided funding to help states and districts meet the requirement. In general, the act requires that teachers have a bachelor‘s degree, meet full state certification, and demonstrate subject area knowledge for every core subject they teach. This report focuses on the (1) number of teachers who met the highly qualified criteria during the 2002-03 school year, (2) conditions that hinder states‘ and districts‘ ability to meet the requirement, and (3) activities on which states and districts were planning to spend their Title II funds. GAO surveyed 50 states and the District of Columbia and a nationally representative sample of districts about their plans to implement the requirement. GAO also visited and interviewed officials in 8 states and 16 districts to discuss their efforts to implement the law.
What GAO Found:
GAO could not develop reliable data on the number of highly qualified
teachers because states did not have the information needed to
determine whether all teachers met the criteria. Officials from 8
states visited said they did not have the information they needed to
develop methods to evaluate current teachers‘ subject area knowledge
and the criteria for some teachers were not issued until December
2002. Officials from 7 of 8 states visited said they did not have data
systems that could track teacher qualifications for each core subject
they teach.
Both state and district officials cited many conditions in the GAO
survey that hinder their ability to have all highly qualified
teachers. State and district officials reported teacher pay issues,
such as low salaries and lack of incentive pay, teacher shortages, and
other issues as hindrances. GAO‘s survey estimates show that
significantly more high-poverty than low-poverty districts reported
hindrances, such as little support for new teachers. Rural district
officials cited hindrances related to their size and isolated
locations. State officials reported they needed assistance or
information from Education, such as in developing incentives to teach
in high-poverty schools, and Education‘s strategic plan addresses some
of these needs.
To help meet the requirement for highly qualified teachers, state
survey respondents reported they planned to spend about 65 percent of
their Title II funds on professional development activities authorized
under Title II, and districts planned to spend an estimated 66 percent
on recruitment and retention. Both state and district officials
planned to spend much larger amounts of funds from sources other than
Title II funds on such activities. High-poverty districts planned to
spend more Title II funds on recruitment and retention than low-
poverty districts. State and district officials visited said that most
activities were a continuation of those begun previously.
What GAO Recommends:
To help states determine which teachers are highly qualified and the
actions they need to take to meet the requirement, GAO recommends that
the Secretary of Education provide more information to states,
especially on ways to evaluate the subject area knowledge of current
teachers. The Department of Education provided written comments on a
draft of this report and generally agreed with GAO‘s recommendation.
www.gao.gov/cgi-bin/getrpt?GAO-03-631.
To view the full product, including the scope and methodology, click
on the link above. For more information, contact Marnie S. Shaul, 512-
7215, shaulm@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Many States Were Uncertain about Numbers of Highly Qualified Teachers:
State and District Officials Reported Many Conditions as Hindrances to
Meeting the Law:
To Help Teachers Meet the Requirement States Planned to Spend Most
Title II Funds on Professional Development Activities, and Districts
Will Spend Most on Recruitment and Retention Activities:
Conclusions:
Recommendation for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Activities on Which States Can Spend Title II, Part A
Funds:
Appendix III: Activities on Which Districts Can Spend Title II, Part A
Funds:
Appendix IV: Comments from the U.S. Department of Education:
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Staff Acknowledgments:
Tables:
Table 1: Federal Criteria for a Highly Qualified Teacher:
Table 2: Estimated Percentages of Districts That Will Have Difficulty
Meeting the Requirement for Highly Qualified Teachers by Grade Level
and Poverty:
Table 3: Number of States Reporting on Conditions That Hinder Their
Ability to Meet the Requirement for Highly Qualified Teachers (Ranked
from Highest to Lowest):
Table 4: Estimated Percentages of Districts Reporting on Conditions
That Hinder Their Ability to Meet the Requirement for Highly Qualified
Teachers (Ranked from Highest to Lowest):
Table 5: Estimated Percentages of High-and Low-Poverty Districts with
Significant Differences in the Hindrances to Meeting the Requirement:
Table 6: Estimated Percent of Spending Title II Funds by Activities for
All Districts, High-Poverty Districts, and Low-Poverty Districts:
Table 7: Population and Sample by Stratum:
Table 8: Sample Estimates Compared to Population Values:
Table 9: Population and Sample by Region:
Table 10: Title II, Part A State Activities:
Table 11: Title II, Part A District Activities:
Figures:
Figure 1: Education's Assistance to States During Calendar Year 2002:
Figure 2: Planned Spending of Title II Funds by Reporting States:
Figure 3: Sources of Funds for Planned Spending by States on Title II
Activities:
Figure 4: Estimated Spending of Title II Funds as a Percentage of Total
Funds by Activities for All Districts, High-Poverty Districts, and Low-
Poverty Districts:
Figure 5: State Survey Respondents:
Abbreviations:
CCD: Core of Common Data:
CCSSO: Council of Chief State School Officers:
CMSA: Consolidated Metropolitan Statistical Area:
LEA: Local Education Agency:
MSA: Metropolitan Statistical Area:
NCLBA: No Child Left Behind Act:
United States General Accounting Office:
Washington, DC 20548:
July 17, 2003:
The Honorable Edward M. Kennedy
The Honorable Jeff Bingaman
United States Senate:
In December 2001, Congress passed the No Child Left Behind Act (NCLBA),
which, among other things, focused attention on closing the achievement
gaps among various groups of students. Recently, a body of research has
shown that quality teachers play a significant role in improving
student performance. However, research has also shown that many
teachers, especially those in high-poverty and rural
districts,[Footnote 1] were not certified and lacked knowledge of the
subjects they taught. NCLBA established the requirement that all
teachers be highly qualified for each core subject they teach by the
end of the 2005-06 school year.[Footnote 2] The criteria for meeting
this requirement vary somewhat by grade level and experience but
generally require that teachers have (1) a bachelor's degree, (2) state
certification, and (3) subject area knowledge for each core subject
they teach. This represents the first time the federal government has
established specific criteria for teachers. Title II, Part A, of NCLBA
replaced the Eisenhower Professional Development and Class Size
Reduction programs with the Teacher and Principal Training and
Recruiting Fund and Congress appropriated $2.85 billion to help states
and districts meet the requirement. In addition, Title II directed
these funds to be spent on specific activities to help states and
districts recruit, retain, and develop highly qualified teachers. The
Department of Education (Education) administers Title II and is
responsible for oversight of states' implementation of NCLBA.
Given the need for states and districts to meet the requirement for
highly qualified teachers by the end of the 2005-06 school year, you
asked us to determine what they were doing to have their teachers meet
the requirement. Specifically, this report focuses on the (1) number of
teachers who met the highly qualified teacher criteria during the 2002-
03 school year, (2) conditions that hinder states' and districts'
ability to meet the requirement, and (3) activities on which states and
districts were planning to spend their Title II funds.
In conducting our work, we surveyed 50 states and the District of
Columbia. We obtained responses for 37 of these 51 surveys and reported
the results as representing only those that responded. The student
enrollment for the responding states represented 85 percent of total
student population in kindergarten through 12th grade. In addition, we
surveyed a nationally representative sample of 830 school districts. We
received a response from 511 or 62 percent. We compared relevant
characteristics of these respondents to the universe of districts and
found them to be similar, which along with the response rate allowed us
to report national estimates.[Footnote 3] For our comparisons of high-
and low-poverty districts, we included responding districts that had 70
percent or more of their students approved for free and reduced-price
meals as high-poverty and those with 30 percent or less of their
students approved for free and reduced-price meals as low-poverty. We
visited and interviewed officials in 8 states selected with a range of
characteristics that might affect their ability to meet the
requirement--California, Connecticut, Illinois, Iowa, Maryland, North
Carolina, Delaware, and Wyoming. We visited 2 districts in each of the
states and 1 school in each district. We interviewed U.S. Department of
Education officials, and officials from professional organizations and
unions that represent teachers. Additionally, we analyzed the
legislation, related reports, and relevant documents. See appendix I
for detailed information on the methodology. We conducted our work from
July 2002 through May 2003 in accordance with generally accepted
government auditing standards.
Results in Brief:
We could not develop reliable data on the number of highly qualified
teachers because states did not have the information needed to
determine whether all teachers met the criteria. During our visits
state officials did not know the criteria for some of their teachers.
Education's draft guidance on the criteria for teachers in alternative
certification programs changed between June and December of 2002, which
meant that states had to reassess their teachers' qualifications.
Guidance for special education teachers was not available until
December 2002, and it was contained in an appendix to the Title I
regulations, but not in the federal regulations. Also, states did not
have the information they needed to develop methods to evaluate subject
area knowledge of their current teachers. In our survey, 32 of 37 state
respondents said that they needed clear and timely guidance from
Education. Additionally, officials from 7 of the 8 states we visited
said they did not have data systems that could track teacher
qualifications by subject, which they needed to determine if a highly
qualified teacher taught each core subject. One official added a
comment to the survey that said the state data system on teachers "was
designed years ago for state certification purposes—[and] has not yet
been updated to include all NCLBA criteria for teachers." Some state
officials we interviewed also expressed reservations about changing
their data systems before complete guidance was issued. Furthermore, 6
of the 8 state officials were reluctant to say that their certified
teachers might not be highly qualified because they believed it would
harm teacher morale. Thus, we concluded that the survey data related to
the number of highly qualified teachers would not likely be reliable.
Both state and district officials cited many conditions that hinder
their ability to have all highly qualified teachers. Many state
officials reported issues related to teacher pay, such as low salaries,
lack of incentive pay programs, and a lack of career ladders as
hindrances. For example, 32 of the 37 state officials responding to our
survey said that teacher salaries were low compared with other
occupations. During our visits officials said that salary issues
particularly hindered their efforts to recruit and retain math and
science teachers. Twenty-three of the 37 state officials reported
teacher shortages in high need subject areas--mostly math, science, and
special education. During the late 1990s, there was an increase in
demand for workers with math and science backgrounds, especially in
information technology, and these occupations generally paid higher
salaries than teaching. Other hindrances cited by state officials
included few programs to support new teachers, a lack of leadership
from principals, and union agreements. Our survey estimates show that
salary issues were also hindrances for the majority of the districts,
and about 20 percent of all districts cited teacher development
conditions such as (1) weak technology training for teachers, (2) few
alternative certification programs, and (3) professional development
programs of too short a duration to improve teacher quality. In
addition, significantly more high-poverty than low-poverty districts
identified some conditions as hindrances, according to our survey
responses. For example, an estimated 30 percent of high-poverty
districts compared to 6 percent of low-poverty districts cited few
programs to support new teachers. Officials in rural districts we
visited and who commented on the survey said they faced unusual
conditions because some of them were very small, isolated, or had only
one or two teachers in total at some schools. While many of the
hindrances that state and district officials reported could not be
addressed by Education, at least half of the state survey respondents
indicated that Education could be more helpful. Specifically, they said
they needed more information on, or assistance with, professional
development programs, best practices related to teacher quality, and
incentives for teachers to teach in high-poverty schools. Education has
identified several steps it will take in its 2002-07 strategic plan
related to these issues.
