No Child Left Behind Act
Education Actions Needed to Improve Local Implementation and State Evaluation of Supplemental Educational Services Gao ID: GAO-06-758 August 4, 2006The No Child Left Behind Act of 2001 (NCLBA) requires districts with schools that have not met state performance goals for 3 consecutive years to offer their low-income students supplemental educational services (SES), such as tutoring, if these schools receive Title I funds. SES are provided outside of the regular school day by a state-approved provider, with responsibility for implementation shared by states and districts. GAO examined (1) how SES participation changed between school years 2003-2004 and 2004-2005; (2) how SES providers are working with districts to deliver SES; (3) how states are monitoring and evaluating SES; and (4) how the Department of Education (Education) monitors and supports state implementation of SES. To collect data on SES, GAO surveyed all states and a nationally representative sample of districts with schools required to offer SES. We also visited 4 school districts, interviewed 22 SES providers, reviewed SES-related research, and interviewed Education staff.
SES participation among eligible students increased from 12 to 19 percent between school years 2003-2004 and 2004-2005, and the number of recipients also increased, due in part to a rise in the number of schools required to offer services. Districts have used some promising practices to inform parents and encourage participation, such as offering services on school campuses and at various times. However, challenges remain, including timely and effective notification of parents and attracting providers to serve certain areas and students, such as rural districts or students with disabilities. To promote improved student academic achievement, SES providers took steps to align their curriculum with district instruction and communicate with teachers and parents, though the extent of their efforts varied. A majority of the 22 providers we interviewed worked to align SES and district curriculum by hiring teachers familiar with the district curriculum as tutors. However, at least some providers did not have any contact with teachers in about 40 percent of districts. Both providers and district officials experienced challenges related to contracting and coordination of service delivery. Providers, districts, and schools reported that greater involvement of schools would improve SES delivery and coordination, as it has in some places where this is occurring. While state monitoring of district and provider efforts to implement SES has been limited in past years, more states reported conducting on-site reviews and other monitoring activities during 2005-2006. In addition, districts have taken a direct role in monitoring providers, and their monitoring efforts have similarly increased. Although states are required to withdraw approval from providers that fail to increase student academic achievement for 2 years, many states struggle to develop meaningful SES evaluations. While a few states have completed evaluations, none provides a conclusive assessment of SES providers' effect on student academic achievement. Several Education offices monitor SES activity across the country and provide SES support to states and districts through written guidance, grants, and technical assistance. However, states and districts reported needing additional SES evaluation support and technical assistance. For example, 85 percent of states reported needing assistance with methods for evaluating SES. Many also voiced interest in Education's pilot programs that increase SES flexibility, including the one that allowed certain districts identified as in need of improvement to act as providers.
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-06-758, No Child Left Behind Act: Education Actions Needed to Improve Local Implementation and State Evaluation of Supplemental Educational Services
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
August 2006:
No Child Left Behind Act:
Education Actions Needed to Improve Local Implementation and State
Evaluation of Supplemental Educational Services:
No Child Left Behind Act:
GAO-06-758:
GAO Highlights:
Highlights of GAO-06-758, a report to congressional requesters
Why GAO Did This Study:
The No Child Left Behind Act of 2001 (NCLBA) requires districts with
schools that have not met state performance goals for 3 consecutive
years to offer their low-income students supplemental educational
services (SES), such as tutoring, if these schools receive Title I
funds. SES are provided outside of the regular school day by a state-
approved provider, with responsibility for implementation shared by
states and districts. GAO examined (1) how SES participation changed
between school years 2003-2004 and 2004-2005; (2) how SES providers are
working with districts to deliver SES; (3) how states are monitoring
and evaluating SES; and (4) how the Department of Education (Education)
monitors and supports state implementation of SES. To collect data on
SES, GAO surveyed all states and a nationally representative sample of
districts with schools required to offer SES. We also visited 4 school
districts, interviewed 22 SES providers, reviewed SES-related research,
and interviewed Education staff.
What GAO Found:
SES participation among eligible students increased from 12 to 19
percent between school years 2003-2004 and 2004-2005, and the number of
recipients also increased, due in part to a rise in the number of
schools required to offer services. Districts have used some promising
practices to inform parents and encourage participation, such as
offering services on school campuses and at various times. However,
challenges remain, including timely and effective notification of
parents and attracting providers to serve certain areas and students,
such as rural districts or students with disabilities. To promote
improved student academic achievement, SES providers took steps to
align their curriculum with district instruction and communicate with
teachers and parents, though the extent of their efforts varied. A
majority of the 22 providers we interviewed worked to align SES and
district curriculum by hiring teachers familiar with the district
curriculum as tutors. However, at least some providers did not have any
contact with teachers in about 40 percent of districts. Both providers
and district officials experienced challenges related to contracting
and coordination of service delivery. Providers, districts, and schools
reported that greater involvement of schools would improve SES delivery
and coordination, as it has in some places where this is occurring.
While state monitoring of district and provider efforts to implement
SES has been limited in past years, more states reported conducting on-
site reviews and other monitoring activities during 2005-2006. In
addition, districts have taken a direct role in monitoring providers,
and their monitoring efforts have similarly increased. Although states
are required to withdraw approval from providers that fail to increase
student academic achievement for 2 years, many states struggle to
develop meaningful SES evaluations. While a few states have completed
evaluations, none provides a conclusive assessment of SES providers‘
effect on student academic achievement. Several Education offices
monitor SES activity across the country and provide SES support to
states and districts through written guidance, grants, and technical
assistance. However, states and districts reported needing additional
SES evaluation support and technical assistance. For example, 85
percent of states reported needing assistance with methods for
evaluating SES. Many also voiced interest in Education‘s pilot programs
that increase SES flexibility, including the one that allowed certain
districts identified as in need of improvement to act as providers.
Figure: SES Is Often Delivered after School and on School Campuses:
[See PDF for Image]
Source: GAO.
[End of Figure]
What GAO Recommends:
GAO recommends that Education disseminate information on promising
practices used to improve SES implementation, provide states with
technical assistance to improve evaluation of SES‘s effect on student
achievement, and expand program flexibility where appropriate.
Education generally supported GAO‘s recommendations.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-758].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Marnie Shaul at (202) 512-
7215 or shaulm@gao.gov.
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
SES Participation Has Increased as Districts Have Taken Steps to Ease
Access, but Challenges Remain:
Providers Have Taken Steps to Deliver Quality Services, but Contracting
and Coordination Remain Challenges to Working with Districts and
Schools:
States' SES Monitoring Has Been Limited Though Their Efforts Are
Increasing, and Many States Struggle to Develop Meaningful Evaluations:
Several Education Offices Monitor and Support SES Implementation, but
States and Districts Cite the Need for Additional Assistance and
Flexibility:
Conclusions:
Recommendations:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Education:
Appendix III: GAO Contacts and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: NCLBA Interventions for Schools Not Meeting Yearly Performance
Goals over Time:
Table 2: SES Stakeholder Roles and Responsibilities:
Table 3: District Actions Taken to Encourage SES Participation (2005-
2006):
Table 4: State Actions Taken to Encourage SES Participation (2005-
2006):
Table 5: Percentage of States and Districts That Reviewed Specified
Program Elements to Monitor Providers in 2005-2006:
Table 6: Percentage of States and Districts in Need of Different Types
of Information or Assistance with SES Implementation:
Table 7: State and District Opinion on the Ordering of School Choice
and SES:
Table 8: Description of the Population and Sample of Districts:
Table 9: Sampling Error Calculations:
Table 10: SES District Survey Response Rates:
Figures:
Figure 1: Number of Students Receiving SES Nationwide (2002-2003 to
2004-2005):
Figure 2: School Districts Required to Offer SES in 2004-2005:
Figure 3: Estimated Percentage of Districts Experiencing Certain Issues
with None, Few, Some, Most, or All of Their Providers in 2004-2005:
Figure 4: Percentage of States That Reviewed Specific Program Elements
to Monitor District SES Implementation in 2005-2006:
Figure 5: Percentage of States Reviewing Information Collected from
Different Sources to Monitor SES Providers in 2004-2005 and 2005-2006:
Figure 6: Estimated Percentage of Districts Reviewing Information
Collected from Different Sources to Monitor SES Providers in 2004-2005
and 2005-2006:
Figure 7: U.S. Department of Education Offices Monitoring and
Supporting SES:
Abbreviations:
AYP: adequate yearly progress:
CSPR: Consolidated State Performance Report:
ESEA: Elementary and Secondary Education Act:
NCLBA: No Child Left Behind Act:
NSLP: National School Lunch Program:
OESE: Office of Elementary and Secondary Education:
OIG: Office of the Inspector General:
OII: Office of Innovation and Improvement:
SES: supplemental educational services:
SESQC: Supplemental Educational Services Quality Center:
United States Government Accountability Office:
Washington, DC 20548:
August 4, 2006:
Congressional Requesters:
Title I of the No Child Left Behind Act (NCLBA) supports the academic
achievement of 16.5 million low-income students nationwide by providing
them with additional opportunities, such as supplemental educational
services (SES), if their schools are low performing. SES includes
tutoring and remediation that are provided outside of the regular
school day by a state-approved provider, such as a for-profit company
or a community-based organization. When a Title I school does not meet
state performance goals for 2 years, including goals set under the
Elementary and Secondary Education Act (ESEA) before the enactment of
NCLBA, the district must offer students the choice of transferring to
another school in the district that is not in improvement status. When
a Title I school does not meet state performance goals for 3 or more
years, the district must offer SES to all of the low-income students
enrolled in the school. Districts with schools required to offer school
choice and SES must set aside an amount equal to 20 percent of their
Title I funds to provide choice-related transportation and SES for
eligible students in these schools. In school year 2005-2006, $12.7
billion in federal Title I funding was distributed to nearly all school
districts and approximately half of the public schools nationwide in
order to improve the education of low-income students.
While states set NCLBA performance goals and schools are judged on the
performance of their students, responsibility for SES implementation is
primarily shared by states and districts under the law. States are
responsible for approving SES providers to serve students in their
states and, therefore, review provider applications to assess each
provider's record of effectiveness and program design, including its
instructional strategies and service costs. States are also responsible
for monitoring SES providers and evaluating their services. Districts
are responsible for notifying parents of their child's eligibility for
SES and contracting with the state-approved providers parents select
for services. At the federal level, the U.S. Department of Education
(Education) oversees SES implementation nationwide and provides
guidance and technical assistance.
Although some districts were first required to offer SES in 2002-2003,
others did not have to offer SES until 2003-2004 or the year after, and
therefore, states and districts are at different stages of implementing
the SES provisions. Further, research suggests that many face
challenges to increasing student participation, working with providers
to ensure students receive quality services, and monitoring and
evaluating these services. In response to congressional interest in
these and other issues related to early implementation of SES, and in
anticipation of reauthorization of the ESEA, we agreed to answer the
following questions: (1) How has SES participation changed between
school years 2003-2004 and 2004-2005, and what actions have been taken
to increase participation? (2) How are providers working with districts
and schools to provide services that increase student achievement? (3)
To what extent are states monitoring and evaluating SES implementation?
(4) How does Education monitor state SES implementation and assist
state and district efforts?
To answer our four research questions, we collected data through
several methods. First, to gather state-level information on SES, we
collected information through a Web-based survey of state SES
coordinators in all 50 states, the District of Columbia, and Puerto
Rico. Further, to gather district-level information on SES, we
conducted a mail survey of district SES coordinators from a nationally
representative sample of districts with schools required to offer SES.
To ensure that we obtained information from the largest districts with
schools required to offer SES, we included all 21 districts with
100,000 or more enrolled students in our sample. In designing our
surveys, we reviewed survey questions used by Education. The district
and state surveys were both administered between January and March
2006. Seventy-seven percent of district SES coordinators, including all
coordinators from districts with 100,000 or more enrolled students, and
all state SES coordinators responded to the surveys. All percentage
estimates presented from the district survey have margins of error of
plus or minus 8 percentage points, unless otherwise noted. While we did
not validate specific information that states and districts reported
through our surveys, we reviewed the information to determine that
their responses were complete and reasonable and found the information
to be sufficiently reliable for the purposes of this report. To gather
federal-level information on SES implementation, we interviewed
Education officials and analyzed Education's data on SES available from
state reports and ongoing studies.
To collect additional information from states and districts, as well as
information from schools and providers, we conducted site visits to
four school districts that had experience with SES implementation
(Woodburn, Ore; Newark, N.J; Chicago, Ill; and Hamilton County, Tenn.)
During the visits, we spoke with state and district officials, as well
as officials from a total of 12 schools and 15 providers. When viewed
as a group, the site visit districts provided variation across
characteristics such as geographic location, district size, student
ethnicity, and the percentage of students with limited English
proficiency or disabilities. In addition to the 15 providers we spoke
with during the site visits, we also interviewed 7 for-profit SES
providers operating in multiple states, for a total of 22 providers. In
our surveys and other data collection efforts, we asked questions about
SES implementation during specific school years, and, therefore, all
years cited refer to school years.
See appendix I for detailed information on both of our surveys as well
as our other data collection methods. We conducted our work from August
2005 through July 2006 in accordance with generally accepted government
auditing standards.
Results in Brief:
Nationally, SES participation increased from 12 percent of eligible
students receiving services in 2003-2004 to 19 percent in 2004-2005,
but challenges to increasing participation remain. The total number of
students receiving services rose from approximately 117,000 in 2002-
2003 to 430,000 in 2004-2005, due in part to a rise in the number of
schools required to offer services. An estimated 20 percent of
districts required to offer SES had no students receiving services, and
the majority of those districts were rural or had less than 2,500
enrolled students. While these districts, therefore, spent no funds for
SES, some other districts that were providing services reported needing
more than the 20 percent Title I set-aside to serve all eligible
students that had requested services. While a student's eligibility for
SES is based on income and not academic achievement, most students
receiving services were among the lower achieving students in school.
Districts have taken multiple actions to encourage participation, such
as using several methods to contact parents and offering services on
school campuses and at various times. For example, 90 percent or more
of districts provided parents with written information, held individual
meetings with parents, encouraged school staff to talk with parents
about SES, and offered services in locations easily accessible to
students, such as on or near the school campus. Although some districts
have used promising practices to increase SES participation, notifying
parents in a timely and effective way continues to be a challenge for
districts. About half of the districts did not notify parents before
the beginning of the current school year, due in part to delays in
receipt of school improvement results from their state. Further,
several providers indicated that confusing parental notification
letters and enrollment forms may discourage participation. States and
districts have also been challenged to ensure there are providers to
serve students from rural areas or students with limited English
proficiency or disabilities. Encouraging student attendance has also
been a challenge, in part because students may participate in other
after-school activities, such as sports or work.
Providers reported that they are working with districts and schools to
deliver quality services, but contracting with districts and
coordinating with schools remain challenges, and all parties reported
that implementation would be improved with greater school involvement.
To help improve student academic achievement, providers align their
curriculum with district instruction primarily by hiring teachers
familiar with the district curriculum and communicating with the
teachers of participating students. Providers reported communicating
with teachers in person as well as mailing information and progress
reports to them, which are similar to the methods reported for
communicating with parents. However, we estimate that some, most, or
all providers did not contact teachers in about 40 percent of districts
and did not contact parents in about 30 percent of districts during the
2004-2005 school year. In addition, contracting for services was
sometimes a challenge for providers and districts. Some of the
providers we interviewed said certain districts impose burdensome
contract requirements, such as limiting provider marketing and use of
school facilities. About 40 percent of districts also considered
contracting to be a challenge, and officials in three of the four
districts we visited expressed concerns about their lack of authority
under the law to set parameters around costs and program design, such
as the number of service hours per student and the tutor-to-student
ratio. While officials from one state we visited expressed interest in
additional federal guidance on setting such parameters, another state
helped to address some of its district's concerns and improve
transparency and accountability by requiring approved providers to
submit cost information and sharing this information with districts.
About 70 percent of the states also reported that coordination among
providers, districts, and schools is a moderate to very great
challenge. For example, services were delayed or withdrawn in three of
the four districts we visited because not enough students signed up to
meet the providers' enrollment targets and districts were not aware of
these targets. Because SES may be delivered in school facilities,
providers and officials in the districts and schools we visited
reported that involvement of school administrators and teachers can
ease SES delivery and coordination with providers.
Prior to 2005-2006, state SES monitoring of both districts and
providers was limited, and over the last few years, many states have
struggled to develop meaningful SES evaluations. In regard to
monitoring districts, more states reported conducting on-site reviews
in 2005-2006, and many states also collected information from other
sources, such as school principals and parents. Further, nearly all
states were collecting information on districts' expenditures for SES
and their efforts to notify parents of available services. In regard to
monitoring providers, though states were challenged by their oversight
capacity, many states reported using a more active monitoring approach
in 2005-2006. For example, approximately three-fourths indicated they
were conducting on-site reviews, and many were also collecting
information from districts, schools, and parents to monitor SES
providers in that year. In addition to states, districts have also
taken an active role in monitoring providers, and similarly increased
their efforts in 2005-2006. While states are required to withdraw
approval from providers that fail to increase student academic
achievement for 2 years, many are struggling to develop meaningful SES
evaluations that assess this outcome. Approximately three-fourths of
states reported that they are experiencing challenges evaluating SES,
including designing methods for determining sufficient academic
progress of students, having the time and knowledge to analyze SES
data, and developing data systems to track SES information. For
example, during our site visits to Illinois and New Jersey, state
officials noted that they were currently in the process of improving
their data collection systems to more effectively capture and analyze
data for SES evaluations. At the time of our survey, only a few states
had drafted or completed an evaluation report addressing SES providers'
effect on student academic achievement, and no state had produced a
report that provided a conclusive assessment of this effect. In
addition, over half of the states reported that they were in the
process of conducting an SES evaluation in order to meet the federal
requirement.
Several Education offices monitor SES and support implementation
through written guidance and technical assistance grants, but states
and districts cite the need for additional assistance and flexibility.
Two Education offices are primarily responsible for SES monitoring. The
Office of Innovation and Improvement (OII) monitors SES implementation
by reviewing SES-related reports and responding to state, district, and
provider concerns brought to its attention, while the Office of
Elementary and Secondary Education (OESE) visits states and districts
as part of its overall Title I monitoring. The Office of the Inspector
General (OIG) also conducts monitoring through on-site SES audits.
Education shares monitoring results internally and has used them to
help states and districts address implementation challenges. For
example, OII has updated the SES non-regulatory guidance several times
since 2002, and OESE has recommended actions needed to improve state
compliance with federal regulations. Education also issues grants that
provide SES implementation support. For example, OESE recently funded
the Center on Innovation and Improvement, which provides technical
assistance to regional centers to help them work with states to improve
Education's programs, including SES. Despite Education's efforts, many
states and districts reported that they need additional information or
assistance with certain aspects of SES implementation to better comply
with SES requirements. For example, 85 percent of states and an
estimated 70 percent of districts needed assistance with methods for
evaluating SES. Further, states and districts both indicated needing
additional capacity to implement SES. Officials also reported needing
additional or clearer guidance from Education on certain SES
provisions, such as crafting a notification letter that is both
complete and easy for parents to understand. Although Education has
cited several states for districts' incomplete notification letters,
the department's current SES guidance provides a sample parental
notification letter that does not clearly specify all of the required
elements. Many states also reported needing a forum to share promising
practices with peers, such as meetings and conferences. In addition,
many states and districts expressed interest in expansion of
Education's pilot programs. For example, some officials suggested
expanding Education's pilot that enables low-achieving districts
typically restricted from being SES providers to provide these services
on the condition that they evaluate the effect of their services on
student achievement. Officials noted this may ease access to SES and
potentially reduce costs.
To help states and districts implement SES more effectively, we are
recommending that Education collect and disseminate information on
promising practices used by districts, including examples of how
districts have successfully involved school officials in SES
implementation, and sample parental notification letters that meet
federal requirements and are easy for parents to understand. Further,
to improve states' and districts' ability to provide services to the
maximum number of students, we are recommending that Education consider
expanding its current SES pilot program allowing selected districts in
need of improvement to serve as providers and clarify state authority
to set parameters around service design and costs. To improve federal
and state monitoring of SES, we are recommending that Education require
states to collect and submit information on the amount and percent of
Title I funds spent on SES by districts and provide states with
technical assistance and additional guidance on how to evaluate the
effect of SES on student academic achievement.
In written comments on a draft of this report, Education supported our
recommendations and cited actions the department has already initiated
or plans to take in addressing them. Education also provided technical
comments, which were incorporated into the report as appropriate.
Background:
Under NCLBA, SES primarily includes tutoring provided outside of the
regular school day that is designed to increase the academic
achievement of economically disadvantaged students in low-performing
Title I schools. These services must consist of high-quality, research-
based instruction that aligns with state educational standards and
district curriculum.
Title I:
Title I[Footnote 1] of ESEA, as amended and reauthorized by NCLBA,
authorizes federal funds to help elementary and secondary schools
establish and maintain programs that will improve the educational
opportunities of economically disadvantaged children. Title I is the
largest federal program supporting education in kindergarten through
12th grade, supplying $12.7 billion in federal funds in fiscal year
2006. According to Education, during the 2005-06 school year, nearly
all U.S. school districts and approximately half of public schools
received some Title I funding. In addition, the latest national data
available from Education counted 16.5 million students as Title I
participants in the 2002-2003 school year.
Title I funds are distributed by formula to state education agencies,
which retain a share for administration and school improvement
activities before passing most of the funds on to school districts.
Districts are required to distribute Title I funds first to schools
with poverty rates over 75 percent, with any remaining funds
distributed at their discretion to schools in rank order of poverty
either districtwide or within grade spans. A school's Title I status
can change from year to year because school enrollment numbers and
demographics may vary over time.
NCLBA:
Enactment of NCLBA strengthened accountability by requiring states and
schools to improve the academic performance of their students so that
all students are proficient in reading and math by 2014. Under NCLBA,
each state creates its own content standards, academic achievement
tests, and proficiency levels. In 2005-2006, states were required to
test all children for reading and mathematics achievement annually in
grades 3-8 and once in high school to determine whether schools are
making adequate yearly progress (AYP).[Footnote 2]
In addition to meeting the state's performance goals by grade, subject,
and overall student population, schools are responsible for meeting
those goals for designated groups. These groups are students who (1)
are economically disadvantaged, (2) are part of a racial or ethnic
group that represents a significant proportion of a school's student
population, (3) have disabilities, or (4) have limited English
proficiency. To make AYP, each school must also show that each of these
groups met the state proficiency goals for both reading and math. In
addition, schools must show that at least 95 percent of students in
grades required to take the test have done so. Schools must also
demonstrate that they have met state targets for at least one other
academic indicator, including graduation rate in high schools and a
state-selected measure in elementary or middle schools.[Footnote 3]
For Title I schools that do not meet state AYP goals, NCLBA requires
the implementation of specific interventions, and these interventions
must continue until the school has met AYP for 2 consecutive years.
Table 1 outlines the interventions applied after each year a Title I
school misses state performance goals. At their discretion, states may
also implement interventions for public schools that do not receive
Title I funds and do not make AYP. Although districts are not required
to offer SES until a Title I school has missed performance goals for 3
years, because some schools had not met state goals set under ESEA
before the enactment of NCLBA, some Title I schools were first required
to offer SES in 2002-2003, the first year of NCLBA implementation.
Table 1: NCLBA Interventions for Schools Not Meeting Yearly Performance
Goals over Time:
Number of years school misses performance goals: First year missed;
School status in the next year: N/A;
NCLBA interventions for Title I schools: None.
Number of years school misses performance goals: Second year missed;
School status in the next year: Needs Improvement - First Year;
NCLBA interventions for Title I schools: Required to offer school
choice.
Number of years school misses performance goals: Third year missed;
School status in the next year: Needs Improvement - Second Year;
NCLBA interventions for Title I schools: Required to offer school
choice and SES.
Number of years school misses performance goals: Fourth year missed;
School status in the next year: Corrective Action[A];
NCLBA interventions for Title I schools: Required to offer school
choice and SES.
Number of years school misses performance goals: Fifth year missed;
School status in the next year: Planning for Restructuring[B];
NCLBA interventions for Title I schools: Required to offer school
choice and SES.
Number of years school misses performance goals: Sixth year missed;
School status in the next year: Implementation of Restructuring;
NCLBA interventions for Title I schools: Required to offer school
choice and SES.
Source: GAO analysis of NCLBA.
Note: N/A = not applicable.
[A] Corrective action is a significant intervention in a school that is
designed to remedy the school's persistent inability to make adequate
progress toward all students becoming proficient in reading and
mathematics.
[B] Restructuring is a major reorganization of a school, involving
fundamental reforms, such as significant changes in the school's
staffing and governance. For example, some schools may be converted to
charter schools during restructuring.
[End of table]
States are also required to establish and implement AYP standards for
school districts based on the performance of all of the schools in the
district. If districts fail to meet these standards for 2 consecutive
years, states may classify districts as needing improvement. A district
identified for improvement must develop and implement an improvement
plan and remain in this status until it meets AYP standards for 2
consecutive years. If a district remains in improvement status for 2 or
more years, it may be identified for corrective action as deemed
necessary by the state.
SES under NCLBA:
Students are eligible for SES if they attend Title I schools that have
missed AYP for 3 consecutive years and are from low-income families.
School districts must determine family income on the same basis they
use to make allocations to schools under Title I, for which many have
historically used National School Lunch Program (NSLP) data. The NSLP
is a federally funded program that annually collects family income data
from students' parents to determine student eligibility for free and
reduced-priced lunch.[Footnote 4] A student's state assessment scores,
grades, and other academic achievement information are generally not
considered when determining SES eligibility. However, if sufficient
funds are not available to provide SES to all eligible children, school
districts must give priority to the lowest-achieving eligible students.
SES providers may include nonprofit entities, for-profit entities,
school districts, public schools, public charter schools, private
schools, public or private institutions of higher education,
educational service agencies, and faith-based organizations. Under the
Title I regulations that govern SES, a district identified as in need
of improvement or corrective action may not be an SES provider, though
its schools that are not identified as needing improvement may. In
addition, individual teachers who work in a school or district
identified as in need of improvement may be hired by any state-approved
provider to serve as a tutor in its program.
A district must set aside an amount equal to 20 percent of its Title I
allocation to fund both SES and transportation for students who elect
to attend other schools under school choice. This set-aside cannot be
spent on administrative costs for these activities, and the district
may reallocate any unused set-aside funds to other Title I activities
after ensuring all eligible students have had adequate time to opt to
transfer to another school or apply for SES. Funding available for SES
is, therefore, somewhat dependent on costs for choice-related
transportation, though as we found in our 2004 report on NCLBA's school
choice provisions, few students are participating in the school choice
option.[Footnote 5] If a district does not incur any choice-related
transportation costs, it must use the full 20 percent set-aside amount
to pay for SES if sufficient demand for services exists. In addition,
if the Title I set-aside is not sufficient to fund SES for interested
students, both states and districts may direct other funds for these
services at their discretion. For each student receiving SES, a
district must spend an amount equal to its Title I per-pupil allocation
or the actual cost of provider services, whichever is less.[Footnote 6]
Education oversees SES implementation by monitoring states and
providing technical assistance and support. OII leads SES policy
development and coordinates the publication of SES guidance, and OESE
oversees and monitors Title I, including SES. NCLBA and the Title I
regulations and SES guidance outline the roles and responsibilities
states, school districts, parents, and service providers have in
ensuring that eligible students receive additional academic assistance
through SES (see table 2).