Title II provided funds to help meet the requirement for highly
qualified teachers, and state survey respondents said they planned to
spend most of their Title II funds on professional development
activities while districts planned to spend the majority of their funds
on recruitment and retention activities authorized under Title II.
Generally, state educational agencies could use up to 2.5 percent of
the state's Title II funds for authorized state activities. State
officials reported they planned to spend 65 percent on professional
development activities. These activities could help teachers enhance
their subject area knowledge and complete state licensing requirements
to meet the criteria for highly qualified teachers. States planned to
spend much larger amounts of other federal and state funds than Title
II funds on authorized state activities. For example, states reported
that 85 percent of the total funds they planned to spend on
professional development activities would come from other federal and
state funds. Districts received about 95 percent of their state's Title
II funds for authorized district activities. From our survey we
estimated that districts planned to spend about two-thirds of their
Title II funds on activities to help recruit and retain highly
qualified teachers, with the remaining funds on activities for
professional development. High-poverty districts planned to spend a
larger percentage of Title II funds on recruitment and retention
activities than low-poverty districts. For example, high-poverty
districts planned to spend 77 percent of their Title II funds for
recruitment and retention while low-poverty districts planned to spend
59 percent. Recruitment and retention activities, such as establishing
incentive pay programs and reducing class sizes, could help attract
more highly qualified teachers to schools. Survey results also show
that districts planned to spend much larger percentages of other
federal, state, and local funds than Title II funds on authorized Title
II activities. For example, an estimated 80 percent of the total funds
all districts planned to spend on professional development came from
other federal, state, and local funds. During our visits, both state
and district officials said that most activities were a continuation of
those begun in previous years.
In order to help states meet the requirement for highly qualified
teachers by the end of the 2005-06 school year, we recommend that the
Secretary of Education provide more information on methods to evaluate
subject area knowledge of current teachers.
Education provided written comments on a draft of this report including
information on the guidance for special education teachers that we
incorporated as appropriate. Additionally, Education indicated that it
plans to take steps to address our recommendation. Our evaluation of
their comments is in the report and Education's comments are in
appendix IV.
Background:
Recently, a body of research has shown that quality teachers are
significant to improving student performance. For example, a 1996 study
by Sanders and Rivers[Footnote 4] examined the effect of teacher
quality on academic achievement and found that children assigned to
effective teachers scored significantly higher in math than children
assigned to ineffective teachers. Research has also shown that many
teachers, especially those in high-poverty and rural districts, were
not certified and lacked knowledge of the subjects they taught. For
example, a report from The Education Trust found that in every subject
area, students in high-poverty schools were more likely than other
students to be taught by teachers without even a minor in the subjects
they teach.[Footnote 5]
States are responsible for developing and administering their education
systems and most have delegated authority for operating schools to
local governments. States and local governments provide most of the
money for public elementary and secondary education. In 2002, Education
reported[Footnote 6] that 49 percent of the revenue for education was
from state sources, 44 percent from local sources, and 7 percent from
federal sources. Therefore, it is mostly state and local funds that are
used to cover most of the major expenses, such as teacher salaries,
school buildings, and transportation. Although the autonomy of
districts varies, states are responsible for monitoring and assisting
their districts that, in turn, monitor and assist their schools.
The federal government plays a limited but important role in education.
The Department of Education's mission is to ensure equal access to
education and promote educational excellence throughout the nation by,
among other things, supporting state and local educational improvement
efforts, gathering statistics and conducting research, and helping to
make education a national priority. Education provides assistance to
help states understand the provisions or requirements of applicable
laws, as well as overseeing and monitoring how states implement them.
With the passage of the No Child Left Behind Act, on January 8, 2002,
the federal government intensified its focus on teacher quality by
establishing a requirement in the act for teachers across the nation to
be "highly qualified" in every core subject they teach by the end of
the 2005-06 school year.[Footnote 7]
While the act contains specific criteria for highly qualified teachers
by grade and experience levels, in general, the act requires that
teachers: (1) have a bachelor's degree, (2) have state certification,
and (3) demonstrate subject area knowledge for each core subject they
teach. Table 1 lists the specific criteria by grade and experience
levels as defined in the act.
Table 1: Federal Criteria for a Highly Qualified Teacher:
Grade level and experience: Any public elementary school or secondary
school teacher; Federal criteria: Has obtained full state
certification as a teacher (including alternative certification) or
passed the state teacher licensing examination and holds a license to
teach in the state; however, when teaching in a charter school,[A] the
teacher may not be certified or licensed if the state does not require
it. Further, the teacher has not had certification or licensure
requirements waived on emergency, temporary, or provisional basis.
Grade level and experience: Elementary school teacher new to the
profession; Federal criteria: Holds at least a bachelor's degree; and
has passed a rigorous state test to demonstrate subject knowledge and
teaching skills in reading, writing, math, and other areas of the basic
elementary school curriculum (these tests may be included in state
certification or licensing tests).
Grade level and experience: Middle or secondary school teacher new to
the profession; Federal criteria: Holds at least a bachelor's degree
and has passed a rigorous state academic subject test in each of the
academic subjects in which the teacher teaches (this may be the state
certification or licensure test) or for each academic subject taught,
the teacher has successfully completed an academic major, a graduate
degree, coursework equivalent to an undergraduate academic major, or
advanced certification or credentialing.
Grade level and experience: Elementary, middle, or secondary teacher
not new to the profession; Federal criteria: Has met the above
standards for new elementary, middle, and secondary school teachers or
demonstrates competence in all the academic subjects in which the
teacher teaches based on a high objective, uniform state standard of
evaluation that (1) is set by the state for both grade appropriate
academic subject matter knowledge and teaching skills; (2) is aligned
with challenging state academic content and student academic
achievement standards and developed in consultation with core content
specialists, teachers, principals, and school administrators; (3)
provides objective, coherent information about the teacher's attainment
of core content knowledge in the academic subjects a teacher teaches;
(4) is applied uniformly to all teachers in the same academic subject
and the same grade level throughout the state; (5) takes into
consideration, but not be based primarily on, the time the teacher has
been teaching in the academic subject; (6) is made available to the
public upon request; and (7) may involve multiple, objective measures
of teacher competency.
Source: NCLBA, Pub.L. No. 107-110, section 9101(2002).
[A] Charter schools are public schools that are exempt from a variety
of local and state regulations.
[End of table]
For Title II, Part A of the act, Congress appropriated $2.85 billion to
the Teacher and Principal Training and Recruiting Fund in fiscal year
2002--about $740 million more than states received in fiscal year 2001
under the previous two programs that it replaced--the Eisenhower
Professional Development and Class Size Reduction programs. The purpose
of the fund is to increase student academic achievement by providing
support for states and districts to implement authorized activities
cited in Title II to help them meet the requirement for highly
qualified teachers. (See apps. II and III for state and district
authorized activities.):
States had to complete an application in order to receive funds. All
applications were due by June 2002, and states received the funds by
August 2002. The funds were to be distributed according to the formula
defined in the act. Specifically, states and districts received an
amount equal to what they received for fiscal year 2001 under the two
previous programs. The additional $740 million was distributed to
states and districts based on the number of families with children ages
5 to 17 who had incomes below the poverty threshold[Footnote 8] and the
relative population of children ages 5 to 17. The act requires states
to ensure that districts target funds to those schools that have the
highest number of teachers who are not highly qualified, the largest
class sizes, or have been identified as in need of improvement.
To help states understand and implement the new law, Education took a
number of actions. The department established a Web site, developed an
application package for the formula grant program, issued draft
guidance, and held informational conferences for states and districts.
Figure 1 summarizes Education's assistance to states.
Figure 1: Education's Assistance to States During Calendar Year 2002:
[See PDF for image]
[End of figure]
In June 2002, Education issued draft guidance entitled "Improving
Teacher Quality State Grants" which has served as Education's principle
form of assistance to states. In December of 2002, Education expanded
and modified the draft guidance and issued final regulations on NCLBA
that included some criteria related to the requirement for highly
qualified teachers. Education does not plan to issue a final version of
its draft guidance; instead, the draft includes the statement that it
"should be viewed as a living document" that will be updated (1) as new
questions arise, (2) if there is a change in the program statute that
requires modification, or (3) when Education determines that more
information would be helpful.
Many States Were Uncertain about Numbers of Highly Qualified Teachers:
In-depth discussions with officials in 8 states revealed that they
could not determine the number of highly qualified teachers with
accuracy because of one or more factors. All state officials said they
did not know the criteria for some of their teachers because
Education's draft guidance changed and was not complete. Officials also
did not have all the information they needed to develop methods to
evaluate subject area knowledge for their current teachers.
Accordingly, officials in all of the states interviewed and nearly all
surveyed said they needed complete and clear guidance before they could
comply with the law. Most of the states we visited also did not have
data systems that could track teacher qualifications by core subject
taught, which they would have to do to ensure that teachers were
teaching only those subjects for which they had demonstrated subject
area knowledge. Finally, many state officials we visited were reluctant
to say that their certified teachers might not be highly qualified.
States Did Not Have Complete or Consistent Criteria to Determine the
Number of Highly Qualified Teachers:
During our review, Education changed its criteria for teachers who were
in alternative certification programs and it reissued the draft
guidance to qualify only teachers in certain programs.[Footnote 9] The
revised draft guidance stated that only those teachers enrolled in
alternative certification programs with specific elements, such as
teacher mentors, would be considered highly qualified. As a result,
state officials had to recount this group of teachers by determining
which alternative certification programs met the standard and then
which teachers participated in those programs. In one state we visited,
there were about 9,000 teachers in alternative certification programs
and all were considered highly qualified until the revised draft
guidance was issued. As of May 2003, an official said she was still
trying to determine the number of teachers who were highly qualified.