Table 2: SES Stakeholder Roles and Responsibilities:
Stakeholder: State;
Roles and responsibilities: Set criteria and standards for approving
providers;
Identify, approve, and maintain public list of providers;
Ensure that the list of approved providers includes organizations that
are able to serve students with disabilities and limited English
proficiency;
Monitor and evaluate the effectiveness of provider services;
Monitor district SES implementation;
Develop and use policy criteria for withdrawing providers from state-
approved list, including if;
* provider fails for 2 consecutive years to increase student
proficiency relative to state academic content and achievement
standards;
* provider fails to adhere to applicable health, safety, and civil
rights requirements.
Stakeholder: School district;
Roles and responsibilities: Provide an annual notice to parents, which
must identify available providers, describe the enrollment process and
timeline, describe the services, qualifications, and demonstrated
effectiveness of each provider, and be easily understandable;
Help parents choose a provider, if requested;
Protect the privacy of students eligible for and receiving services;
Calculate and establish the SES per pupil allocation if not determined
by the state;
Determine which students should receive services if more students apply
for SES than can be served with available funds;
Enter into contracts with providers;
Ensure eligible students with disabilities and eligible students with
limited English proficiency may participate in SES;
At the discretion of the state, may be involved in collecting data from
providers to assist state monitoring and evaluation activities.
Stakeholder: Providers;
Roles and responsibilities: Provide services in accordance with
district agreements;
Enable students to attain their individual achievement goals;
Measure student progress and inform parents and teachers of progress
made by students;
Ensure non- disclosure of student data to the public;
Provide services consistent with applicable health, safety, and civil
rights laws;
Provide services that are secular, neutral, and non-ideological.
Stakeholder: Parents;
Roles and responsibilities: Choose a provider from the state-approved
list;
Are encouraged to be actively involved in their child's SES program.
Source: GAO, per P.L.107-110, 34 C.F.R. Part 200, or the U.S.
Department of Education, Supplemental Educational Services Non-
Regulatory Guidance, June 2005.
[End of table]
During the 2005-2006 school year, Education announced the
implementation of two pilot programs intended to increase the number of
eligible students receiving SES and generate additional information
about the effectiveness of SES on students' academic achievement. In
the first, Education permitted four districts in Virginia to offer SES
instead of school choice in schools that are in their first year of
needs improvement. In the second, Education entered into flexibility
agreements with the Boston and Chicago school districts, enabling them
to act as SES providers while in improvement status. OII and OESE
coordinated implementation of the pilots for the department. Both
pilots were subject to review at the end of the 2005-2006 school year,
at which time Education planned to evaluate their effect on student
academic achievement.
SES Participation Has Increased as Districts Have Taken Steps to Ease
Access, but Challenges Remain:
SES participation increased between 2003-2004 and 2004-2005, and most
students receiving services were among the lower achieving students in
school. Districts have taken multiple actions to encourage
participation, such as offering services on or near the school campus
or at various times. Despite these efforts, challenges to increasing
participation remain, including notifying parents in a timely and
effective manner, ensuring there are providers to serve certain areas
and students, and encouraging student attendance.
Participation among Eligible Students Increased from 12 to 19 Percent
between 2003-2004 and 2004-2005, and Most Participants Were Low
Achieving:
Nationally, the participation rate increased substantially from 12
percent of eligible students receiving SES in 2003-2004 to 19 percent
in 2004-2005.[Footnote 7] In addition, the number of students receiving
services almost quadrupled between 2002-2003 and 2004-2005 from
approximately 117,000 to 430,000 students nationwide, based on the best
available national data (see fig. 1). This increase may be due in part
to the increase in the number of schools required to offer SES over
that time period. Specifically, between 2004-2005 and 2005-2006 the
number of schools required to offer SES increased from an estimated
4,509 to 6,584.[Footnote 8]
Figure 1: Number of Students Receiving SES Nationwide (2002-2003 to
2004-2005):
[See PDF for image]
Source: Education's NCLBA Consolidated State Performance Reports and
GAP state survey.
Note: Certain states did not submit SES recipient information to
Education through their NCLBA Consolidated State Performance Reports
for all years. Specifically, 2002-2003 data from Kansas and North
Dakota, 2003-2004 data from Pennsylvania, and 2004-2005 data from New
Jersey are not included in the figure. In addition, 2002-2003 data from
New York only include information from New York City.
[End of figure]
Although nationally SES participation is increasing, some districts
required to offer SES have no students receiving services.
Specifically, we estimate that no students received services in about
20 percent of the approximately 1,000 districts required to offer SES
in 2004-2005. A majority of these districts were rural or had a total
enrollment of fewer than 2,500 students. Our survey did not provide
sufficient information to explain why these districts had no students
receiving services in 2004-2005; therefore, it is unclear whether their
lack of participation was related to district SES implementation or
other issues.
Nationwide, we estimate that districts required to offer SES spent the
equivalent of 5 percent of their total Title I funds for SES in 2004-
2005 excluding administrative expenditures. Districts set aside an
amount equal to 20 percent of their Title I funds for SES and choice-
related transportation at the beginning of the school year, and the
proportion of the set-aside spent on SES varied by district.
Specifically, in 2004-2005, about 40 percent of districts spent 20
percent or less of the set-aside to provide SES and almost one-fifth of
districts spent over 80 percent.[Footnote 9] Nationwide, of the total
amount districts set-aside for SES, we estimate they spent 42 percent
on SES, excluding administrative expenditures.
Further, an estimated 16 percent of districts reported that the
required Title I set-aside was not sufficient to fund SES for all
eligible students whose parents requested services. For example, during
our site visit to Newark, N.J., district officials reported budgeting
the entire 20 percent Title I set-aside to fund SES in 2004-2005, but
with this amount of funding, the district was only able to fund SES for
17 percent of the students eligible for services. In addition,
according to Chicago, Ill., district officials, the district budgeted
the entire 20 percent Title I set-aside to fund SES in 2005-2006, and
because parents' demand for services significantly exceeded the amount
of funding available, the district also allocated $5 million in local
funds to provide SES.
While approximately 1,000 of the over 14,000 districts nationwide were
required to offer SES in 2004-2005, SES recipients are concentrated in
a small group of large districts, as 56 percent of recipients attended
school in the 21 districts required to offer SES with more than 100,000
total enrolled students (see fig. 2). Further, states ranged from
having 0 districts to 257 districts required to offer SES in 2004-2005,
with most states having fewer than 10 districts required to offer SES.
State differences in the number of districts required to offer SES may
have resulted from differences in performance or differences in state
proficiency standards and methods used to measure adequate yearly
progress.
Figure 2: School Districts Required to Offer SES in 2004-2005:
[See PDF for image]
Source: GAO.
[End of figure]
Students receiving SES in 2004-2005 shared certain characteristics, as
districts reported that most students receiving services were among the
lower achieving students in school. Specifically, an estimated 91
percent of the districts that reviewed the academic records of students
receiving SES classified most or all of the students receiving SES as
academically low achieving.[Footnote 10] For example, Hamilton County,
Tenn., school officials said that students receiving SES are frequently
behind grade level in their skills and require special attention to
increase their academic achievement.
Further, we estimate that over half of SES recipients were elementary
school students in the majority of districts and about 60 percent of
schools required to offer SES in 2004-2005 were elementary
schools.[Footnote 11] Districts varied in the percentage of students
with limited English proficiency receiving services. In about one-third
of districts, less than 5 percent of SES recipients were students with
limited English proficiency; however, in about one-fifth of districts,
over half of SES recipients were students with limited English
proficiency. Students with disabilities made up less than 20 percent of
students receiving services in about two-thirds of districts. Finally,
in some districts, the majority of SES recipients were African-American
or Hispanic. In about 40 percent of districts, over half of SES
recipients were African-American, and in about 30 percent of districts,
over half of SES recipients were Hispanic. Because we were unable to
obtain comparable data on the characteristics of Title I students
enrolled in these districts in 2004-2005, we were unable to determine
whether certain groups of students were underserved.
We estimate that about 2,800 providers delivered services to students
nationwide in 2004-2005, and more providers were available to deliver
services in the districts with the largest student
enrollments.[Footnote 12] Specifically, about 80 percent of districts
had between 1 and 5 providers delivering services in 2004-2005.
However, the number of providers delivering services in the 21
districts with more than 100,000 total enrolled students ranged from 4
to 45, and averaged 15 providers per district in 2004-2005.
Districts Used Several Methods to Contact Parents and Offered Services
on School Campuses and at Various Times to Increase Participation:
Districts have taken multiple actions to encourage participation, as
shown in table 3. In line with the federal statutory requirement that
districts notify parents in an understandable format of the
availability of SES, over 90 percent of districts provided written
information in English, held individual meetings with parents, and
encouraged school staff to talk with parents about SES. Some districts
collaborated with providers to notify parents. For example, during our
site visit, Illinois state officials described a provider and district
sharing administrative resources to increase participation, which
involved the provider printing promotional materials and the district
addressing and mailing the materials to parents. In addition, we
estimate that over 70 percent of districts lengthened the period of
time for parents to turn in SES applications, held informational events
for parents to learn about providers, and provided written information
to parents in languages other than English. During our site visit to
Woodburn, Ore., district officials reported extending the time parents
had to sign up their children for SES and hosting an event where
providers presented their programs to parents in English and Spanish.
Further, Newark, N.J., district officials told us during our site visit
that the district provided transportation for parents to attend
informational events to increase participation. Also to encourage
participation, an estimated 90 percent of districts offered services at
locations easily accessible to students, such as on or near the school
campus, and almost 80 percent of districts offered services at a
variety of times, such as before and after school or on weekends. For
example, Hamilton County, Tenn., worked with providers to offer an
early morning tutoring program located at the school site in addition
to providing services after school. Providers also reported delivering
SES on school campuses and at various times. Specifically, over three-
fourths of the 22 providers we interviewed reported delivering services
at the school site, although providers also offered services off-site,
such as in the home, online, or at the provider's facility. In
addition, providers generally delivered SES after school and some also
offered SES at alternative times, such as before school, on weekends,
or during the summer. Finally, about one-third of districts provided or
arranged for transportation for participating students or worked with a
local community partner to raise awareness of the services. For
example, in Newark, N.J., the district worked with a local community
organization to inform parents and students living in public housing
and homeless shelters about SES.
Table 3: District Actions Taken to Encourage SES Participation (2005-
2006):
Action taken during the 2005-2006 school year: Provided written
information in English to parents;
Estimated percentage of districts: 99.
Action taken during the 2005-2006 school year: Held individual meetings
and/or phone conversations with interested parents;
Estimated percentage of districts: 95.
Action taken during the 2005-2006 school year: Encouraged principals,
teachers, or other school staff to talk with parents;
Estimated percentage of districts: 93.
Action taken during the 2005-2006 school year: Offered supplemental
services in locations that are easily accessible to students after
school (e.g., on or near the school campus);
Estimated percentage of districts: 90.
Action taken during the 2005-2006 school year: Offered SES at a variety
of times (e.g., after school, weekends, summer break);
Estimated percentage of districts: 79.
Action taken during the 2005-2006 school year: Lengthened the period of
time parents have to submit applications for SES;
Estimated percentage of districts: 79.
Action taken during the 2005-2006 school year: Held events where
parents of eligible students can learn about providers;
Estimated percentage of districts: 78.
Action taken during the 2005-2006 school year: Provided written
information in language(s) other than English about SES to parents;
Estimated percentage of districts: 72.
Action taken during the 2005-2006 school year: Made public
announcements (e.g., television, billboards, newspaper ads, school
newsletters);
Estimated percentage of districts: 67.
Action taken during the 2005-2006 school year: Worked with a local
community partner to raise awareness of SES (e.g., Parent Information
Resource Center);
Estimated percentage of districts: 39.
Action taken during the 2005-2006 school year: Provided or arranged for
transportation of students receiving SES to off-site providers;
Estimated percentage of districts: 33.
Source: GAO.
[End of table]
States also reported taking actions to increase participation in 2005-
2006, as shown in table 4. Regarding parent notification, all states
encouraged district staff to communicate with parents about SES. In
addition, almost 90 percent of states provided guidance to districts on
the use of school campuses for service delivery to encourage
participation.
Table 4: State Actions Taken to Encourage SES Participation (2005-
2006):
Action taken during the 2005-2006 school year: Encouraged district
superintendents, supplemental educational services coordinators, or
other district staff to talk with parents about supplemental
educational services;
Percentage of states: 100.
Action taken during the 2005-2006 school year: Increased the number of
approved providers;
Percentage of states: 94.
Action taken during the 2005-2006 school year: Provided guidance to
districts on the use of school sites to deliver supplemental
educational services;
Percentage of states: 87.
Action taken during the 2005-2006 school year: Increased the number of
approved providers that offer supplemental educational services online;
Percentage of states: 73.
Action taken during the 2005-2006 school year: Worked with a local
community partner to raise awareness of SES (e.g., Parent Information
Resource Center);
Percentage of states: 40.
Action taken during the 2005-2006 school year: Made public
announcements (e.g., television, billboards, newspaper ads);
Percentage of states: 23.
Source: GAO.
[End of table]
Remaining Challenges Include Notifying Parents in a Timely and
Effective Manner and Attracting More Providers for Certain Areas and
Students:
Despite some districts' promising approaches to encourage
participation, notifying parents in a timely manner remains a challenge
for some districts. An estimated 58 percent of districts did not notify
parents that their children may be eligible to receive SES before the
beginning of the 2005-2006 school year, which may be due in part to
delays in states reporting which schools were identified for
improvement.[Footnote 13] Specifically, about half of districts that
did not notify parents before the beginning of the 2005-2006 school
year did not receive notification from the state of the schools
identified for improvement by that time.[Footnote 14] Moreover,
district officials in three of the states we visited experienced delays
in receiving school improvement information, and state officials agreed
that providing timely information about whether schools have met state
performance goals has been a challenge. Almost all of the districts
that did not notify parents before the beginning of the 2005-2006
school year did so within the first 2 months of the year.[Footnote 15]
Effectively notifying parents is also a challenge for some districts.
For example, officials in all four districts we visited reported
difficulties contacting parents to inform them about SES in part
because some families frequently move and do not always update their
mailing address with districts. In addition, some providers we
interviewed indicated that confusing parental notification letters do
not effectively encourage SES participation. For example, some of the
providers we interviewed said some districts use confusing and poorly
written letters to inform parents of SES or send letters to parents of
eligible children but conduct no further outreach to encourage
participation in SES. Four of the providers we interviewed also
indicated that complicated district enrollment processes can discourage
participation. For example, one provider said certain districts send
parents multiple documents to complete in order for their child to
receive SES, such as an enrollment form to select an SES provider and a
separate contract and learning plan.
Another challenge to increasing SES participation is attracting more
SES providers for certain areas. Some rural districts surveyed
indicated that no students received services last year because of a
lack of providers in the area.[Footnote 16] We estimate that the
availability of transportation for students attending supplemental
services was a moderate, great or very great challenge for about half
of rural districts.[Footnote 17] For example, one rural district
commented in our survey that there are no approved providers within 200
miles of its schools. A few other rural districts commented in our
survey that it was difficult to attract providers to their area because
there were few students to serve or providers had trouble finding staff
to serve as tutors.
In addition, ensuring there are providers to serve students with
limited English proficiency or disabilities has been a challenge for
some districts. There were not enough providers to meet the needs of
students with limited English proficiency in an estimated one-third of
districts, and not enough providers to meet the needs of students with
disabilities in an estimated one-quarter of districts. Many states also
indicated that the number of providers available to serve these groups
of students was inadequate. While over half of the providers we
interviewed reported serving students with limited English proficiency
or disabilities, some providers served these students on a limited
basis and reported difficulties meeting their needs. For example, one
provider reported serving few students with limited English proficiency
and disabilities because the amount of funding the provider receives
for SES was not sufficient to pay for specialized tutors to serve these
students. Another provider said it was difficult to find tutors to meet
the needs of students with limited English proficiency and its program
was not designed for students with disabilities. Another provider said
that it was difficult to serve students with disabilities because it
required significantly modifying the tutoring lessons to meet their
needs.
Encouraging student attendance has also been a challenge, in part
because students may participate in other afterschool activities, such
as sports or work. Low parent and student demand for SES has been a
challenge in about two-thirds of districts. For example, about one-
quarter of districts reported that both competition from other
afterschool programs and the availability of services that are engaging
to students were challenges to implementing SES. In addition,
providers, district and school officials in all four districts we
visited told us that SES is competing for students with extracurricular
and other activities. For example, a Chicago, Ill., high school
official indicated that student attendance at SES sessions declined
significantly as the school year progressed. To address this problem,
providers sometimes offer students incentives for participation. For
example, while 2 of the 22 providers we interviewed offered incentives
for students to sign up for services, 19 providers used incentives to
encourage student attendance, such as school supplies and gift
certificates.
Providers Have Taken Steps to Deliver Quality Services, but Contracting
and Coordination Remain Challenges to Working with Districts and
Schools:
To promote improved student academic achievement, providers aligned
their curriculum with district instruction primarily by hiring district
teachers and communicating with the teachers of participating students.
Providers reported communicating with teachers and parents in person as
well as mailing information and progress reports to them; however,
districts indicated the extent of provider efforts varied, as some did
not contact teachers and parents in 2004-2005. In addition, both
providers and districts experienced contracting and coordination
difficulties. In part because SES is often delivered in school
facilities, providers and officials in the districts and schools we
visited reported that involvement of school administrators and teachers
can improve SES delivery and coordination.
Providers Worked to Align Curriculum and Communicate with Parents,
though the Extent of Their Efforts Varied:
In order to increase student academic achievement, providers took steps
to align their curriculum with school instruction by hiring and
communicating with teachers, though the extent of their efforts varied.
A majority of the 22 providers we interviewed hired certified teachers
in the district as tutors. Some providers said hiring district teachers
promoted curriculum alignment, in part because district teachers were
apt to draw on district curriculum during tutoring sessions. School
officials in three of our site visits also said providers' use of
district teachers as tutors helped to align the tutoring program with
what the student learned in the classroom. In addition, some providers
reported aligning curriculum by communicating with the teachers of
participating students to identify student needs and discuss progress.
The frequency of contact between tutors and teachers ranged from
mailing teachers information once prior to the beginning of the program
to contacting teachers at least weekly, according to the providers we
interviewed. A few providers also used other methods to align their
curriculum with district instruction, such as using the same tests to
evaluate student progress and allowing principals to choose components
of the tutoring curriculum for students receiving SES in their schools.
However, not all providers worked with schools to align curriculum, as
we estimate that some, most, or all providers did not contact teachers
to align curriculum with school instruction in almost 40 percent of
districts in 2004-2005. For example, Woodburn, Ore., district and
school officials indicated during our site visit that instead of
aligning their services with the district curriculum, certain providers
openly questioned the district's curriculum and teaching methods, which
caused confusion among some parents and students.
Providers reported mailing information as well as meeting with parents
over the phone and in-person to communicate about student needs and
progress;
however, the frequency of communication with parents varied by
provider. A majority of the providers we interviewed communicated with
parents about student progress repeatedly, sometimes by sending home
progress reports on a monthly basis or holding parent-tutor
conferences. The frequency of contact between tutors and parents
reported by the 22 providers we interviewed ranged from meeting with
parents twice during the tutoring program to giving parents a weekly
progress report. A few providers also reported communicating with
parents by holding workshops for parents to learn about the SES program
and in some cases having the parents sign their students' learning
plans. For example, one provider conducted workshops where parents
received reading materials to share with their children and a parent
guide in English and Spanish that explained the program and how to use
the materials to enhance student learning. Some providers also reported
hiring staff dedicated in part to maintaining communication with
parents. However, some providers faced difficulties when communicating
with parents about SES, such as language barriers or incorrect contact
information. Districts confirmed that the degree to which providers
communicated with parents varied, as we estimate that some, most, or
all providers did not contact parents to discuss student needs and
progress in about 30 percent of districts in 2004-2005.
Despite these challenges, most districts had positive relationships
with providers. Specifically, an estimated 90 percent of districts
indicated that their working relationships with providers during 2004-
2005 were good, very good, or excellent. In addition, many of the
providers we interviewed during our site visits also reported having
positive working relationships with district officials. Although other
studies have found that districts reported certain difficulties working
with providers, relatively few districts reported that their providers
signed up ineligible students or billed for services not performed in
2004-2005, as shown in figure 3.
Figure 3: Estimated Percentage of Districts Experiencing Certain Issues
with None, Few, Some, Most, or All of Their Providers in 2004-2005:
[See PDF for image]
Source: GAO.
[End of figure]
Generally, states did not hear about these provider issues very often.
Almost half of states said the issue of providers not showing up for
SES sessions was rarely brought to their attention.[Footnote 18]
Similarly, half of states said the issue of providers billing the
district for services not performed was rarely brought to their
attention. In addition, about 40 percent of states said the issue of
providers using excessive incentives was rarely brought to their
attention. Further, about 40 percent of states said the issue of
providers signing up ineligible students rarely arose. Almost one-third
of states heard about each of these issues sometimes, while few states
had these issues brought to their attention very often. For example,
during our site visits, state officials provided examples of issues
that had been brought to their attention regarding provider practices,
but these issues were often isolated incidents particular to one or a
few providers in certain districts.
Providers and Districts Experienced Contracting and Coordination
Difficulties:
While providers have taken steps to deliver quality services, both
providers and districts reported experiencing difficulties during the
contracting process. For example, some of the providers we interviewed
said certain districts imposed burdensome contract requirements, such
as requiring substantial documentation to be submitted with invoices,
limiting the marketing they could do to parents and students, or
restricting the use of school facilities to deliver services.
Specifically, 7 of the 22 providers we interviewed experienced
difficulties with districts restricting provider access to school
facilities, by for example, not allowing providers to deliver services
in school buildings or by charging providers substantial fees to do so.
A few providers also said contracting with districts was a resource-
intensive process, in part because contract requirements vary by
district and state. Some of the multi-state providers we interviewed
reported dedicating a team of staff to help them finalize and manage
contracts with districts. These providers commented that, while they
have the administrative capacity to manage this process, smaller
providers may not have such capacity. In addition, one provider that
delivered services exclusively online commented that contracting with
districts across the country was a challenge, particularly because some
states and districts require provider representatives to attend
meetings in-person and be fingerprinted in their states.
Contracting with providers was also a challenge for some districts.
Specifically, negotiating contracts with providers was a moderate,
great, or very great challenge in about 40 percent of districts
nationwide. For example, Woodburn, Ore., district officials described
having contractual discussions with providers around whether the
district would charge fees for the use of school facilities, the types
of incentives providers could use to encourage students to sign up, and
whether the district would pay for services when students did not
attend SES sessions. While states may review and define program design
parameters as part of the provider approval process, district officials
in three of our site visits expressed concern about their lack of
authority to set parameters in provider contracts around costs and
program design, such as tutor-to-student ratios and total hours of
instruction. For example, during our site visit, a Hamilton County,
Tenn., district official expressed frustration with providers that
charged the maximum per-pupil amount but varied in the level of
services provided, such as the number of instructional hours and tutor-
to-student ratio. Chicago, Ill., district officials also expressed
concern about the variation among providers in the hours of instruction
and cost of services because the district does not have sufficient
funds to serve all eligible students and officials would like to
maximize the number of students they can serve. In part to help address
district concerns, in 2005-2006, Illinois required approved providers
to submit information on the cost of providing services in each of the
districts they served and made this information available to districts
and the public in order to improve transparency and accountability.
While Tennessee state officials told us they were hesitant to set
restrictions on providers and would like more federal direction on this
issue, other states have set restrictions on the cost and design of SES
programs. For example, Georgia set a maximum tutor-to-student ratio of
1:8 for non-computer based instruction and 1:10 for computer based
instruction, and New Mexico adopted a sliding fee scale based on the
educational level of tutors.
Coordination of service delivery has also been a challenge for
providers, districts, and schools. About 70 percent of states reported
that the level of coordination between providers, districts, and
schools implementing SES was a moderate to very great challenge.
Sometimes these coordination difficulties have resulted in service
delays. For example, services were delayed or withdrawn in three of the
districts we visited because not enough students signed up to meet the
providers' enrollment targets and districts were not aware of these
targets.[Footnote 19] In one district we visited, services were delayed
because school teachers hired to be tutors did not provide evidence of
their background checks and teaching certificates to providers in a
timely manner. Coordination difficulties also occurred during the
enrollment process. Though districts are responsible for arranging SES
for eligible students, in two districts we visited, both the district
and providers sent parents enrollment forms, which caused confusion
among parents as well as additional work for the district staff
processing the forms. In addition, a few providers told us they do not
know how many students they will serve until enrollment forms are
returned to district officials, which hinders planning and may delay
services since they do not know how many tutors they will need to hire
and train to deliver SES in each district.
Providers, District and School Officials Reported That a Greater Role
for Schools Would Improve Local SES Implementation:
In part because SES can be delivered in school facilities, providers
and officials in the districts and schools we visited reported that
involvement of school administrators and other staff improves SES
implementation. Although schools do not have federally-defined
responsibilities for administering SES, many officials said SES
implementation is hindered when school officials are not involved. Some
providers we interviewed said that a lack of involvement of school
principals can make it difficult for them to coordinate with schools to
encourage student participation. In addition, a few providers said
certain districts contributed to this problem by restricting
communication with school officials or not defining a role for schools
in SES implementation. Officials in one of the districts we visited
also told us that encouraging participation and administering the
program was more difficult when they did not designate school staff to
assist the district with SES implementation. School officials from all
four of our site visits also said the lack of a clear role for school
officials, including principals, in administering SES has been a
challenge. For example, Illinois and Oregon school principals told us
they found it difficult to manage afterschool activities because they
didn't have sufficient authority to oversee SES tutors operating in
their buildings at that time. Further, problems can arise when school
officials are not fully informed about the SES program. For example,
Woodburn, Ore., school officials told us that although the school was
not provided SES tutoring schedules for students, parents and students
have come to school officials for help when they were unclear about the
schedule or when tutors failed to show up.
A majority of the providers we interviewed told us that involvement of
school principals can improve participation and make it easier to
deliver services, in part because principals are familiar with the
students and manage school staff. For example, certain providers
reported providing principals with information about the tutoring
program so that school staff can assist with the enrollment process,
involving principals in selecting the curriculum used in their schools,
and sending principals student progress reports. In addition, all four
districts we visited had school site coordinators to assist with SES,
such as helping with the enrollment process and assisting with the day-
to-day administration of the SES program in the schools. For example,
Woodburn, Ore., district officials told us implementation improved when
the district designated school site coordinators to assist with
parental notification and events where providers present their
programs, and meet with parents and providers to help them complete
individual student learning plans. A few providers we interviewed also
assigned a staff person at the school site to communicate with teachers
and parents. While helping to administer the SES program adds
additional administrative burden on schools, school officials in all
four of the districts we visited said they welcomed a stronger or more
clearly defined role.
States' SES Monitoring Has Been Limited Though Their Efforts Are
Increasing, and Many States Struggle to Develop Meaningful Evaluations:
While state monitoring of SES had been limited, more states reported
taking steps to monitor both district and provider efforts to implement
SES in 2005-2006. In addition, districts have taken a direct role in
monitoring providers, and their monitoring activities similarly
increased during this time. Although states are required to withdraw
approval from providers that fail to increase student academic
achievement for 2 years, many states reported challenges evaluating SES
providers. In addition, the few states that have completed an
evaluation have not yet produced reports that provided a conclusive
assessment of SES providers' effect on student academic achievement.