Also during our review, state officials were uncertain about the
criteria for special education teachers. The draft guidance that was
available during most of our visits did not address special education
teachers. As a result, state officials could not know, for example,
whether a special education teacher teaching math and reading would
have to demonstrate subject area knowledge in both or neither of the
subjects. For school year 1999-2000, special education teachers
represented about 11 percent of the national teacher
population,[Footnote 10] so that, on average, state officials were
unable to determine whether at least a tenth of their teachers met the
highly qualified criteria. In some districts, special education
teachers represented a larger portion of the workforce. For example, in
one high-poverty urban district that we visited, special education
teachers were 21 percent of their teachers. Education issued final
Title I regulations on December 2, 2002, with an appendix that
discussed the highly qualified requirements for special education
teachers, among other things. However, the requirements are not
discussed in the federal regulations nor are they discussed in the
Title II draft guidance that was issued December 19, 2002. In addition,
as of March 2003 some officials still had questions about the
requirements. Perhaps because the guidance was issued in an appendix,
it was not given the prominence needed to ensure that all officials
would be aware of the information.
Furthermore, neither Education's draft guidance nor its regulations
provided more information than the law to help state officials develop
methods other than tests to evaluate their current teachers' subject
area knowledge. The law allows states to use a "high, objective uniform
state standard of evaluation" instead of a test. Education's draft
guidance repeated the language of the law, but provided no further
interpretation. In addition, Education officials said they would review
states' implementation of this provision when they conduct compliance
reviews and then determine if the state evaluation is in compliance
with the law. State officials said they needed more information, such
as examples, to be confident of what Education would consider adequate
for compliance with the law. State officials prefer evaluations instead
of tests, according to an official at the Council of Chief State School
Officers (CCSSO), because they expect evaluations to be less expensive,
more flexible, and more acceptable to teachers and unions. Such
evaluations might be done through classroom observations, examination
of portfolios, and peer reviews. In March 2003, CCSSO held a conference
attended by about 25 state officials and several Education officials to
discuss the implementation of state evaluations. At that conference,
state officials said Education's lack of specificity was particularly a
problem for evaluating middle and high school teachers who had not
demonstrated subject area knowledge. According to our survey data, 23
of 37 state officials said they would have difficulty fulfilling the
highly qualified requirement for middle school teachers and 14
anticipated difficulty for high school teachers. According to district
survey results, 20 percent anticipated difficulties in meeting the
federal criteria for middle school teachers and 24 percent for high
school teachers. Furthermore, as table 2 shows, a significantly higher
percentage of high-poverty districts reported they would have greater
difficulty fulfilling the requirement for teachers, especially at the
middle and high school levels, than would low-poverty districts.
Table 2: Estimated Percentages of Districts That Will Have Difficulty
Meeting the Requirement for Highly Qualified Teachers by Grade Level
and Poverty:
Type of school: Elementary; All districts: 7; High-poverty districts:
18; Low-poverty districts: 4.
Type of school: Middle/junior high; All districts: 20; High-poverty
districts: 35; Low-poverty districts: 13.
Type of school: High; All districts: 24; High-poverty districts: 46[A];
Low-poverty districts: 15.
Source: GAO survey.
[A] The percentage estimate for high schools in high-poverty districts
has a 95 percent confidence interval of plus or minus 11 percentage
points.
[End of table]
State officials from the 8 states we visited said they could not
determine the number of highly qualified teachers because the draft
guidance was changing, not clear, or incomplete. Most, 32 of 37, state
officials responding to our survey said they needed clear and timely
guidance to help them meet the law.
State Data Systems Did Not Track Federal Criteria:
Officials from 7 of the 8 states we visited told us they did not have
data systems that would allow them to track teachers' qualifications
according to the federal criteria by every subject taught. Officials in
one state projected that it would take at least 2 years before the
state could develop and implement a system to track teachers by the
federal criteria. State officials we visited said since their state
certifications had not required some teachers to demonstrate subject
area knowledge as required in the federal criteria, their information
systems did not track such information. In written comments to our
survey, for example, one official said, "Questions [related to counting
teachers] are impossible to answer at this point because we not have
finished the identification of those who need to be tested or
evaluated." Another respondent wrote that the data system "was designed
years ago for state certification purposes—[and] has not yet been
updated to include all NCLBA criteria for teachers." Other state
officials also told us during our visits and through survey comments
that their state certifications did not always require teachers to
demonstrate subject area knowledge, so they did not have information on
many teachers' qualifications for this criteria. Another state official
wrote, "[We] do not have data on teachers who were grand fathered in
before 1991 or from out of state— who do not have subject matter
competency." Given the cost and time they thought it would take, some
state officials expressed reservations about changing their data
systems before Education provided complete guidance.
Some State Officials Reluctant to Report Teachers Not Highly Qualified:
Officials in 6 of the 8 states visited were reluctant to report their
certified teachers might not be highly qualified. Three of these
officials equated their state certification with the federal criteria
for a highly qualified teacher even though they differed. They
expressed a reluctance to say that their state certification
requirements did not produce a highly qualified teacher even though the
requirements did not match all the federal criteria, such as
demonstration of subject area knowledge. Additionally, state officials
expressed concern about the morale of teachers who are state certified
but who would not meet the federal criteria. They were also concerned
about how teachers and unions would react to testing already certified
teachers. For example, in 5 states we visited officials told us that
the unions in these states objected to the testing of certified
teachers.
State and District Officials Reported Many Conditions as Hindrances to
Meeting the Law:
Many state officials responding to our survey reported that teacher
salary issues and teacher shortages were hindrances. State officials
also identified other conditions such as few programs to support new
teachers, lack of principal leadership, teacher training, and union
agreements. District officials also cited teacher salary and teacher
development issues as conditions that hindered them. Our district
survey also shows that significantly more high-poverty districts
reported some conditions as hindrances than low-poverty districts, and
rural districts officials we visited cited hindrances specific to their
small size and isolated locations. In our state survey, officials
indicated that they needed more information from Education on
professional development programs, best practices, and developing
incentives for teachers to teach in high-poverty schools.
State Officials Cited Several Problems as Hindrances:
Many state officials responding to our survey reported that pay issues
hindered their ability to meet the requirement to have all highly
qualified teachers. These issues included low salaries, lack of
incentive pay programs, and a lack of career ladders for teachers. For
example, 32 of 37 state respondents said low teachers' salaries
compared to other occupations was a hindrance. Officials we visited
said that because of the low salaries it has been more difficult to
recruit and retain some highly qualified teachers, especially math and
science teachers. Several occupations are open to people with a
bachelor's degree in math and science, such as computer scientists and
geologists. During the late 1990s, there was an increase in demand for
workers with math and science backgrounds, especially in information
technology occupations. Between 1994 and 2001, the number of workers
employed in the mathematical and computer sciences increased by about
77 percent while the number of teachers increased by about 28 percent
and total employment increased by about 14 percent. Furthermore, the
math and science occupations have generally paid higher salaries than
teaching positions. The U.S. Department of Labor's Bureau of Labor
Statistics data indicate that in 2001 average weekly earnings was
$1,074 for mathematical and computer scientist positions and $730 for
teachers. Some research shows that teacher salary is only one of many
factors that influence teacher recruitment and retention. For example,
the American Association of School Administrators explained the
relationship between pay and working conditions in a report on higher
pay in hard-to-staff schools.[Footnote 11] The report stated "How money
matters becomes much clearer if salary is viewed as just one of many
factors that employees weigh when assessing the relative attractiveness
of any particular job, such as opportunities for advancement,
difficulty of the job, physical working conditions, length of commute,
flexibility of working hours, and demands on personal time. Adjusting
the salaries upward can compensate for less appealing aspects of a job;
conversely, improving the relative attractiveness of jobs can
compensate for lower salaries.":
Many state survey respondents also cited teacher shortages as a
hindrance. Specifically, 23 of the 37 state officials reported teacher
shortages in high-need subject areas--such as, math, science, and
special education.[Footnote 12] Additionally, 12 state officials
reported a shortage in the number of new highly qualified teachers in
subject areas that are not high need, and 12 reported that having few
alternative certification programs hindered their efforts. Education
experts have debated the causes and effects of teacher shortages. Some
experts argue that the problem is not in the number of teachers in the
pool of applicants but in their distribution across the country. Others
argue that poor retention is the real cause of teacher shortages. As
for alternative certification programs, they were established to help
overcome teacher shortages by offering other avenues for people to
enter the teaching profession. However, in 1 state we visited officials
said the success of these programs had been mixed because the content
and length of the programs varied and some alternative certification
teachers were better prepared than others.
Although states have been facing teacher shortages in some subject
areas for years, the new requirement for highly qualified teachers
could make it even more difficult to fulfill the demand for teachers.
The new law requires states to ensure that teachers only teach subjects
for which they have taken a rigorous state test or evaluation,
completed an academic major or graduate degree, finished course work
equivalent to such degrees, or obtained advanced certification or
credentialing in the subjects. Previously, states allowed teachers to
teach subjects without such course work or credentials. From its
Schools and Staffing Survey,[Footnote 13] the National Center for
Education Statistics, within the Department of Education, reported that
in 1999-2000, 14 to 22 percent of students in middle grades and 5 to 10
percent of high school students taking English, math, and science were
in classes taught by teachers without a major, minor, or certification
in the subjects they taught. Also, the report indicated that in the
high school grades, 17 percent of students enrolled in physics and 36
percent enrolled in geology/earth/space science classes were taught by
out-of-field teachers.
Some states also cited several other conditions that might hinder their
ability to meet the requirement for highly qualified teachers. For
example, 13 of the 37 state respondents reported few programs to
support new teachers,[Footnote 14] and 9 reported large classes as
hindrances. State respondents also cited work environment factors such
as teacher performance assessments, a lack of principal leadership, and
lack of school supplies and equipment as hindrances. See table 3 for
more information on hindrances reported by state officials.
Additionally, 7 state officials who responded to our survey cited union
agreements as a hindrance. Officials in 5 states that we visited said
that the teachers' unions objected to testing currently certified
teachers for subject area knowledge, and officials in 2 of these states
also said that current teachers might leave rather than take a test. An
official representing the American Federation of Teachers (AFT), an
organization that represents teachers, school support staff, higher
education faculty and staff, among others, said that AFT supports the
federal definition for highly qualified teachers and incentive pay for
teachers in high-need subject areas and that certified teachers should
have a choice between taking a test and having a state evaluation to
determine subject area knowledge. The National Education Association,
an organization with members who work at every level of education,
issued an analysis of the NCLBA that identified several changes it
believes should be made in the law, including clarifying the
requirement for highly qualified teachers. The union officials we spoke
with from 2 states we visited said they also support the requirement
for highly qualified teachers but expressed concerns about how their
states would implement the legislation. One state union official said
the current state process for certification requires multiple tests--
more than is required in the legislation--and the union is concerned
that the state will collapse the testing and streamline the teacher
preparation process as part of its changes to meet the requirement. The
union official from the other state said that his union was concerned
because the state's approach for implementing the requirement for
highly qualified teachers has become a moving target and this causes
frustration for teachers.
Table 3: Number of States Reporting on Conditions That Hinder Their
Ability to Meet the Requirement for Highly Qualified Teachers (Ranked
from Highest to Lowest):
Number of states reporting this condition to be a hindrance[A] (n=37):
32; Condition: Teachers' salaries low compared to other occupations.
Number of states reporting this condition to be a hindrance[A] (n=37):
23; Condition: Shortage in the number of teachers who meet the Title II
requirement for highly qualified teachers in subject areas where there
is high need.
Number of states reporting this condition to be a hindrance[A] (n=37):
21; Condition: Teachers' salaries low compared to teachers elsewhere.
Number of states reporting this condition to be a hindrance[A] (n=37):
18; Condition: Lack of incentive pay programs.
Number of states reporting this condition to be a hindrance[A] (n=37):
17; Condition: Lack of a career ladder for teachers.
Number of states reporting this condition to be a hindrance[A] (n=37):
14; Condition: Professional development programs not of sufficient
duration to have an effect on teacher quality.
Number of states reporting this condition to be a hindrance[A] (n=37):
13; Condition: Few programs to support new teachers.
Number of states reporting this condition to be a hindrance[A] (n=37):
12; Condition: Few alternative certification programs.
Number of states reporting this condition to be a hindrance[A] (n=37):
12; Condition: Shortage in the number of new teachers who meet the
Title II requirement for highly qualified teachers in subject areas
that are not high need.
Number of states reporting this condition to be a hindrance[A] (n=37):
12; Condition: School lacks supplies and equipment.
Number of states reporting this condition to be a hindrance[A] (n=37):
11; Condition: Lack of leadership on the part of principals.
Number of states reporting this condition to be a hindrance[A] (n=37):
9; Condition: College of Arts and Science Departments do not work with
college Education Departments to develop teacher preparation programs.
Number of states reporting this condition to be a hindrance[A] (n=37):
9; Condition: Large class sizes resulting in teacher retention
problems.
Number of states reporting this condition to be a hindrance[A] (n=37):
9; Condition: Many currently employed teachers do not meet the Title II
requirement for highly qualified teachers in areas that are not high
need.
Number of states reporting this condition to be a hindrance[A] (n=37):
7; Condition: Teacher assessments not based on the Title II requirement
for highly qualified teachers.
Number of states reporting this condition to be a hindrance[A] (n=37):
7; Condition: Weak training for teachers in the use of technology.
Number of states reporting this condition to be a hindrance[A] (n=37):
7; Condition: Union agreements inhibit implementing activities
encouraged by Title II to develop highly qualified teachers.
Number of states reporting this condition to be a hindrance[A] (n=37):
7; Condition: Professional development programs not based on recent
scientific research on teaching methods or subject matter.
Number of states reporting this condition to be a hindrance[A] (n=37):
4; Condition: State certification requirements not meeting the Title II
requirement for highly qualified teachers.
Number of states reporting this condition to be a hindrance[A] (n=37):
3; Condition: Alternative certification programs not providing teachers
with adequate teaching skills.
Number of states reporting this condition to be a hindrance[A] (n=37):
3; Condition: Teacher preparation programs not aligned with state
subject content standards.
Number of states reporting this condition to be a hindrance[A] (n=37):
3; Condition: State and local laws and regulations inhibit implementing
activities encouraged by Title II to develop highly qualified
teachers.
Number of states reporting this condition to be a hindrance[A] (n=37):
2; Condition: Teacher preparation programs not providing teachers with
adequate subject matter expertise.
Source: GAO survey.
[A] These numbers include states that reported these conditions as a
moderate, great, or very great hindrance.
[End of table]
School Districts Reported Hindrances Similar to Those Reported by
States and More High-Poverty Districts Reported Certain Hindrances:
School district estimates from our survey show that, similar to state
respondents, salary issues hinder districts' efforts to meet the
requirement for highly qualified teachers. Almost 60 percent of
district officials cited low teacher salaries compared to other
occupations as a hindrance, with a significantly higher number of high-
poverty than low-poverty district officials reporting this as a
hindrance. During our site visits to 4 rural districts, officials said
that their salaries could not compete with salaries offered in other
occupations and locations. One official said that pay in the rural
districts was low compared to teacher salaries in surrounding states.
Both state and district officials also said that these salary
conditions affect the recruitment and retention of highly qualified
teachers.
Our survey estimates also show that conditions related to teacher
development were hindering districts' ability to meet the highly
qualified teacher requirement. The conditions reported by districts
included (1) weak training for teachers in the use of technology (28
percent), (2) few alternative certification programs (18 percent), and
(3) professional development programs that are not of sufficient
duration to improve teacher quality (23 percent). Weak training
programs can leave teachers unprepared to deal with all the challenges
of teaching and lead to job dissatisfaction. Table 4 provides estimates
of the percentages of districts reporting conditions that hinder their
ability to meet the requirement for highly qualified teachers.
Table 4: Estimated Percentages of Districts Reporting on Conditions
That Hinder Their Ability to Meet the Requirement for Highly Qualified
Teachers (Ranked from Highest to Lowest):
Percent of all districts reporting this condition to be a hindrance[A]:
57; Condition: Teachers' salaries low compared to other occupations.
Percent of all districts reporting this condition to be a hindrance[A]:
37; Condition: Teachers' salaries low compared to teachers elsewhere.
Percent of all districts reporting this condition to be a hindrance[A]:
28; Condition: Training for teachers in the use of technology is weak.
Percent of all districts reporting this condition to be a hindrance[A]:
25; Condition: Lack of incentive pay programs.
Percent of all districts reporting this condition to be a hindrance[A]:
23; Condition: Professional development programs not of sufficient
duration to have an effect on teacher quality.
Percent of all districts reporting this condition to be a hindrance[A]:
19; Condition: Shortage in the number of teachers who meet the Title II
requirement for highly qualified teachers in subject areas where there
is high need.
Percent of all districts reporting this condition to be a hindrance[A]:
18; Condition: Teacher preparation programs not providing teachers with
adequate subject matter expertise.
Percent of all districts reporting this condition to be a hindrance[A]:
18; Condition: Few alternative certification programs.
Percent of all districts reporting this condition to be a hindrance[A]:
17; Condition: College of Arts and Science Departments not working with
college Education Departments to develop teacher preparation programs.
Percent of all districts reporting this condition to be a hindrance[A]:
16; Condition: Alternative certification programs not providing
teachers with adequate teaching skills.
Percent of all districts reporting this condition to be a hindrance[A]:
16; Condition: Few programs to support new teachers.
Percent of all districts reporting this condition to be a hindrance[A]:
16; Condition: Lack of a career ladder for teachers.
Percent of all districts reporting this condition to be a hindrance[A]:
16; Condition: Shortage in the number of new teachers who meet the
Title II requirement for highly qualified teachers in low achieving
schools.
Percent of all districts reporting this condition to be a hindrance[A]:
15; Condition: Teacher preparation programs not aligned with state
subject content standards.
Percent of all districts reporting this condition to be a hindrance[A]:
14; Condition: School lacks supplies and equipment.
Percent of all districts reporting this condition to be a hindrance[A]:
12; Condition: Teacher assessments not based on the Title II
requirement for highly qualified teachers.
Percent of all districts reporting this condition to be a hindrance[A]:
10; Condition: Union agreements that inhibit implementing activities
encouraged by Title II to develop highly qualified teachers.
Percent of all districts reporting this condition to be a hindrance[A]:
7; Condition: Lack of leadership on the part of principals.
Percent of all districts reporting this condition to be a hindrance[A]:
7; Condition: Large class sizes resulting in teacher retention
problems.
Percent of all districts reporting this condition to be a hindrance[A]:
7; Condition: Professional development programs not based on recent
scientific research on teaching methods or subject matter.
Percent of all districts reporting this condition to be a hindrance[A]:
7; Condition: State certification requirements not meeting the Title II
requirement for highly qualified teachers.
Percent of all districts reporting this condition to be a hindrance[A]:
6; Condition: Many currently employed teachers not meeting the Title II
requirement for highly qualified teachers in areas that are not high
need.
Percent of all districts reporting this condition to be a hindrance[A]:
4; Condition: State and local laws and regulations inhibit implementing
activities encouraged by Title II to develop highly qualified
teachers.
Source: GAO survey.
[A] These percentages include districts that reported these conditions
as a moderate, great, or very great hindrance.
[End of table]
While the ranking of most of the hindrances reported by districts and
states were similar, three conditions were reported among the top third
of hindrances for districts but among the bottom third for states.
Specifically, these conditions were (1) alternative certification
programs do not provide teachers with adequate teaching skills, (2)
teacher preparation programs do not provide teachers with adequate
subject matter expertise, and (3) training for teachers in the use of
technology is weak. The first two of these conditions relate to
programs that are usually responsibilities of the state departments of
education. States or districts can address the third condition,
technology training. These conditions indicate areas in which states
and districts can work together to improve programs and help meet the
requirement for highly qualified teachers.
A significantly higher number of high-poverty districts than low-
poverty districts identified some conditions as hindrances. As table 5
shows, in addition to teacher shortages and pay issues, a larger
percentage of high-poverty districts cited few programs to support new
teachers and few alternative certification programs, among others, as
hindrances to meeting the requirement.
Table 5: Estimated Percentages of High-and Low-Poverty Districts with
Significant Differences in the Hindrances to Meeting the Requirement:
Condition: Teachers' salaries are low compared to other occupations;
Percent of high-poverty districts: 75; Percent of low-poverty
districts: 50.
Condition: Teachers' salaries are low compared to teachers elsewhere;
Percent of high-poverty districts: 57; Percent of low-poverty
districts: 33.
Condition: Lack of incentive pay programs; Percent of high-poverty
districts: 32; Percent of low-poverty districts: 17.