More States Reported Conducting On-Site Reviews of Districts in 2005-
2006, and Many also Collected Information from Other Sources to Monitor
District SES Implementation:
State monitoring of district SES implementation, which is sometimes
performed as part of state Title I monitoring, had been limited prior
to 2005-2006, though more states reported conducting on-site reviews of
districts in that year. While less than one-third of states conducted
on-site reviews of districts to monitor their implementation of SES in
2004-2005, almost three-fourths reported conducting such reviews in
2005-2006. This increase reflects both those states that had already
begun monitoring district SES implementation for 2005-2006 at the time
of our survey and those states planning to conduct monitoring
activities before the end of that school year. Because our data were
collected during the middle of the 2005-2006 school year, we do not
know whether all of the states that planned to complete these
activities before the end of the year did so. In both years, a majority
of the states that conducted on-site reviews visited few or some of
their districts. Therefore, while more states reported conducting such
reviews in 2005-2006 than in 2004-2005, the number of districts per
state receiving reviews does not appear to have increased.
In addition to on-site reviews, many states also reported reviewing
information collected from several other sources to assess district SES
implementation in 2005-2006. The most common source used by states was
district officials, as almost all states reported reviewing or planning
to review information collected from district officials to monitor
their implementation of SES in 2005-2006. Further, many states were
also collecting information from school principals, parents, and
providers to monitor districts, with between 67 and 81 percent of
states reviewing or planning to review information collected from these
sources in 2005-2006.
States also reported reviewing or planning to review information
related to several aspects of district SES implementation in 2005-2006.
For example, almost all states reported reviewing district notification
of parents and SES expenditures, as shown in figure 4.
Figure 4: Percentage of States That Reviewed Specific Program Elements
to Monitor District SES Implementation in 2005-2006:
[See PDF for image]
Source: GAO.
Note: The percentage of states that did not review or plan to review
these program elements to monitor district SES implementation in 2005-
2006 and the percentage of states that did not answer these survey
questions are not shown in this figure.
[End of figure]
States we visited reported that some districts have had difficulties
implementing SES, in part because of district staff capacity
limitations and the complexities of administering SES at the local
level. When states find that a district is having difficulty
implementing SES, most hold a meeting with the district and provide or
arrange for assistance, including consultations or training. Half of
the states also develop an action plan and time line with the district
to help improve its efforts. During our site visits, state officials
reported that notifying parents, maintaining a fair and competitive
environment for providers, ensuring providers understand their SES
roles and responsibilities, and determining an appropriate role for
schools continue to challenge some districts as they implement SES.
Though States and Districts Are Challenged to Monitor Providers, They
Are Moving from Limited Monitoring of Providers to a More Active
Approach:
Although states and districts reported increasing their efforts to
monitor SES providers between 2004-2005 and 2005-2006, over two-thirds
of states reported that on-site monitoring of providers has been a
challenge. In addition, several districts commented in our survey that
more provider monitoring is needed. During all four of our site visits,
state and district officials expressed concerns about their capacity to
fully administer and oversee all required aspects of SES
implementation, including provider monitoring. Officials explained that
state and district capacity to implement SES is limited, because there
is typically one staff person at each level coordinating all of SES,
and sometimes that person may also oversee implementation of additional
federal education programs. Further, several states commented in our
survey that additional training, technical assistance, and national
monitoring protocols from the federal government would assist their
efforts to monitor providers.
During our site visits, state officials noted that while they did not
initially have structured plans or procedures in place to monitor SES
providers, they took steps to develop and formalize procedures starting
with the 2004-2005 and 2005-2006 school years. Nationally, in 2004-
2005, states monitored providers primarily by collecting data from
district officials, though many states reported using a more active
monitoring approach in the next year. For example, while less than one-
third of states conducted on-site reviews of providers in 2004-2005,
over three-fourths had conducted or planned to conduct such reviews in
2005-2006, as shown in figure 5. In addition, while one-third or fewer
states reviewed information collected from school staff, parents, and
students in 2004-2005, the percentage that reported reviewing or
planning to review information collected from these sources more than
doubled the next year. Similar to 2004-2005, many states continued to
rely on information collected from district officials to monitor
providers in 2005-2006, with almost all states reviewing or planning to
review information collected from districts in that year.
Figure 5: Percentage of States Reviewing Information Collected from
Different Sources to Monitor SES Providers in 2004-2005 and 2005-2006:
[See PDF for image]
Source: GAO.
Note: The percentage of states that did not review or plan to review
information collected from these sources to monitor providers in each
year and the percentage of states that did not answer these survey
questions are not shown in this figure.
[End of figure]
Federal guidance suggests states may request district assistance in
collecting data from providers to assist state monitoring activities.
While the state is ultimately responsible for monitoring providers,
most states reported that districts have taken a direct role in
monitoring providers. Similar to states, although district monitoring
of providers was limited in 2004-2005, districts used a more extensive
and active approach in the next year, as shown in figure 6.[Footnote
20] For example, while we estimate that less than half of districts
collected information from on-site reviews, school staff, parents, and
students to monitor providers in 2004-2005, 70 percent or more were
collecting or planning to collect information from these sources in
2005-2006.
Figure 6: Estimated Percentage of Districts Reviewing Information
Collected from Different Sources to Monitor SES Providers in 2004-2005
and 2005-2006:
[See PDF for image]
Source: GAO.
[End of figure]
Although states and districts collected information from similar
sources to monitor providers, districts collected information from more
providers than states. Specifically, while a majority of the states
that conducted on-site reviews observed only some or few providers, we
estimate that a majority of districts that conducted on-site reviews
observed most or all of their providers in 2004-2005.[Footnote 21]
While states and districts may both have capacity limitations that
affect their ability to conduct on-site reviews to monitor providers,
conducting such reviews is likely easier for districts because services
are often delivered on or near school campuses.
States and districts collected information on several aspects of SES
programs to monitor providers, as shown in table 5. While federal
regulations provide states flexibility to design their own SES
monitoring systems, over two-thirds or more of states and districts
monitored or planned to monitor all program elements listed, including
those related to service delivery and use of funds. For example, 94
percent of states monitored or planned to monitor parent or student
satisfaction with providers, and 93 percent of districts monitored or
planned to monitor billing and payment for services and student
attendance records.
Table 5: Percentage of States and Districts That Reviewed Specified
Program Elements to Monitor Providers in 2005-2006:
Program element: Parent/student satisfaction with a provider;
Percentage of states: Monitored: 27;
Percentage of states: Planned to monitor: 67;
Percentage of states: Monitored or planned to monitor: 94;
Estimated percentage of districts: Monitored: 34;
Estimated percentage of districts: Planned to monitor: 57;
Estimated percentage of districts: Monitored or planned to monitor: 91.
Program element: Provider communication with teachers and parents;
Percentage of states: Monitored: 37;
Percentage of states: Planned to monitor: 56;
Percentage of states: Monitored or planned to monitor: 92;
Estimated percentage of districts: Monitored: 46;
Estimated percentage of districts: Planned to monitor: 43;
Estimated percentage of districts: Monitored or planned to monitor: 89.
Program element: Extent to which a provider's program, as enacted,
reflects its program design, as outlined in its application to your
state;
Percentage of states: Monitored: 19;
Percentage of states: Planned to monitor: 73;
Percentage of states: Monitored or planned to monitor: 92;
Estimated percentage of districts: Monitored: 30;
Estimated percentage of districts: Planned to monitor: 41;
Estimated percentage of districts: Monitored or planned to monitor: 70.
Program element: Evidence of meeting academic achievement goals as
stated on student learning plan;
Percentage of states: Monitored: 23;
Percentage of states: Planned to monitor: 65;
Percentage of states: Monitored or planned to monitor: 88;
Estimated percentage of districts: Monitored: 28;
Estimated percentage of districts: Planned to monitor: 60;
Estimated percentage of districts: Monitored or planned to monitor: 88.
Program element: Evidence of improved student achievement based on any
statewide assessment;
Percentage of states: Monitored: 15;
Percentage of states: Planned to monitor: 71;
Percentage of states: Monitored or planned to monitor: 87;
Estimated percentage of districts: Monitored: 26;
Estimated percentage of districts: Planned to monitor: 65;
Estimated percentage of districts: Monitored or planned to monitor: 91.
Program element: Alignment of provider curriculum with district/school
curriculum or instruction;
Percentage of states: Monitored: 25;
Percentage of states: Planned to monitor: 62;
Percentage of states: Monitored or planned to monitor: 87;
Estimated percentage of districts: Monitored: 35;
Estimated percentage of districts: Planned to monitor: 39;
Estimated percentage of districts: Monitored or planned to monitor: 74.
Program element: Student attendance records;
Percentage of states: Monitored: 27;
Percentage of states: Planned to monitor: 56;
Percentage of states: Monitored or planned to monitor: 83;
Estimated percentage of districts: Monitored: 67;
Estimated percentage of districts: Planned to monitor: 25;
Estimated percentage of districts: Monitored or planned to monitor: 93.
Program element: Evidence of improved student achievement based on
provider assessments;
Percentage of states: Monitored: 27;
Percentage of states: Planned to monitor: 56;
Percentage of states: Monitored or planned to monitor: 83;
Estimated percentage of districts: Monitored: 39;
Estimated percentage of districts: Planned to monitor: 52;
Estimated percentage of districts: Monitored or planned to monitor: 91.
Program element: Protection of student privacy;
Percentage of states: Monitored: 33;
Percentage of states: Planned to monitor: 50;
Percentage of states: Monitored or planned to monitor: 83;
Estimated percentage of districts: Monitored: 55;
Estimated percentage of districts: Planned to monitor: 28;
Estimated percentage of districts: Monitored or planned to monitor: 82.
Program element: Adherence to applicable health, safety, and civil
rights laws;
Percentage of states: Monitored: 29;
Percentage of states: Planned to monitor: 48;
Percentage of states: Monitored or planned to monitor: 77;
Estimated percentage of districts: Monitored: 48;
Estimated percentage of districts: Planned to monitor: 26;
Estimated percentage of districts: Monitored or planned to monitor: 74.
Program element: Provider financial stability (e.g., audits, financial
statements);
Percentage of states: Monitored: 31;
Percentage of states: Planned to monitor: 42;
Percentage of states: Monitored or planned to monitor: 73;
Estimated percentage of districts: Monitored: N/ A;
Estimated percentage of districts: Planned to monitor: N/A;
Estimated percentage of districts: Monitored or planned to monitor: N/
A.
Program element: Evidence of improved student achievement based on
grades, promotion, and/or graduation;
Percentage of states: Monitored: 12;
Percentage of states: Planned to monitor: 58;
Percentage of states: Monitored or planned to monitor: 69;
Estimated percentage of districts: Monitored: 23;
Estimated percentage of districts: Planned to monitor: 57;
Estimated percentage of districts: Monitored or planned to monitor: 80.
Program element: Billing and payment for services;
Percentage of states: Monitored: N/A;
Percentage of states: Planned to monitor: N/A;
Percentage of states: Monitored or planned to monitor: N/A;
Estimated percentage of districts: Monitored: 72;
Estimated percentage of districts: Planned to monitor: 21;
Estimated percentage of districts: Monitored or planned to monitor: 93.
Source: GAO.
Note: The percentage of states that did not review or plan to review
these program elements to monitor providers in 2005-2006 and the
percentage of states that did not answer these survey questions are not
shown in this table. In addition, we did not ask states if they
monitored billing and payment for services, and we did not ask
districts if they monitored provider financial stability.
[End of table]
Many States Struggle to Develop Meaningful Evaluations, and the Few
State Evaluations Completed to Date Were Inconclusive:
Many states struggle to develop evaluations to determine whether SES
providers are improving student achievement, though states are required
to evaluate and withdraw approval from providers that fail to do so
after 2 years. Specifically, federal law requires states to develop
standards and techniques to evaluate the services delivered by approved
providers, but it does not require states to use specific evaluation
methods or criteria for determining provider effectiveness.[Footnote
22] Through our survey, states reported several challenges to
evaluating SES providers. Specifically, over three-fourths of states
reported that determining sufficient academic progress of students,
having the time and knowledge to analyze SES data, and developing data
systems to track SES information have been challenges. Further, during
our site visits to Illinois and New Jersey, state officials noted they
were currently in the process of improving their data collection
systems to more effectively capture and analyze data for SES
evaluations. In addition, several state officials reported that while
they have collected some information to assess provider effectiveness,
they have done little with that data. Others noted that they have not
received sufficient federal guidance on effective models for SES
provider evaluations, and because developing and implementing such
evaluations can be both time-consuming and costly, additional
assistance from Education would improve their efforts.
At the time of our survey in early 2006, only a few states had drafted
or completed an evaluation report addressing individual SES provider's
effects on student academic achievement, and we found that no state had
produced a report that provided a conclusive assessment of this effect.
New Mexico and Tennessee were the only two states that had completed
final or draft SES evaluation reports that attempted to assess the
impact of all SES providers serving students in their states in
previous years.[Footnote 23] To measure student academic achievement,
New Mexico's report analyzed students' grades as well as their scores
on state assessments and provider assessments, which often differ by
provider and are administered both before SES sessions begin and at the
end of SES sessions each year. However, the report noted that these
assessments produced different results related to student academic
achievement gains. While Tennessee also planned to review students'
state assessment scores, the draft available at the time of our
analysis did not include this information. In addition, both reports
drew on information obtained through other sources, such as teacher
surveys, to assess provider effectiveness. Due to their limitations,
neither evaluation provided a conclusive assessment of SES providers'
effect on student academic achievement.
In addition, at the time of our survey, over half of the states
reported that they were in the process of conducting an evaluation of
SES providers in order to meet the federal requirement of assessing
each provider's effect on student academic achievement.[Footnote 24]
Similar to the state evaluations already undertaken, officials reported
using different methods and criteria to evaluate SES providers. For
example, some states were collecting each provider's pre-and post-SES
assessments of students while others were collecting student
achievement data from districts or students' state assessment scores.