Condition: Few programs to support new teachers; Percent of high-
poverty districts: 30; Percent of low-poverty districts: 6.
Condition: Shortage in the number of teachers who meet the Title II
requirement for highly qualified teachers in subject areas where there
is a high need; Percent of high-poverty districts: 29; Percent of low-
poverty districts: 13.
Condition: Shortage in the number of new teachers who meet the Title II
requirement in low achieving schools; Percent of high-poverty
districts: 26; Percent of low-poverty districts: 10.
Condition: Lack of career ladder for teachers; Percent of high-poverty
districts: 25; Percent of low-poverty districts: 8.
Condition: Few alternative certification programs; Percent of high-
poverty districts: 24; Percent of low-poverty districts: 11.
Condition: Teacher preparation programs do not provide adequate subject
matter expertise; Percent of high-poverty districts: 24; Percent of
low-poverty districts: 13.
Condition: Many currently employed teachers do no meet the Title II
requirement in areas that are not high need; Percent of high-poverty
districts: 13; Percent of low-poverty districts: 4.
Condition: Large class sizes resulting in teacher retention problems;
Percent of high-poverty districts: 12; Percent of low-poverty
districts: 4.
Condition: Lack of leadership on the part of principals; Percent of
high-poverty districts: 12; Percent of low-poverty districts: 3.
Source: GAO survey.
Note: Each difference between high-and low-poverty districts in this
table is significant at the 95 percent confidence interval.
[End of table]
During our site visits, officials from high-poverty districts told us
they had great difficulty retaining teachers. For example, officials in
one district said that although the district provided training for new
teachers in the skills they needed, these teachers became more
marketable after they completed the training and often left for higher
paying teaching positions. According to these officials, the schools in
this district did not always benefit from the district's training
programs. High-poverty district officials also said they could not
compete with surrounding, wealthier districts in teacher pay. Officials
in these districts and at the American Association of School
Administrators also said that some unions do not support the use of
incentive pay for high-poverty schools because they believe that salary
scales should be equal for all schools within a district.
Rural district officials we visited and also those who provided survey
comments said they faced unusual hindrances because some of them were
very small, isolated, or had only one or two teachers in total at some
schools. During our site visits, some officials from rural districts
also said that they were facing teacher shortages because not enough
teachers were willing to teach in rural districts. For example, one
official in a large, rural state said that the state had only one
university, which makes it difficult for teachers to obtain further
course work to meet the federal criteria for subject area knowledge.
Since many teachers in this state's rural districts had to teach more
than one core subject, with limited access to subject area training,
they may not meet the highly qualified criteria for all subjects they
teach. One survey respondent also wrote, "Rural schools have to assign
teachers to several subject areas at [the] secondary level. We do not
have large numbers of students, and teachers have to wear more than one
hat. Rural schools are also a long way from colleges and to require
licensure in every subject they teach is ludicrous." In a 2001 report
to Congress, Education estimated that 84 percent of 4-year institutions
would offer distance education courses[Footnote 15] in 2002. Such
courses may help address this hindrance.
States Say They Need More Information from Education and Education
Plans to Work with States on Some Issues:
As districts work to address the conditions that affect their ability
to meet the new federal requirement, they look to their state officials
for guidance and technical assistance. In turn, states look to
Education for help. Many of the hindrances that state and district
officials reported related to conditions that they could address such
as teachers' salaries, the number of alternative certification
programs, and certification requirements. However, states indicated
they needed some additional information and assistance from Education.
At least half of the 37 state respondents reported needing (1)
information or other assistance to meet the requirement that
professional development programs be based on recent scientific
research and be of sufficient duration to have an effect on teacher
quality, (2) information on best practices in the area of teacher
quality, and (3) assistance in developing incentives for teachers to
teach in high-poverty schools. Education's 2002-07 strategic plan
identifies several steps it will take to work with states.
Specifically, the strategies listed under the plan's goal for improving
teacher and principal quality include supporting professional
development in research-based instruction and encouraging innovative
teacher compensation and accountability systems. Additionally, in
December 2002, Education reorganized and established a new office to
administer the Title II program.
To Help Teachers Meet the Requirement States Planned to Spend Most
Title II Funds on Professional Development Activities, and Districts
Will Spend Most on Recruitment and Retention Activities:
To help meet the requirement for highly qualified teachers, state
officials planned to spend most of their Title II funds on professional
development activities, and district officials planned to spend a
majority of their Title II funds on recruitment and retention
activities. State and district officials planned to spend much larger
amounts of other federal,[Footnote 16] state, and local funds than
Title II funds on the activities authorized in the act. Generally,
state and district officials told us they were continuing activities
from previous years. The survey data also indicated high-poverty
districts relied more on Title II funds for recruitment and retention
activities than low-poverty districts. In addition, while the act
requires districts to target their Title II funds to schools that meet
certain criteria, until district officials know the number of highly
qualified teachers and where they are located, they cannot fully comply
with this requirement.
States Planned to Spend the Majority of Title II Funds on Professional
Development:
Generally, state educational agencies could use up to 2.5 percent of
the state's Title II funds for authorized state activities.[Footnote
17] Twenty-four state officials responding to our survey planned to
spend about 65 percent of their Title II funds on professional
development activities to develop and support highly qualified teachers
and principals. For example, professional development activities could
help teachers enhance their subject area knowledge and complete state
licensing requirements to meet the criteria for highly qualified
teachers. During our site visits, state officials described their
professional development activities as seminars, conferences, and
various instructional initiatives. For example, in one state we
visited, officials planned to hold a workshop to provide middle and
high school math teachers with technology training so that they could
incorporate interactive Web sites in their instruction. Generally,
state officials said they planned to use Title II funds to continue
activities that were begun in previous years.
While professional development activities were to receive the largest
share of funds, survey results show state officials planned to also
spend Title II funds on other activities cited in the act. Officials in
28 states planned to spend about 18 percent on technical assistance
activities, such as providing information about the requirement for
highly qualified teachers to districts via the state Web site.
Certification activities received the smallest percentage of Title II
funds-2 percent. These activities include efforts to promote
certification reciprocity with other states and efforts to establish,
expand, or improve alternative routes for certification. (See fig. 2.):
Figure 2: Planned Spending of Title II Funds by Reporting States:
[See PDF for image]
[End of figure]
Title II Funds Are a Small Part of Total Funds:
State officials reported they planned to spend much larger amounts of
other federal and state funds than Title II funds on nearly all of the
authorized Title II activities. For example, states reported that 85
percent of the total funds they planned to spend on professional
development activities would come from other federal and state funds.
The one exception was technical assistance activities, where Title II
funds accounted for 77 percent of the total. (See fig. 3.) Providing
technical assistance to districts is an important role for states. In
our visits to districts, several officials said they needed more
information and technical assistance from their state to understand and
implement the law.
Figure 3: Sources of Funds for Planned Spending by States on Title II
Activities:
[See PDF for image]
[End of figure]
Districts Planned to Spend a Majority of Their Title II Funds on
Recruitment and Retention Activities:
Districts received about 95 percent of their state's Title II funds for
authorized activities.[Footnote 18] Based on our survey, district
officials planned to spend an estimated 66 percent of their Title II
funds on recruitment and retention activities and 34 percent on
activities related to professional development. Class size reduction
activities were the largest funded recruitment and retention activity
and accounted for 56 percent of total Title II funds. In a majority of
our site visits we learned that district officials used these funds to
hire additional highly qualified teachers to continue activities
developed under the previous Class Size Reduction Program. Class size
reduction activities may help improve teacher retention because,
according to an Education report,[Footnote 19] teachers in small
classes spend less time on classroom management and more time providing
instruction, thus raising the teacher's level of job satisfaction.
While class size reduction activities can be seen as a retention tool,
they may also increase the number of highly qualified teachers that
need to be hired. This may be a problem for some districts and states.
In fact, officials in one large state we visited said class size
reduction activities presented a challenge by increasing the number of
classes not being taught by a highly qualified teacher.
Additionally, district officials in our site visits said that they
implemented or planned to implement a broad range of professional
development activities. For example, one district had a teacher-coach
program for its math and science teachers. This program used senior
teachers as full-time coaches to assist less experienced teachers with
instructional strategies and curriculum preparation. Other programs
focused on math and reading, varied instructional strategies for
different types of students, and use of technology. District officials
in our site visits said most activities were in place prior to the act.
While all districts spent more on recruitment and retention activities
than professional development, there were differences between high-and
low-poverty districts. From our survey, we estimate that high-poverty
districts planned to spend a significantly larger percentage of Title
II funds on recruitment and retention and a smaller percentage on
professional development activities than low-poverty districts. (See
table 6.):
Table 6: Estimated Percent of Spending Title II Funds by Activities for
All Districts, High-Poverty Districts, and Low-Poverty Districts:
Activity: Professional development activities; All districts: 34; All
high-poverty districts: 23; All low-poverty districts: 41.
Activity: Recruitment and retention/class size reduction; All
districts: 66; All high-poverty districts: 77; All low-poverty
districts: 59.
Source: GAO survey.
Note: Each difference between high-and low-poverty districts in this
table is significant at the 95 percent confidence interval.
[End of table]
Districts Planned to Spend Larger Amounts of Other Funds and Title II
Funds Are a Larger Percentage of Total for High-Poverty Districts:
From our survey, we estimated all districts planned to spend much
larger percentages of other federal, state, and local funds than Title
II funds on authorized activities but in high-poverty districts the
share of the funds was lower. Overall, 80 percent of the total funds
districts planned to spend on professional development activities came
from other federal, state, and local funds. Title II funds represented
a larger percentage of total funds spent on authorized activities for
high-poverty districts than low-poverty districts. For example, in
high-poverty districts Title II funds were 48 percent of the funds they
planned to spend for recruitment and retention activities compared to
15 percent in low-poverty districts. There may be several reasons for
these differences. For example, Title II allocated more funds to those
districts with more high-poverty families, and low-poverty districts
may have had more local funds to contribute to the total. Figure 4
shows the Title II percentage of total funds for professional
development activities and recruitment and retention activities, for
all, high-poverty, and low-poverty districts. A majority of district
officials said they planned to fund activities that were begun in
previous years.
Figure 4: Estimated Spending of Title II Funds as a Percentage of Total
Funds by Activities for All Districts, High-Poverty Districts, and Low-
Poverty Districts:
[See PDF for image]
[End of figure]
Approximately One-Third of All Districts Were Targeting Funds:
We estimated about one-third of all districts (34 percent) were
targeting their Title II funds as required by the act. The act requires
districts to target funds to those schools (1) with the highest number
of teachers who are not highly qualified, (2) with the largest class
sizes, or (3) in need of improvement. There was little difference
between the percentages of high-and low-poverty districts that targeted
their funds or between urban and rural districts. For example, 29
percent of high-poverty districts and 30 percent of low-poverty
districts reported targeting some of their Title II funds.
Additionally, some district officials we visited said they did not
target funds according to the criteria listed in the act but that they
targeted funds in other ways such as to support math and science
programs for teachers and for administrative leadership programs. It
may be too early for district officials to fully implement this
targeting requirement. Until they know the true number of teachers who
are highly qualified, they cannot target the schools with the highest
numbers of teachers who are not highly qualified.
Conclusions:
Education officials have had to interpret and help states implement
many new requirements established by the NCLBA, including the highly
qualified teacher requirement. During this first year of
implementation, state officials were still determining how they could
assess whether their teachers met all the criteria and identifying
steps they needed to take to meet the new requirement. Generally, state
and district officials continued to be challenged by many longstanding
hindrances and they continued to fund activities from previous years.
Education issued regulations and draft guidance to help states begin to
implement the requirement for highly qualified teachers and has plans
to help states with some of their challenges. However, state officials
need more assistance from Education, especially about methods to
evaluate current teachers' subject area knowledge. Without this
information state officials are unsure how to assess whether their
current teachers meet the highly qualified requirement. This would also
help them accurately determine the number of teachers who are highly
qualified and take appropriate steps, such as deciding on which
activities to spend Title II funds and targeting Title II funds to
schools with the highest numbers of teachers who are not highly
qualified. It is important that states have the information they need
as soon as possible in order to take all necessary actions to ensure
that all teachers are highly qualified by the 2005-06 deadline.
Recommendation for Executive Action:
In order to assist states' efforts to determine the number of highly
qualified teachers they have and the actions they need to take to meet
the requirement for highly qualified teachers by the end of the 2005-06
school year, we recommend that the Secretary of Education provide more
information to states. Specifically, information is needed about
methods to evaluate subject area knowledge of current teachers.
Agency Comments and Our Evaluation:
We received written comments on a draft of this report from Education.
These comments are reprinted in appendix IV. In response to our
recommendation related to requirements for special education teachers,
Education stated that the appendix of the Title I Final Regulations
clarifies how the highly qualified requirements apply to special
education teachers. Consequently, we modified the report to reflect
this information and we withdrew this recommendation.
Education indicated it plans to take steps to address our
recommendation on the need for information about methods to evaluate
subject area knowledge of current teachers. Education stated that it
will continue to work with state officials and will actively share
promising strategies and models for "high objective uniform State
standard of evaluation" with states to help them develop ways for
teachers to demonstrate subject area competency.
Also, Education commented that it views a "one-size fits all" approach
to addressing many of the issues raised in the report as undesirable
because states and districts will have to meet the requirement highly
qualified teachers in a manner that is compatible with their teacher
certification, assessment and data collection processes. Education
stated that it will provide assistance wherever possible to help states
meet the requirement. We generally agree that this is an appropriate
approach.
Additionally, Education provided technical comments and we made changes
as appropriate.
We are sending copies of this report to appropriate congressional
committees, the Secretary of Education, and other interested parties.
Copies will be made available to other interested parties upon request.
In addition, the report will be available at no charge on GAO's Web
site at http://www.gao.gov. If you have any questions about this
report, please call me at (202) 512-7215. Key contributors are listed
in appendix V.
Marnie S. Shaul,
Director
Education, Workforce, and Income Security Issues:
Signed by Marnie S. Shaul:
[End of section]
Appendix I: Scope and Methodology:
In conducting our work, we administered a Web survey to the 50 states
and the District of Columbia, and a separate Web survey to a nationally
representative sample of 830 school districts, that included strata for
high-poverty, low-poverty, rural, and urban districts. The response
rate for the state survey was 71 percent and for the district survey 62
percent. The surveys were conducted between December 4, 2002, and April
4, 2003. We analyzed the survey data and identified significant
results. See figure 5 for a geographic display of responding and
nonresponding states.
Figure 5: State Survey Respondents:
[See PDF for image]
[End of figure]
The study population for the district survey consisted of public school
districts contained in the Department of Education's Core of Common
Data (CCD) Local Education Agency (LEA) file for the 2000-2001 school
year. From this, we identified a population of 14,503 school districts
in the 50 states and the District of Columbia.
Sample Design. The sample design for this survey was a stratified
sample of 830 LEAs in the study population. This sample included the
100 largest districts and a stratified sample of the remaining
districts with strata defined by community type[Footnote 20] (city,
urban, and rural) and by the district's poverty level.[Footnote 21]
Table 7 summarizes the population, sample sizes, and response rates by
stratum.
Table 7: Population and Sample by Stratum:
Stratum number: 1; Description: Largest 100 districts; Districts in
population: 100; Districts in sample: 100; Districts responding: 64;
Response rate: 64%.
Stratum number: 2; Description: City, low poverty; Districts in
population: 648; Districts in sample: 120; Districts responding: 76;
Response rate: 63%.
Stratum number: 3; Description: City, high poverty; Districts in
population: 210; Districts in sample: 94; Districts responding: 35;
Response rate: 37%.
Stratum number: 4; Description: Urban, low poverty; Districts in
population: 5,264; Districts in sample: 135; Districts responding: 87;
Response rate: 64%.
Stratum number: 5; Description: Urban, high poverty; Districts in
population: 648; Districts in sample: 120; Districts responding: 79;
Response rate: 66%.
Stratum number: 6; Description: Rural, low poverty; Districts in
population: 6,515; Districts in sample: 135; Districts responding: 87;
Response rate: 64%.
Stratum number: 7; Description: Rural, high poverty; Districts in
population: 1,118; Districts in sample: 126; Districts responding: 83;
Response rate: 66%.
Total; Districts in
population: Districts in population: 14,503; Districts in
sample: Districts in sample: 830; Districts responding:
Districts responding: 511; Response rate: Response rate: 62%.
Source: GAO analysis of Education's 2000-1 CCD data:
[End of table]
Estimates. All estimates produced from the district sample in this
report are for a target population defined as all public school
districts in the 50 states and the District of Columbia for the 2002-03
school year. Estimates to this target population were formed by
weighting the survey data to account for both the sample design and the
response rates for each stratum. For our estimates of high-and low-
poverty districts, we defined high-poverty districts as those with
participation rates in the free and reduced meals program of 70 percent
or above. Low-poverty districts were defined as those with free and
reduced meals program rates at 30 percent and below. One of the
advantages of this approach was that it allowed for a sufficient number
of cases in each category to conduct statistical analyses.
Sampling Error. Because we surveyed a sample of school districts, our
results are estimates of a population of school districts and thus are
subject to sampling errors that are associated with samples of this
size and type. Our confidence in the precision of the results from this
sample is expressed in 95 percent confidence intervals. The 95 percent
confidence intervals are expected to include the actual results for 95
percent of the samples of this type. We calculated confidence intervals
for our study results using methods that are appropriate for a
stratified, probability sample. For the percentages presented in this
report, we are 95 percent confident that the results we would have
obtained if we had studied the entire study population are within plus
or minus 10 percentage points of our results, unless otherwise noted.
For example, we estimate that 34 percent of the districts target at
least some funds to specific types of schools. The 95 percent
confidence interval for this estimate would be no wider than plus or
minus 10 percent, or from 24 percent to 44 percent.
Nonsampling Error. In addition to these sampling errors, the practical
difficulties in conducting surveys of this type may introduce other
types of errors, commonly referred to as nonsampling errors. For
example, questions may be misinterpreted, the respondents' answers may
differ from those of districts that did not respond, or errors could be
made in keying questionnaire data. We took several steps to reduce
these errors.
To minimize some of these errors, the state and district questionnaires
were each pretested three times to ensure that respondents would
understand the questions and that answers could be provided. To
increase the response rate, sampled districts received two calls
encouraging them to complete and return the questionnaire.
We also performed an analysis to determine whether some sample-based
estimates compared favorably with known population values.[Footnote 22]
We performed this analysis for 12 estimates providing information on
students, teachers, number of schools, and administrators that covered
major segments those groups. For example, we did an analysis on all
full-time equivalent classroom teachers but not on teachers of ungraded
students, which is a very small proportion of all teachers. We used
these values for the 511 sample respondents to produce sample estimates
to the total population of all 14,503 districts. These estimated
values, their associated 95 percent confidence intervals, and their
true population values are presented in table 8.
Table 8: Sample Estimates Compared to Population Values:
Description of estimate: Students with Individualized Education
Programs; Mean per district estimated from survey respondents: 455.6;
Lower bound of 95 percent confidence interval: 391.8; Upper bound: of
95 percent confidence interval: 519.5; Mean per district for
population: 424.8.
Description of estimate: Full-time equivalent classroom teachers; Mean
per district estimated from survey respondents: 186.0; Lower bound of
95 percent confidence interval: 157.8; Upper bound: of 95 percent
confidence interval: 214.2; Mean per district for population: 180.8.
Description of estimate: Students in Pre-Kindergarten to 12th grade;
Mean per district estimated from survey respondents: 3,306.8; Lower
bound of 95 percent confidence interval: 2,851.2; Upper bound: of 95
percent confidence interval: 3,762.3; Mean per district for population:
3,168.1.
Description of estimate: Total diploma recipients; Mean per district
estimated from survey respondents: 198.5; Lower bound of 95 percent
confidence interval: 169; Upper bound: of 95 percent confidence
interval: 227.9; Mean per district for population: 201.4.
Description of estimate: Limited English proficient students; Mean per
district estimated from survey respondents: 268.9; Lower bound of 95
percent confidence interval: 210.5; Upper bound: of 95 percent
confidence interval: 327.3; Mean per district for population: 340.9.
Description of estimate: Schools in district; Mean per district
estimated from survey respondents: 6.7; Lower bound of 95 percent
confidence interval: 5.9; Upper bound: of 95 percent confidence
interval: 7.5; Mean per district for population: 6.2.
Description of estimate: Local Education Authority administrators; Mean
per district estimated from survey respondents: 4.2; Lower bound of 95
percent confidence interval: 3.6; Upper bound: of 95 percent confidence
interval: 4.8; Mean per district for population: 3.7.