Further, while one state defined adequate student progress as 80
percent of a provider's students making one-grade level of improvement
after a year of SES, another state defined adequate student progress as
50 percent or more of a provider's students having any positive
academic achievement gain after a year of SES. While these states have
yet to produce final results from their SES provider evaluations, it is
unclear whether any of these efforts will produce a conclusive
assessment of SES providers' effect on student academic achievement.
Likely because states are struggling to complete evaluations to assess
SES providers' effect on student academic achievement, states did not
report that they have withdrawn approval from providers because their
programs were determined to be ineffective at achieving this
goal.[Footnote 25] Rather, though over 40 percent of states reported
that they had withdrawn approval from some providers, they most
frequently reported withdrawing provider approval because the provider
was a school or district that had entered needs improvement status, the
provider asked to be removed from the state-approved provider list, or
because of provider financial impropriety.
Several Education Offices Monitor and Support SES Implementation, but
States and Districts Cite the Need for Additional Assistance and
Flexibility:
Several offices within Education monitor various aspects of SES
activity across the country and provide support, but states and
districts reported needing additional assistance and flexibility with
program implementation. Education conducts SES monitoring in part
through policy oversight and compliance reviews of states and
districts, and provides SES support through guidance, grants, research,
and technical assistance. However, many states and districts reported
needing additional assistance and guidance regarding evaluation and
administration of SES. Further, some states and districts voiced
interest in expansion of Education's pilot programs that increase SES
flexibility, including the pilot that allows certain low-achieving
districts to serve as SES providers.
Education Monitors SES and Provides States and Districts with Guidance
and Technical Assistance:
OII and OESE are primarily responsible for monitoring and supporting
state and district SES implementation, and other Education offices also
contribute to these efforts (see fig. 7).
Figure 7: U.S. Department of Education Offices Monitoring and
Supporting SES:
[See PDF for image]
Source: GAO analysis.
Note: This figure reflects the coordination of Education's offices
rather than the statutory reporting relationship. ]
[End of figure]
OII, which leads SES policy development and provides strategic
direction, monitors SES policy issues primarily through what it calls
"desk monitoring." This monitoring is performed at its federal office
and includes the review of SES-related research and media reports. OII
also conducts more intensive monitoring of specific SES implementation
challenges when states, districts, and providers bring them to
Education's attention and keeps a log documenting these issues. For
example, during 2004-2005, Illinois and New Jersey officials contacted
OII to clarify guidance regarding providers affiliated with districts
in need of improvement, and OII staff provided assistance and
clarification. In addition, several providers we interviewed also
mentioned that they have contacted OII directly to discuss
implementation challenges associated with enrollment, district
contracts, and provider access to school facilities.
OESE, which oversees and supports NCLBA implementation, is also
involved in monitoring SES implementation through its overall
monitoring of state compliance with Title I and NCLBA. To monitor Title
I, OESE staff visit state departments of education and selected
districts within each state to interview officials and review relevant
documents. Once the review is complete, OESE issues a report to the
state outlining any instances of Title I non-compliance, including
those related to SES, and actions needed to comply with regulations. As
of June 2006, OESE had visited and issued reports to over three-fourths
of the states.
In addition to its Title I monitoring, OESE also oversees the
collection of state NCLBA data, including data on SES, through the
annual Consolidated State Performance Report (CSPR). For the CSPR, each
state is required to report the number of schools with students
receiving SES, the number of students eligible for services, and the
number that received services.[Footnote 26] However, although almost
all states reported that they are collecting information on district
SES expenditures as part of their oversight, Education does not require
states to submit information on the percent or amount of Title I funds
districts spent for SES through the CSPR or other means. Therefore,
while Education tracks the extent to which states are providing SES to
eligible students, the department does not collect data on the relative
costs of serving them. Further, under NCLBA, Education is required to
present an annual summary of the CSPR data to Congress. As of June
2006, the most recent report to Congress was for the 2002-2003 school
year, though Education officials indicated they expect to submit
reports for 2003-2004 and 2004-2005 in the near future.
While OII and OESE monitoring of SES has been either limited to desk
monitoring or combined with general Title I monitoring, OIG has
conducted audits specifically focused on SES. During 2003-2004 and 2004-
2005, the office performed a series of SES implementation audits in six
states, which involved site visits to state offices and selected
districts within each state.[Footnote 27] Also during 2004-2005, OIG
performed audits of five California districts and one SES provider
within each district.[Footnote 28] These audits included an examination
of district SES contracts with providers, provider services, and
provider compliance with state SES regulations.
Several Education officials reported coordinating internally to share
information, including SES monitoring results. To facilitate
coordination, OII leads an internal group comprised of staff members
from other Education offices, who meet bi-weekly to exchange
information. OESE shares its state Title I monitoring results and CSPR
data with other Education offices. In addition, OIG makes
recommendations to both OII and OESE in its state and district SES
auditing reports and disseminates the reports throughout Education and
on the department's Web site. Since 2002, OII has coordinated the
publication of four versions of non-regulatory SES guidance, each
updated to address ongoing challenges with SES implementation. The
latest and most comprehensive version of non-regulatory SES guidance
was published in June 2005. In May 2006, Education issued a separate
supplement to the guidance containing additional information on private
school participation in providing SES and a policy letter clarifying
the definition of a district-affiliated provider.
In addition to its monitoring efforts, OII also provides SES
implementation assistance, in part through presentations at
conferences, and through grants to external organizations that assist
states and districts. For example, OII staff have presented information
on SES policy and promising practices at national meetings attended by
SES coordinators and others involved in SES implementation. In
addition, the office has issued grants to the Black Alliance for
Educational Options, the Hispanic Council for Reform and Educational
Options, and through the Star Schools Program to promote SES to
minority students and those in rural areas. Further, OII funded the
Supplemental Educational Services Quality Center (SESQC), which offered
SES technical assistance through tool-kits, issue briefs, and a Web
site containing SES information for state and district officials,
schools, parents, and providers. SESQC also periodically convened
representatives of organizations working on education issues to discuss
SES national coordination, challenges, and promising practices.
However, those meetings and all SESQC activities were discontinued in
December 2005 when SESQC's grant period ended.
Other Education offices also provide SES support through various means.
For example, OESE funded the Comprehensive Centers Program through
grants that established technical assistance centers across the country
to help low-performing schools and districts close achievement gaps and
meet the goals of NCLBA. Of these, the Center on Innovation and
Improvement provides support to regional centers that assist states
with Education's programs, including SES. In addition, Education's
Policy and Program Studies Service, within the Office of Planning,
Evaluation and Policy Development, oversees several research studies
that examine SES, either in whole or in part. These reports, such as
the National Assessment of Title I: Interim Report and Case Studies of
Supplemental Services under the No Child Left Behind Act, provide
states and districts with information on SES implementation,
challenges, and promising practices. Further, Education's Center for
Faith-Based and Community Initiatives offers technical assistance to
faith-and community-based organizations interested in becoming state-
approved SES providers.
Given the technical assistance and support Education has already
provided to states and districts for implementation of SES and school
choice, and the department's view that implementation of these
provisions has been uneven throughout the country, in May 2006,
Education issued a policy letter announcing the department's plans to
take significant enforcement action. Specifically, Education plans to
use the data collected through its monitoring and evaluation efforts to
take enforcement actions such as placing conditions on state Title I
grants, withholding federal funds, or entering into compliance
agreements. In the letter, the department noted that its various
monitoring activities have identified several areas of noncompliance
with SES requirements. For example, the OIG's audits found that each of
the six states reviewed failed to adequately monitor their districts
for compliance. Consequently, nearly all of the parental notification
letters reviewed failed to include the required key components, and
several districts failed to budget sufficient funding for services.
Through our own analysis of Education's monitoring reports, we also
found that some of the states reviewed were found to have inadequate or
incomplete processes for monitoring and evaluating SES providers.
Many States and Districts Reported Needing SES Evaluation Support and
Additional Technical Assistance, and Some Suggested Increasing
Flexibility through Education's Pilot Programs:
Despite Education's efforts, many states and districts reported needing
more information and assistance to better comply with certain aspects
of SES implementation, including SES evaluation (see table 6).
Specifically, 85 percent of states and an estimated 70 percent of
districts needed additional assistance with methods for evaluating SES,
and over 60 percent also needed assistance with developing data
systems. Many districts also needed more information on provider
quality and effectiveness. Although OESE and OIG monitoring results
have also continually indicated that states and districts struggle with
SES evaluation, Education has yet to provide comprehensive assistance
in this area, and during our site visits, officials mentioned that they
have been relying on other states, organizations, or individuals for
evaluation assistance. States and districts also indicated a need for
more support and technical assistance to help them administer SES.
Specifically, approximately three-fourths of states and two-thirds of
districts reported needing funding to increase their capacity to
implement SES. Many states also reported needing tool kits and model/
sample documents, as well as training from Education, and a majority of
districts needed effective parent outreach strategies. Further, most
states reported a need for conferences or meetings where they could
share lessons learned and promising practices with other states. A few
Tennessee officials mentioned that conferences hosted by national
organizations have been an effective means of allowing SES officials to
gather and share knowledge.
Table 6: Percentage of States and Districts in Need of Different Types
of Information or Assistance with SES Implementation:
Evaluation information or assistance needed: Methods for evaluating
SES;
Percentage of states: Evaluation information or assistance needed: 85;
Information on provider quality or effectiveness;
Estimated percentage of districts: 78.
Evaluation information or assistance needed: Developing data systems;
Percentage of states: Evaluation information or assistance needed: 71;
Methods for evaluating SES;
Estimated percentage of districts: 70.
Evaluation information or assistance needed: Developing data systems;
Percentage of states: Evaluation information or assistance needed: 71;
Developing data systems for monitoring and evaluation;
Estimated percentage of districts: 64.
Other support or technical assistance needed: Conferences/meetings with
other states to share lessons learned/ promising practices;
Percentage of states: 90;
Funding to increase district capacity to implement SES;
Estimated percentage of districts: 67.
Other support or technical assistance needed: Tool kits and
model/sample documents;
Percentage of states: 85;
Information on effective parent outreach strategies;
Estimated percentage of districts: 61.
Other support or technical assistance needed: Training;
Percentage of states: 85;
Assistance with contract negotiation;
Estimated percentage of districts: 35.
Other support or technical assistance needed: Funding to increase state
capacity to implement SES;
Percentage of states: 77;
[Empty];
Estimated percentage of districts: [Empty].
Other support or technical assistance needed: Approving and monitoring
providers;
Percentage of states: 71;
[Empty];
Estimated percentage of districts: [Empty].
Other support or technical assistance needed: Allowances for SES to be
offered before school choice provisions;
Percentage of states: 58;
[Empty];
Estimated percentage of districts: [Empty].
Other support or technical assistance needed: Clarification of roles
for states, districts, and providers in implementing SES;
Percentage of states: 46;
[Empty];
Estimated percentage of districts: [Empty].
Other support or technical assistance needed: Waivers for states for
exclusion from specific SES provisions;
Percentage of states: 44;
[Empty];
Estimated percentage of districts: [Empty].
Other support or technical assistance needed: Clarification of the 20-
percent set-aside requirements and carryover allowances;
Percentage of states: 44;
[Empty];
Estimated percentage of districts: [Empty].
Source: GAO.
[End of table]
While three-fourths of states reported that the most recent version of
Education's SES guidance, published in June 2005, has been very or
extremely useful, several states commented through our survey that they
needed additional or clearer guidance on certain SES provisions. This
included guidance on managing SES costs and fees, implementing SES in
rural areas, and handling provider complaints. During three of our site
visits, officials also expressed some concern about the lack of clarity
in the SES guidance with regards to student eligibility requirements
and how to craft a parental SES notification letter that is both
complete and easy for parents to understand.
Regarding parental notification letters, though both OESE and OIG found
many states and districts to be non-compliant with the federal
requirement that district SES parental notification letters include
several specific elements,[Footnote 29] Education's SES guidance, which
is coordinated by OII, provides a sample that does not clearly specify
all of the key elements required by SES law and regulations. For
example, the sample letter does not include information on provider
services, qualifications, and effectiveness. Furthermore, a few state
and district officials commented that, when followed, the Title I
regulations governing SES yield a letter that is unreasonably long and
complex, which may be difficult for parents to understand.
Many states and districts expressed interest in the flexibility offered
through two pilot programs that Education implemented during 2005-2006.
The department designed these pilots to increase the number of eligible
students receiving SES and to generate additional information about the
effect of SES on student academic achievement. For example, several
state and district SES coordinators expressed interest in Education's
pilot program that allowed two districts in needs improvement status to
act as SES providers in exchange for their expansion of student access
to SES providers and collection of achievement data to determine SES
program effectiveness. During three of our four site visits, state and
district officials expressed concern that districts identified for
needs improvement are excluded from delivering SES, and one state
official noted that removing districts from the state approved provider
list may result in lower SES participation. Further, in our surveys,
three state SES coordinators and 17 district SES coordinators wrote in
comments that permitting districts in needs improvement status to
provide services would assist their efforts. Through both our surveys
and site visits, officials suggested that allowing districts to act as
providers may ease student access to SES for rural districts that do
not have providers located nearby, allow more students to participate
in SES because district costs to provide services are sometimes lower
than other providers' costs, and enable districts to continue their
existing tutoring programs that they feel are effective and meet the
same goals as SES. Overall, we estimate that 15 percent of districts
were state-approved providers in 2004-2005. However, another national
survey recently found the percentage of urban and suburban districts
that are state-approved SES providers is declining.[Footnote 30]
The other SES pilot allowed four districts in Virginia to offer SES
instead of school choice in schools that have missed state performance
goals for 2 years and are in their first year of needs improvement.
During our site visits and through our surveys, many states and
districts expressed interest in adjusting the order of the SES and
school choice interventions. Specifically, half of states and over 60
percent of districts suggested that SES should be made available before
school choice (see table 7). Further, approximately three-quarters of
both states and districts indicated that SES should be offered either
before or simultaneously with choice. As we found through our previous
work on school choice, few students are opting to transfer schools in
the first year of needs improvement, and therefore this change would
provide students with another option to receive additional academic
support in that year. Further, in a recent national study, district and
school officials noted that parents and students are often not
interested in changing schools, in part because of potential long
commutes and satisfaction with their current schools, which suggests
that parents and students would likely prefer to receive SES in their
own schools and neighborhoods rather than school choice.[Footnote 31]
In line with interest in increased flexibility with these
interventions, in May 2006, Education announced that due to the
positive results in Virginia districts under the pilot, the department
plans to extend and expand this pilot in 2006-2007.
Table 7: State and District Opinion on the Ordering of School Choice
and SES:
In percent: Order of school choice and SES: SES should precede school
choice;
States: 48;
District: 62.
In percent: Order of school choice and SES: Both school choice and SES
should be offered at the same time;
States: 27;
District: 15.
In percent: Order of school choice and SES: School choice should
precede SES;
States: 15;
District: 23.
Source: GAO.
Note: 10 percent of states did not respond or were not sure. In
addition, district percentages are estimates.
[End of table]
Conclusions:
Over the last few years, almost all states and approximately 1,000
districts have been required to implement SES across the country and,
if current trends continue, more schools will be required to offer
services in the future. Although some states and districts are
beginning to gain experience in implementing SES and use promising
approaches to increase SES participation, many students are still not
receiving services, in part because providers are sometimes not
available to serve certain areas and groups. In addition, some
districts are unsure how to involve school officials in facilitating
local coordination of SES implementation and providing effective
parental notification. While Education has provided support to states
and districts through guidance and technical assistance, many report
needing additional assistance to address these challenges. Further, the
lack of clarity between policy guidance issued by OII and criteria used
by OESE in their compliance reviews of states' implementation efforts
creates additional challenges in meeting the federal requirements for
parental notification letters. Providing states with clear guidance
that has been coordinated across Education offices is especially
important now that the department has announced plans to take
significant enforcement actions to ensure states comply with federal
SES requirements.
While some districts do not have any students receiving services and,
therefore, are not spending any Title I funds for SES, other districts
are spending more than their entire set-aside and still have students
on waiting lists to receive services. Two districts have been able to
participate in Education's pilot program waiving federal regulations
that preclude districts in need of improvement from providing SES,
which may help them provide services to more students at a lower cost.
However, extending this flexibility to more districts depends on the
evaluation of the quality of these services to determine if SES is
having a positive impact on student academic achievement. In addition,
the absence of strategies that states can use to set parameters around
program design and costs further hinders their ability to stretch
available funding to serve more students. Federal and state oversight
of district efficiency in using federal funds to provide SES services
is hindered by incomplete reporting requirements that require states to
report on the number of eligible children receiving SES, but not the
data they collect on the amount of Title I funding used to serve them.
This information gap limits Education's ability to track state and
district compliance in spending funds for SES. Further, Education's
ability to ensure that federal dollars are effectively spent to improve
student academic achievement is limited until states increase their
capacity to monitor and evaluate provider performance. In the absence
of additional federal technical assistance and access to information
about state and district promising practices, some states may continue
to struggle with implementation and evaluation of SES.
Recommendations:
To help states and districts implement SES more effectively, we
recommend that the Secretary of Education use the department's Web site
and the Center on Innovation and Improvement, as well as other means of
communication, to:
* Provide federal guidance on SES parental notification letters that is
clear and has been coordinated internally between OII and OESE to
provide additional assistance to states and districts to help them
comply with federal requirements and ensure that letters are easy for
parents to understand. Education might consider providing several
samples of actual district notification letters that meet these
criteria.
* Collect and disseminate information on promising practices used by
states to attract more providers for certain areas and groups and
promising practices used by districts to improve parental notification
of SES services and providers' ability to serve specific groups of
students and to encourage student attendance.
* Provide examples of how districts can involve schools and school
officials to facilitate local coordination with providers.
To improve states' and districts' ability to make the most of funding
for SES and provide services to the maximum number of students, we
recommend that the Secretary of Education:
* Consider expanding the 2005-2006 pilot that allowed two districts in
need of improvement to enter into flexibility agreements to serve as
SES providers if evaluation results show that these districts can
provide quality SES services.
* Clarify what states can do through the provider approval process to
set parameters around program design and costs. For example, Education
could issue guidance to states that clarifies their authority to set
parameters on issues such as minimum hours of SES per student, minimum
tutor qualifications, and cost ranges. In addition, Education could
suggest to states that they coordinate these discussions with districts
to address their concerns about program design and costs.
To improve federal and state monitoring of SES, we recommend that the
Secretary of Education:
* Require states to report information necessary to determine the
amount of funds spent by districts to provide SES and the percentage of
their Title I allocations that this amount represents. Because almost
all states reported that they are planning to monitor district SES
expenditures, Education could require the states to submit these data
through the annual NCLBA Consolidated State Performance Reports.
* Provide states with technical assistance and guidance on how to
evaluate the effect of SES on student academic achievement. For
example, Education might require the Center on Innovation and
Improvement to focus its SES assistance on providing states with
suggested evaluation methods, measures to assess the impact of SES on
achievement, and criteria for using this information to monitor and
withdraw state approval from providers. Further, lessons learned and
promising practices on evaluation could also be shared with states on
the Center on Innovation and Improvement's Web site or during national
or regional meetings, trainings, or conferences.
Agency Comments:
We provided a draft of this report to Education for review and comment.
Educations' written comments are reprinted in appendix II, and the
department's technical comments were incorporated into the report as
appropriate. In its written comments, Education expressed appreciation
for the report's recommendations and cited actions the department has
already initiated or plans to take in addressing them. Specifically,
Education noted several projects under development that might assist in
carrying out our recommendations to provide more assistance to states
on notifying parents, attracting providers for certain areas and
groups, and involving schools. The department also said that is
currently considering expanding the pilot allowing districts in need of
improvement to apply to become SES providers, per our recommendation.
Regarding our recommendation that Education clarify what states can do
to set parameters around program design and costs, Education said it
would consider addressing this issue further in the next set of
revisions to the SES non-regulatory guidance. In addition, Education
said it would address our recommendations to improve federal and state
monitoring of SES by proposing that districts report on their SES
spending and by providing more SES evaluation assistance to states
through an updated issue brief as well as technical assistance provided
by the Comprehensive Center on Innovation and Improvement and at a
conference this fall.
We are sending copies of this report to appropriate congressional
committees, the Secretary of Education, and other interested parties.
Copies will also be made available upon request. In addition, the
report will be available at no charge on GAO's Web site at [Hyperlink,
http://www.gao.gov]. If you or your staff have any questions about the
report, please contact me at (202) 512-7215. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix III.
Signed by:
Marnie S. Shaul:
Director, Education, Workforce, and Income Security Issues:
List of Requesters:
The Honorable Edward M. Kennedy:
Ranking Minority Member:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
The Honorable Christopher J. Dodd:
Ranking Minority Member:
Subcommittee on Education and Early Childhood Development:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
The Honorable Howard "Buck" McKeon:
Chairman:
The Honorable George Miller:
Ranking Minority Member:
Committee on Education and the Workforce:
House of Representatives:
The Honorable Dale E. Kildee:
Ranking Minority Member:
Subcommittee on 21st Century Competitiveness Committee on Education and
the Workforce:
House of Representatives:
The Honorable Lynn C. Woolsey:
Ranking Minority Member:
Subcommittee on Education Reform Committee on Education and the
Workforce:
House of Representatives:
The Honorable Hillary Rodham Clinton:
The Honorable Richard J. Durbin:
The Honorable Charles E. Schumer:
United States Senate:
The Honorable Robert E. Andrews:
The Honorable John A. Boehner:
The Honorable Rahm Emanuel:
The Honorable Betty McCollum:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To obtain nationally representative information on supplemental
educational services (SES) participation, state and local
implementation, and federal oversight, we conducted a Web-based survey
of state SES coordinators and a mail survey of district SES
coordinators from a nationally representative sample of districts with
schools required to offer SES. We also conducted site visits during
which we interviewed state, district, and school officials representing
four school districts, and we conducted interviews with 22 SES
providers both during the site visits and separately. In addition, we
spoke with staff at Education involved in SES oversight and
implementation and reviewed Education's data on SES. We conducted our
work from August 2005 through July 2006 in accordance with generally
accepted government auditing standards.
Survey of States:
To better understand state SES implementation, particularly how states
are monitoring and evaluating SES, we designed and administered a Web-
based survey of state SES coordinators in all 50 states, the District
of Columbia, and Puerto Rico. The survey was conducted between January
and March 2006 with 100 percent of state SES coordinators responding.
The survey included questions about student participation in SES,
actions taken to increase participation, SES funding and expenditures,
methods used to monitor and evaluate implementation, implementation
challenges, and assistance received from Education.
Because this was not a sample survey, there are no sampling errors.
However, the practical difficulties of conducting any survey may
introduce nonsampling errors, such as variations in how respondents
interpret questions and their willingness to offer accurate responses.
We took steps to minimize nonsampling errors, including pre-testing
draft instruments and using a Web-based administration system.
Specifically, during survey development, we pre-tested draft
instruments with officials in Oregon, Maryland, and Washington between
October and November 2005. In the pre-tests, we were generally
interested in the clarity of the questions and the flow and layout of
the survey. For example, we wanted to ensure definitions used in the
surveys were clear and known to the respondents, categories provided in
closed-ended questions were complete and exclusive, and the ordering of
survey sections and the questions within each section was appropriate.
On the basis of the pre-tests, the Web instrument underwent some slight
revisions. A second step we took to minimize nonsampling errors was
using a Web-based survey. By allowing respondents to enter their
responses directly into an electronic instrument, this method
automatically created a record for each respondent in a data file and
eliminated the need for and the errors (and costs) associated with a
manual data entry process. To further minimize errors, programs used to
analyze the survey data and make estimations were independently
verified to ensure the accuracy of this work.
While we did not fully validate specific information that states
reported through our survey, we took several steps to ensure that the
information was sufficiently reliable for the purposes of this report.
For example, after the survey was closed, we made comparisons between
select items from our survey data and other national-level data
sets.[Footnote 32] We found our survey data were reasonably consistent
with the other data sets. On the basis of our checks, we believe our
survey data are sufficient for the purposes of our work.
Survey of School Districts:
To obtain national-level information on district implementation of SES,
we administered a mail survey to a nationally representative sample of
districts that had schools required to offer SES in school year 2004-
2005. The survey was conducted between January and March 2006. To
obtain the maximum number of responses to our survey, we sent a
reminder postcard to nonrespondents approximately 1 week after the
initial mailing of the survey instrument, a follow-up mailing with the
full survey instrument to nonrespondents approximately 3 weeks after
the initial mailing, and a second follow-up mailing with the full
survey instrument approximately 4 weeks later. The survey included
questions about student participation in SES, characteristics of
students receiving SES, actions taken to increase participation, SES
funding and expenditures, methods used to monitor and evaluate
implementation, implementation challenges, and assistance received and
still needed.
Population:
The target population of 1,095 districts consisted of public school
districts with at least one school in each of their jurisdictions
required to provide SES in the 2004-2005 school year. To define our
population, we collected school improvement information from state
education agency Web sites and the NCLBA Consolidated State Performance
Reports: Part I for Reporting on School Year 2003-2004 that states
submitted to Education. When available, we checked both sources for
school improvement information and used the source that provided the
most recently updated data, as this data is often updated by states
over the course of the school year. After constructing our population
of districts, we used Education's Common Core of Data Local Education
Agency (School District) preliminary file and the Public Elementary/
Secondary School preliminary file for the 2003-2004 school year to
further define the characteristics of our population. On the basis of
our review of these data, we determined these sources to be adequate
for the purposes of our work.
Sample Design and Errors:
The sample design for the mail survey was a stratified random sample of
districts with one certainty stratum containing all of the districts
with 100,000 students or more and one stratum containing all other
districts in the universe. We included the 21 districts with 100,000 or
more students with certainty in the sample to ensure we gathered
information from the largest districts required to offer SES.
We selected a simple random sample of districts in the non-certainty
stratum and calculated the sample size to achieve a precision of plus
and minus 7 percent at the 95 percent confidence level for an expected
proportion of 50 percent. To ensure the sample sizes were adequate, we
increased the sample size assuming we would obtain a 70 percent
response rate. The total sample size for this stratum was 237
districts. In the sample, each district in the population had a known,
nonzero probability of being selected. Each selected district was
subsequently weighted in the analysis to account statistically for all
the schools in the population, including those that were not selected.
Table 8 provides a description of the universe and sample of districts.
Table 8: Description of the Population and Sample of Districts:
Stratum: District enrollment >= 100,000;
Population: 21;
Sample size: 21.
Stratum: District enrollment < 100,000;
Population: 1,074;
Sample size: 237.
Stratum: Total;
Population: 1,095;
Sample size: 258.
Source: GAO.
[End of table]
Because we surveyed a sample of districts, our results are estimates of
a population of districts and thus are subject to sampling errors that
are associated with samples of this size and type. Our confidence in
the precisions of the results from this sample is expressed in 95
percent confidence intervals, which are expected to include the actual
results in 95 percent of the samples of this type. We calculated
confidence intervals for this sample based on methods that are
appropriate for a stratified random sample.
We determined that 10 of the sampled districts were out of scope
because they did not have any schools required to provide SES in the
2004-2005 school year. All estimates produced from the sample and
presented in this report are for the estimated target population of
1,034 districts with at least one school required to provide SES in the
2004-2005 school year. All percentage estimates included in this report
have margins of error of plus or minus 8 percentage points or less,
except for those shown in table 9. All other numerical estimates, such
as the total number of schools required to offer SES in 2004-2005,
included in this report have margins of error of plus or minus 18
percent or less.