Description of estimate: LEA support staff; Mean per district estimated
from survey respondents: 11.8; Lower bound of 95 percent confidence
interval: 9.8; Upper bound: of 95 percent confidence interval: 13.9;
Mean per district for population: 10.9.
Description of estimate: School administrators; Mean per district
estimated from survey respondents: 10.4; Lower bound of 95 percent
confidence interval: 8.9; Upper bound: of 95 percent confidence
interval: 11.9; Mean per district for population: 9.7.
Description of estimate: School administrative support staff; Mean per
district estimated from survey respondents: 17.3; Lower bound of 95
percent confidence interval: 14.6; Upper bound: of 95 percent
confidence interval: 19.9; Mean per district for population: 16.5.
Description of estimate: Student support services staff; Mean per
district estimated from survey respondents: 10.8; Lower bound of 95
percent confidence interval: 9.3; Upper bound: of 95 percent confidence
interval: 12.2; Mean per district for population: 10.6.
Description of estimate: Instructional coordinators and supervisors;
Mean per district estimated from survey respondents: 2.9; Lower bound
of 95 percent confidence interval: 2.2; Upper bound: of 95 percent
confidence interval: 3.6; Mean per district for population: 2.5.
Source: GAO analysis of Education's 2000-1 CCD data:
Note: LEAs are also known as school districts.
[End of table]
For 11 out of the 12 estimates we examined, the population value falls
within the 95 percent confidence interval for the estimate, thus
providing some indication that respondents to this survey reflect the
12 characteristics we examined in the population. Although these
characteristics were selected because they might be related to other
characteristics of district teachers and district administration, we do
not know the extent to which the survey respondents would reflect the
population characteristics for the specific questions asked on our
survey. For example, we are not certain whether districts responding to
the survey were further along in the implementation of Title II
requirements than the districts that did not respond.
Our sample was not designed to produce geographical area estimates, and
we did not explicitly stratify our sample by state or region. However,
our sample was selected nationally and all regions are represented in
our sample. The following table summarizes sample size and responses
for 10 regions.
Table 9: Population and Sample by Region:
Region number: 1; State in each region: CT, ME, MA, NH, RI, and VT;
Districts in population: 1,079; Districts in sample: 42; Districts
responding: 25.
Region number: 2; State in each region: NY and NJ; Districts in
population: 1,281; Districts in sample: 49; Districts responding: 27.
Region number: 3; State in each region: DE, DC, MD, PA, VA, and WV;
Districts in population: 731; Districts in sample: 41; Districts
responding: 26.
Region number: 4; State in each region: AL, FL, GA, KY, MS, NC, SC, and
TN; Districts in population: 1,049; Districts in sample: 113; Districts
responding: 76.
Region number: 5; State in each region: IL, IN, MI, MN, OH, and WI;
Districts in population: 3,413; Districts in sample: 179; Districts
responding: 111.
Region number: 6; State in each region: AR, LA, NM, OK, and TX;
Districts in population: 2,061; Districts in sample: 144; Districts
responding: 100.
Region number: 7; State in each region: IA, KS, MO, and NE; Districts
in population: 1,744; Districts in sample: 54; Districts responding:
30.
Region number: 8; State in each region: CO, MT, ND, SD, UT, and WY;
Districts in population: 1,111; Districts in sample: 42; Districts
responding: 32.
Region number: 9; State in each region: AZ, CA, HI, and NV; Districts
in population: 1,375; Districts in sample: 135; Districts responding:
62.
Region number: 10; State in each region: AK, ID, OR, and WA; Districts
in population: 659; Districts in sample: 31; Districts responding: 22.
Total: Districts in population: 14,503; Districts in sample: 830;
Districts responding: 511.
Source:
Note: for this table, we adopted the Department of Education's region
definitions as provided at http://www.ed.gov/offices/OIIA/Regions.
[End of table]
On the basis of the national distribution of our sample and on the
result of our comparison of a set of survey estimates to known
population values from the CCD file, we chose to include the survey
results in our report and to produce sample based estimates to the
total population of school districts in our study population.
We chose not to report the survey responses to questions asking about
the number of highly qualified teachers because other information from
the survey and our in-depth discussions with officials during our site
visits indicated that the respondents could not accurately answer the
question. For example, three of five officials who completed the survey
but did not answer this question commented in the survey that they
could not answer because they could not count the number of teachers.
Additionally, one official who reported that 100 percent of the
teachers were highly qualified and another who reported 94 percent,
also commented that they were unable to count their teachers. During
our site visits we learned that officials did not have know the
criteria for some groups of teachers, did not have data systems to
allow them to track teachers by class and therefore, could not
accurately determine how many teachers were highly qualified.
Other Methodology:
We also visited 8 states with a range of characteristics that might
affect their meeting Title II requirement for highly qualified
teachers. Those states were California, Connecticut, Illinois, Iowa,
Maryland, North Carolina, Delaware, and Wyoming. We visited and
interviewed officials in 2 districts in each state, one of which was a
high-poverty district, and one school in each district. We interviewed
Department of Education officials, and officials and representatives
from several professional organizations. We also reviewed the
legislation, the regulations, and guidance as well as related reports
and other relevant documents. We conducted our work between July 2002
and May 2003 in accordance with generally accepted government auditing
standards.
[End of section]
Appendix II: Activities on Which States Can Spend Title II, Part A
Funds:
Table 10 lists our summaries of the authorized activities on which
states can spend Title II funds and shows the five categories we used
to group them.
Table 10: Title II, Part A State Activities:
Category: Accountability; Activity: Developing systems to measure the
effectiveness of professional development programs and strategies to
document improvements in students' academic achievement;
Ensuring that teachers use
challenging state academic content standards, assessments, and student
achievement standards to improve their teaching practices and their
students' achievement.
Category: Certification; Activity: Reforming teacher and principal
certification; Reforming tenure and implementing tests for subject
matter knowledge; Promoting license and certification reciprocity
agreements with other states for teachers and principals; Providing
programs that
establish, expand, or improve alternative routes for state
certification, especially for highly qualified individuals in the areas
of mathematics and science.
Category: Professional development; Activity: Conducting programs that
provide support to teachers, such as those that provide teacher
mentoring and use assessments that are consistent with student academic
achievement standards;
Providing professional development for teachers and principals;
Developing or assisting local educational agencies
(LEAs) in developing and using, proven innovative strategies for
intensive professional development programs that are both cost
effective and easily accessible;
Encouraging and supporting the training of teachers
and administrators to integrate technology into curricula and
instruction, including training to improve their ability to use data to
improve their teaching; Providing assistance to
teachers to enable them to meet certification, licensing, or other
Title II requirements needed to become highly qualified.
Category: Recruitment and retention; Activity: Developing or assisting
LEAs to develop, merit-based performance systems and strategies that
provide pay differentials and bonus pay for teachers in academic
subjects in which there is high need; Developing projects and programs
to encourage men to become elementary teachers; Establishing and
operating a statewide clearinghouse and programs for the recruitment,
placement, and retention of teachers;
Assisting LEAs and schools in recruiting and
retaining highly qualified teachers, including specialists in core
subjects; Developing or assisting LEAs to
develop, teacher advancement initiatives that promote professional
growth, and emphasize multiple career paths and pay differentiation.
Category: Technical assistance; Activity: Fulfilling the state agency's
responsibility to properly and efficiently carry out the administration
of programs, including providing technical assistance to LEAs;
Assisting LEAs to develop and implement
professional development programs and school leadership academies for
principals and superintendents.
Source: NCLBA Pub.L. No. 107-110, section 2113 (2002).
[End of table]
[End of section]
Appendix III: Activities on Which Districts Can Spend Title II, Part A
Funds:
Table 11 lists our summaries of the authorized activities on which
districts can spend Title II funds and shows the two categories we used
to group them.
Table 11: Title II, Part A District Activities:
Category: Professional development; Activity: Providing professional
development activities for teachers and principals that improve their
knowledge of their core subjects and effective instructional
strategies; Carrying out professional development activities
designed to improve the quality of principals and superintendents;
Carrying out teacher advancement initiatives to
promote professional growth and to emphasize multiple career paths and
pay differentiation; Carrying out programs and
activities that are designed to improve the quality of teachers, such
as professional development programs, merit pay programs, and testing
teachers in the subjects they teach.
Category: Recruitment and retention; Activity: Developing and
implementing mechanisms to assist schools in effectively recruiting and
retaining highly qualified teachers and principals;
Developing and implementing initiatives to retain
highly qualified teachers and principals, particularly in schools with
a high percentage of low-achieving students; including programs that
provide teacher mentoring and incentives; Carrying out programs and
activities related to exemplary teachers;
Developing and implementing initiatives to assist
schools in recruiting and hiring teachers, including providing
financial incentives, and establishing programs that train and hire
special education and other teachers, recruit qualified professionals
from other fields, and provide increased opportunities for minorities,
individuals with disabilities and others; Hiring highly qualified
teachers in order to reduce class size, particularly in the early
grades.
Source: NCLBA Pub.L. No. 107-110, section 2123 (2002).
[End of section]
[End of table]
Appendix IV: Comments from the U.S. Department of Education:
UNITED STATES DEPARTMENT OF EDUCATION:
THE UNDER SECRETARY:
July 3, 2003:
Ms. Marnie Shaul Director:
Education, Workforce, and Income Security Issues
United States General Accounting Office
Washington, D.C. 20548:
Dear Ms. Shaul:
This is in response to your draft report entitled "No Child Left Behind
Act: Complete Guidance and More Information Would Help States Determine
How Many Teachers are Highly Qualified" (GAO-03-631). We have carefully
reviewed the document and appreciate the opportunity to provide
comments.
The U.S. Department of Education recognizes that States, districts, and
schools face many implementation issues as they strive to meet the
teacher qualification standards created in the No Child Left Behind Act
of 2001. The law sets forth basic requirements for teachers, but
provides States considerable flexibility in such areas as determining
what constitutes full State certification and what is a "high objective
uniform State standard of evaluation" of teacher competence. We
recognize it is important to provide timely and informative guidance,
while respecting each State's ability to develop its own systems for
implementing the law.