Table 9: Sampling Error Calculations:
Page: 15;
Description: Percentage of districts that spent 20 percent or less of
the amount set aside for SES in 2004-2005;
Estimate: 38;
Lower bound: 30;
Upper bound: 47.
Page: 15;
Description: Percentage of districts that spent over 80 percent of the
amount set aside for SES in 2004-2005;
Estimate: 18;
Lower bound: 11;
Upper bound: 26.
Page: 17;
Description: Percentage of districts where over half of SES recipients
in 2004-2005 were elementary school students;
Estimate: 56;
Lower bound: 48;
Upper bound: 65.
Page: 17;
Description: Percentage of districts where less than 5 percent of SES
recipients in 2004-2005 were students with limited English proficiency;
Estimate: 33;
Lower bound: 22;
Upper bound: 43.
Page: 17;
Description: Percentage of districts where over half of SES recipients
in 2004-2005 were students with limited English proficiency;
Estimate: 21;
Lower bound: 13;
Upper bound: 32.
Page: 17;
Description: Percentage of districts where less than 20 percent of SES
recipients in 2004-2005 were students with disabilities;
Estimate: 69;
Lower bound: 59;
Upper bound: 79.
Page: 17;
Description: Percentage of districts where over half of SES recipients
in 2004-2005 were African-American students;
Estimate: 41;
Lower bound: 31;
Upper bound: 50.
Page: 17;
Description: Percentage of districts where over half of SES recipients
in 2004-2005 were Hispanic students;
Estimate: 30;
Lower bound: 21;
Upper bound: 39.
Page: 20;
Description: Percentage of the districts not notifying parents before
the beginning of the school year that did not receive final school
improvement data from the state prior to beginning of the school year;
Estimate: 51;
Lower bound: 42;
Upper bound: 61.
Page: 20;
Description: Percentage of the districts not notifying parents before
the beginning of the school year that notified parents within 2 months
following the beginning of the school year;
Estimate: 91;
Lower bound: 82;
Upper bound: 96.
Page: 21;
Description: Percentage of rural districts where availability of
transportation for students attending SES was a moderate to very great
challenge;
Estimate: 50;
Lower bound: 37;
Upper bound: 63.
Page: 32;
Description: Percentage of the districts that observed most or all
providers during on-site reviews conducted in 2004-2005;
Estimate: 83;
Lower bound: 72;
Upper bound: 91.
Source: GAO.
[End of table]
We took steps to minimize nonsampling errors that are not accounted for
through statistical tests, like sampling errors. In developing the mail
survey, we conducted several pretests of draft instruments. We
pretested the survey instrument with district officials in Woodburn,
Ore; Tacoma, Wash; Baltimore, Md; and Alexandria, Va., between October
and November 2005. These pre-tests were similar to the state Web survey
pre-tests in design and content. On the basis of the pre- tests, the
draft survey instrument underwent some slight revisions.
While we did not fully validate specific information that districts
reported through our survey, we took several steps to ensure that the
information was sufficiently reliable for the purposes of this report.
For example, data from the surveys were double-keyed to ensure data
entry accuracy, and the information was analyzed using statistical
software. After the survey was closed, we also made comparisons between
select items from our survey data and other national-level data
sets.[Footnote 33] We found our survey data were reasonably consistent
with the external sources. On the basis of our checks, we believe our
survey data are sufficient for the purposes of our work.
Response Rate:
We received survey responses from 73 percent of the 258 district Title
I/SES coordinators in our sample. The response rate, adjusted for the
known and estimated districts that were out of scope, was 77 percent.
Table 10: SES District Survey Response Rates:
Stratum: District enrollment >= 100,000;
Districts in population: 21;
Districts in sample: 21;
In-scope districts in sample: 21;
Districts responding: 21.
Stratum: District enrollment < 100,000;
Districts in population: 1,074;
Districts in sample: 237;
In-scope districts in sample: 227;
Districts responding: 167.
Stratum: Total;
Districts in population: 1,095;
Districts in sample: 258;
In-scope districts in sample: 248;
Districts responding: 188.
Source: GAO.
[End of table]
After the survey was closed, we analyzed the survey respondents to
determine if there were any differences between the responding
districts, the nonresponding districts, and the population. We
performed this analysis for three characteristics--total number of
students enrolled, total number of special education students, and
total number of English language learner students. We determined
whether sample-based estimates of these characteristics compared
favorably with the known population values. The population value for
all of the characteristics we examined fell within the 95 percent
confidence intervals for the estimates from the survey respondents. On
the basis of the 77 percent response rate and this analysis, we chose
to include the survey results in our report and produce sample-based
estimates to the population of districts required to provide SES in the
2004-2005 school year.
Site Visits:
To understand SES implementation at the local level, we conducted site
visits to four districts between October 17, 2005, and February 16,
2006. The districts visited included Woodburn School District
(Woodburn, Ore.), Hamilton County Schools (Chattanooga, Tenn.), Newark
Public Schools (Newark, N.J.), and Chicago Public Schools (Chicago,
Ill.) The four districts visited were selected because they had
experience implementing SES in their schools and were recommended by
stakeholders as having promising parent outreach and/or monitoring
practices. When viewed as a group, the districts also provided
variation across characteristics such as geographic location, district
size, student ethnicity, and the percentage of students with limited
English proficiency or disabilities.
During the site visits, we interviewed state officials, including the
state SES coordinator, and district officials, including the
superintendent and SES coordinator. We also interviewed officials
representing 12 schools, including principals and other school staff
involved with SES. In total, we visited several schools of each level,
from elementary to high, and though district officials selected the
schools we visited, all of the schools had experience implementing SES.
Through our interviews with state, district, and school officials, we
collected information on district efforts to notify parents and fulfill
implementation responsibilities, student participation, providers,
local implementation challenges, and implementation assistance received
and needed. During the visits, we also interviewed providers and
observed tutoring sessions in order to better understand
implementation. During our visit to Woodburn, Ore., we also observed a
provider fair.
In addition to our site visits to four districts, we also visited the
Rhode Island Department of Elementary and Secondary Education in March
2006 to gather additional information on state efforts to monitor and
evaluate SES. Rhode Island invited us to attend two meetings the state
held with districts implementing SES and providers serving students in
Rhode Island, during which SES challenges, ways to improve
implementation, and state efforts to evaluate providers were discussed.
Provider Interviews:
In total, we conducted interviews with 22 providers, including 15
providers during the site visits and 7 providers operating in multiple
states. The Education Industry Association assisted our efforts to
contact multi-state providers, and most of the multi-state providers we
interviewed were association members.[Footnote 34] Multi-state provider
interviews were conducted between November and December 2005.
Through all of our provider interviews, we collected information on
provider efforts to increase participation in SES, align services with
state standards and district curriculum, and communicate with parents
and schools to ensure students are receiving needed services. We also
collected information on students served, tutor and program
characteristics, and provider challenges to SES implementation. While
the providers we interviewed reflect some variety in provider
characteristics, our selections were not intended to be representative.
Thus, the findings from our interviews cannot be used to make
inferences about all providers.
Education Data Analyses:
We analyzed state data submitted to Education through the NCLBA
Consolidated State Performance Reports (CSPR) for school years 2002-
2003, 2003-2004, and 2004-2005. State reports from all 3 years included
the number of students receiving SES and the number of schools those
students attended, and state reports from 2003-2004 and 2004-2005 also
included the number of students eligible for SES. Data from the 2003-
2004 CSPRs were used to assist our analysis of SES participation. To
assess the reliability of the 2003-2004 data, we performed a series of
tests, which included checking to ensure that data were consistent,
that subtotals added to overall totals and that data provided for 1
year bore a reasonable relationship to the next year's data and to data
reported elsewhere, including state education reports. We also spoke
with Education officials about their follow-up efforts to verify the
data. At the time of our review, Education was in the process of
completing efforts to verify the 2003-2004 data.
While we compared the 2004-2005 CSPR data to data obtained through our
state and district surveys to further verify our data, we generally did
not use the 2004-2005 CSPR data for our analysis.[Footnote 35] During
this comparison analysis, where we found discrepancies or sought
clarification, we followed up with state officials. In several states,
officials revised the numbers that they had initially reported to us or
to Education. On the basis of our review of these data, we determined
these sources to be adequate for the purposes of our work.
We also considered SES-related findings from Education studies,
including the Evaluation of Title I Accountability Systems and School
Improvement Efforts: Findings From 2002-03 (2005) and the National
Assessment of Title I: Interim Report (2006). To ensure the findings
from these studies were generally reliable, we reviewed each study's
methodology, including data sources and analyses, limitations, and
conclusions. In addition, in designing our state and district surveys,
we reviewed SES-related survey questions used by Education in these
studies.
[End of section]
Appendix II: Comments from the Department of Education:
United States Department Of Education:
Office Of Innovation And Improvement:
July 14, 2006:
Ms. Marnie S. Shaul:
Director, Education, Workforce, and Income Securities Issues:
Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Shaul:
I am writing in response to your request for comments on the Government
Accountability Office (GAO) draft report (GAO-06-758) entitled,
"Education Actions Needed to Improve Local Implementation and State
Evaluation of Supplemental Educational Services." I appreciate the
opportunity to respond to the recommendations made in the report and to
provide you with additional information on how the U.S. Department of
Education (Department) is supporting effective implementation of the
supplemental educational services (SES) provisions of Title I of the
Elementary and Secondary Education Act of 1965, as amended by the No
Child Left Behind Act of 2001 (NCLB).
As you know, the Department takes very seriously the need for effective
SES implementation at all levels. In a letter to all Chief State School
Officers on May 15, 2006, Secretary Spellings stressed the need for the
Department and States to work together to expedite the implementation
of further improvements of SES. For example, we expect districts to
notify eligible families about SES in a way that is timely, clear, and
complete, as well as to spend the full amount of funds necessary to
meet demand for SES from families. In the May 15 letter, the Secretary
also directed States to help their districts become fully compliant
with SES in 2006-07 by closely monitoring districts' actions and
providing them with requisite technical assistance. In such cases where
districts are not complying with the SES provisions, the Secretary made
clear that we are fully prepared to take actions such as placing
conditions on Title I grants, withholding funding, and, if appropriate,
entering into compliance agreements. The Department believes that these
actions, as well as other strategies and actions we are undertaking,
explained in more detail below, will provide significant motivation and
resources to help all districts and States be successful with their SES
implementation. We appreciate the specific recommendations you make in
the report and respond to each of them below.
Your first three recommendations concern additional assistance to help
States and districts implement SES more effectively, which is a primary
goal of the Department and one we pursue with full commitment and
dedication. Specifically, you recommend that the Department: (1)
provide better guidance on SES parental notification letters, (2)
collect and disseminate information on promising practices used by
States to attract more providers and used by districts to improve
parental notification letters and provider services, and (3) provide
examples of how districts can involve schools and school officials in
coordinating activities with providers.
As you state in your report, the Department has provided States and
districts with a sample parent notification letter in the June 2005
edition of the SES Non-Regulatory Guidance. A team of Department staff,
including staff from both the Office of Elementary and Secondary
Education (OESE) and the Office of Innovation and Improvement (OII),
developed this letter, in direct response to the need we saw in the
field for more informative and higher-quality parent letters. We
drafted a sample letter not only to contain all required information,
but also to be as "parent-friendly" and easy to use as possible.
However, we recognize that States and districts may need more
information on parent outreach and communication. The Department has
assigned to our Comprehensive Center on Innovation and Improvement the
task of developing a technical assistance effort to help respond to the
needs of States, districts, and community-based organizations to
conduct effective outreach on SES issues. The Center will be developing
this effort this summer and fall and will implement it in sites around
the country during the 2006-07 school year. The Center's effort will
include technical assistance in the areas of planning and implementing
outreach, as well as providing sample tools for educators to use to
effectively reach parents. Department officials also will be meeting
with State Title I Directors at the end of July 2006, and in that
forum, we will solicit further information on the types of technical
assistance that would be most useful in improving parent outreach and
communication, including on how the sample letter in the SES guidance
might be improved.
We will also continue to collect and share examples of districts that
are effectively reaching out to parents and working well with
providers. We believe that there are lessons to be learned from the
districts that participated in the two SES pilots in 2005-06. For
example, we invited Newport News Public Schools in Virginia to
participate in a recent production of the Department's Education News
Parents Can Use program that focused on SES topics. Newport News shared
with a national audience of viewers the activities and actions it had
taken to implement SES successfully in that district.
We will also be disseminating promising practices that States use to
attract providers through our State SES directors meeting, to be held
this October. This is the third meeting that the Department has
sponsored, in conjunction with the Council of Chief State School
Officers (CCSSO) and with the support of the C.S. Mott Foundation, to
assist State SES directors with SES implementation. (The meeting also
supports successful collaboration between SES and the 21ST Century
Community Learning Centers Program.) As part of this October meeting,
we will feature a session on successful State actions that help ensure
a diversity of providers and on-going, high-quality communication
between States and providers. During this meeting, we will also feature
a session exploring successful partnerships between districts, schools,
and providers. This session will build on guidance that the Department
has already offered in the area of school involvement in SES. In the
Department's June 2005 revisions to the SES Non-Regulatory Guidance, we
encouraged districts to enlist the help of their schools in reaching
parents. For example, we suggested that districts could use back-to-
school nights to explain SES to parents and that districts should
educate their teachers and principals about the SES provisions to make
sure they are able to answer parents' questions. We will continue to
highlight the important role that schools can play in the SES process
as we provide technical assistance to the field on SES.
Your second set of recommendations involves States' and districts'
ability to fund SES sufficiently and provide services to the maximum
number of students. As noted above, these matters were addressed in
various ways in the May 15, 2006, letter. For example, the Secretary
announced in this letter that the Department was expanding the SES
pilot program that began last year that allowed four districts in
Virginia to provide