The report recommends that the Secretary provide complete guidance and
more information to the States. We have been working with States to
provide accurate and timely assistance, recognizing that in these early
stages of implementation, issues take time and attention. The
Department released, on December 2, 2002, Title I Regulations and, on
December 19, 2002, Title II - A Non-Regulatory Guidance. In response to
requests for clarification about how the "highly qualified"
requirements apply to special education and limited English proficient
(LEP) teachers, guidance included in the Appendix of the Title I Final
Regulations clarifies that both special education and LEP teachers "who
are providing instruction in core academic content areas must meet the
highly qualified requirements of ESEA." This guidance further clarifies
that "special educators who do not directly instruct students on any
core academic subject or who provide only consultation to highly
qualified teachers of core academic subjects on behavioral supports and
interventions and selecting appropriate accommodations do not need to
meet the same "highly qualified" subject-matter competency requirements
that apply under NCLB to teachers of core academic subjects.":
We continue to work with the Council of Chief State School Officers'
INTASC (Interstate New Teachers Assessment and Support Coalition) to
discuss teacher quality issues at several national meetings. The
Department convened all State Title II Directors to discuss teacher
quality issues at a national meeting on June 12, 2003. We are in the
process of sending out teacher quality
support teams, establishing a technical assistance and evaluation
support plan, and expanding our guidance on issues that are still
outstanding.
Additionally, the Department has funded the new "What Works
Clearinghouse" to identify research-based best practices related to,
among other things, teacher training and teaching in subject areas.
Many States have asked for our help, and we have provided and will
continue to provide assistance. We engage in conversations daily
assisting States in meeting the highly qualified teacher goals of NCLB.
Demonstration of subject area competency is a key requirement in the
highly qualified teacher provisions. Each State has the option within
the law to develop a way for veteran teachers to demonstrate that
competency. The Department has not issued written guidance on the "high
objective uniform State standard of evaluation" (HOUSSE) requirements,
but we have provided large-scale technical assistance at various
meetings across the country, such as at a recent meeting of the
National Association of State Directors of Teacher Education and
Certification (NASDTEC). We continue to work with State officials by
offering technical assistance on ensuring that a State's HOUSSE system
reflects the requirements in the law. Several States have developed
draft procedures and have asked the Department for feedback and
comments. As we continue to learn more about promising strategies and
models for HOUSSE, the Department will actively share these with
States.
Additionally, the report identifies many issues that are outside of the
scope of the federal requirements, and that are matters of State and
local policy. A Federal "one size fits all" approach would be
undesirable and counterproductive, as States and districts strive to
meet the requirements of the statute in a manner that meshes with the
teacher certification, teacher assessment, and data collection systems
of each individual State. The Department will continue to provide
technical assistance wherever possible, in order to assist States in
the development of their plans.
There are significant resources available to States to meet the "highly
qualified teacher" requirements. However, the report identifies only
the amount of Title II-A funds that districts and States may use to
help teachers become highly qualified. The report should instead note
that, under NCLB, districts must use between five and ten percent of
their Title I-A funding for this purpose, and that they also have
available Title V and other Title I-A funds. Without that inclusion,
the report significantly understates the Federal investment available
to help districts and schools meet the requirements.
The No Child Left Behind Act also provides LEAs with flexibility to
consolidate certain Federal funds to carry out activities, including
programs that improve teacher quality, that best meet their own needs.
For example, under the State and Local Transferability Act, an LEA not
identified as being in need of improvement or corrective action under
Title I may transfer up to 50 percent of its formula allocation under
the Improving Teacher Quality State Grants, Educational Technology
State Grants, State Grants for Innovative Programs, and Safe and Drug-
Free Schools State Grants programs to its allocation under: (1) any of
the other authorized programs; or (2) Part A of Title I.
We encourage States to act boldly as they develop plans to meet the
requirements of the law. Highly qualified teachers are vital to student
achievement and realizing the promise and potential of NCLB. The law
recognizes this fundamental principal, and the Department of Education
does as well. We look forward to continuing our work assisting States
in implementing these important goals.
Sincerely,
Eugene W. Hickok:
Signed by Eugene W. Hickok:
[End of section]
Appendix V: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Carolyn M. Taylor (202) 512-2974 or taylorcm@gao.gov Mary E. Roy (202)
512-7072 or roym@gao.gov:
Staff Acknowledgments:
In addition to those named above, the following individuals made
important contributions to this report: Susan Higgins, Anjali
Tekchandani, David Garten, Joel Grossman, Richard Kelley, Mark Ramage,
Minnette Richardson, Susan Bernstein, and Jeff Edmondson.
FOOTNOTES
[1] In this report, the term "district" refers to local education
agencies.
[2] Core subjects include English, reading or language arts,
mathematics, science, foreign languages, civics and government,
economics, arts, history, and geography.
[3] All percentage estimates produced from the district survey have
sampling errors of no more than plus or minus 10 percentage points, at
a 95 percent confidence level, unless otherwise noted.
[4] Sanders, W. and Rivers, J., Cumulative and Residual Effects of
Teachers on Future Student Academic Achievement. Knoxville, TN:
University of Tennessee Value-Added Research and Assessment Center,
November, 1996.
[5] Kati Haycock, Closing the Achievement Gap (The Education Trust,
March 2001).
[6] National Center for Education Statistics, U.S. Department of
Education, The Condition of Education 2002.
[7] Title I of NCLBA requires that every state that accepts Title I
funds must ensure that all their teachers meet the requirement. All
states and the District of Columbia have accepted the funds. Title I of
NCLBA is designed to help educate disadvantaged children--those with
low academic achievement attending schools serving high-poverty areas.
Title I was appropriated funding of over $10 billion in fiscal year
2002.
[8] For 2002, the poverty threshold was $18,556 annually for a family
of four.
[9] Many states have alternate routes to certification, referred to
here as alternative certification programs, that allow an individual
who has a bachelor's degree from a college or university but who does
not hold a degree in education, to receive a license to teach.
Alternative certification programs range from those that place people
in classrooms immediately to longer programs that delay placing people
in classrooms until they have completed course work and received a
mentor. While these programs vary within and among states, nearly all
states have some type of alternative to the traditional path of
majoring in education in order to become a teacher.
[10] National Center for Education Statistics, Schools and Staffing
Survey, 1990-2000, "Number and Percent of Public School Special
Education Teachers Who Teach Special Education Classes as Their Main
Assignment or as Their Second Assignment" (2002).
[11] Cynthia Prince, Higher Pay in Hard to Staff Schools: The Case for
Financial Incentives, American Association of School Administrators,
June 2002.
[12] In this report, when discussing a shortage of teachers in the high
need subject area of special education, we are referring to a shortage
of persons qualified to be special education teachers to teach core
subjects to children with disabilities as defined in Section 602 of the
Individuals with Disabilities Education Act Amendments of 1997.
[13] Department of Education, Qualifications of the Public School
Teacher Workforce: Prevalence of Out-of-Field Teaching 1987-88 and
1999-2000, Statistical Analysis Report, Schools and Staffing Survey,
National Center for Education Statistics, 2002.
[14] As provided in Title II of NCLBA, programs to support new teachers
include teacher mentoring, team teaching, reduced class schedules, and
intensive professional development.
[15] The Higher Education Act defines distance education as an
educational process where the student is separated in time or place
from the instructor.
[16] For example, districts must use 5 to 10 percent of their Title I-
A funds in fiscal years 2002 and 2003 for professional development
activities to ensure that teachers become highly qualified.
[17] State education agencies receive 5 percent of the total grant
funds and can retain up to 1 percent of these funds for administrative
costs. Of the remaining funds, 2.5 percent must be spent on subgrants
to eligible partnerships and the remaining funds are to be used for
authorized activities. We grouped the Title II activities into five
categories: (1) accountability, (2) certification, (3) professional
development, (4) recruitment and retention, and (5) technical
assistance. Appendix II lists all 18 activities.
[18] Districts are to spend their Title II funds on 9 authorized
activities that we grouped into 2 categories: (1) professional
development and (2) recruitment and retention. Appendix III lists all 9
activities.
[19] U. S. Department of Education, The Class-Size Reduction Program:
Boosting Student Achievement in Schools Across the Nation, A First-Year
Report, September 2000.
[20] "City" is defined as a central city of Consolidated Metropolitan
Statistical Area (CMSA) or as a central city of a Metropolitan
Statistical Area (MSA). "Urban" refers to Urban Fringe (an incorporated
place, Census Designated Place, or nonplace territory within a CMSA or
MSA of a city and defined as urban by the Census Bureau), to a large
town (an incorporated place or Census Designated Place with a
population greater than or equal to 25,000 and located outside a CMSA
or MSA), or to an incorporated place or Census Designated Place with a
population less than 25,000 and greater than 2,500 located outside a
CMSA or MSA. A "rural community" is any incorporated place, Census
Designated Place, or nonplace territory designated as rural by the
Census Bureau.
[21] Poverty level was not available on the CCD data files; however, as
a proxy for poverty, we stratified based on participation in the free/
reduced student meals program. For sample selection, high-poverty
districts are those districts having at least 60 percent participation
in free/reduced meals programs. Less than 60 percent participation in
this program identifies a district as a low-poverty district for
stratification purposes.
[22] This was possible because the CCD population file contains certain
data elements for the universe of districts from which we drew our
sample.
GAO's Mission:
The General Accounting Office, the investigative arm of Congress,
exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability
of the federal government for the American people. GAO examines the use
of public funds; evaluates federal programs and policies; and provides
analyses, recommendations, and other assistance to help Congress make
informed oversight, policy, and funding decisions. GAO's commitment to
good government is reflected in its core values of accountability,
integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains
abstracts and full-text files of current reports and testimony and an
expanding archive of older products. The Web site features a search
engine to help you locate documents using key words and phrases. You
can print these documents in their entirety, including charts and other
graphics.
Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as "Today's Reports," on its
Web site daily. The list contains links to the full-text document
files. To have GAO e-mail this list to you every afternoon, go to
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order
GAO Products" heading.
Order by Mail or Phone:
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or
more copies mailed to a single address are discounted 25 percent.
Orders should be sent to:
U.S. General Accounting Office
441 G Street NW,
Room LM Washington,
D.C. 20548:
To order by Phone:
Voice: (202) 512-6000:
TDD: (202) 512-2537:
Fax: (202) 512-6061:
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470:
Public Affairs:
Jeff Nelligan, managing director, NelliganJ@gao.gov (202) 512-4800 U.S.
General Accounting Office, 441 G Street NW, Room 7149 Washington, D.C.
20548:
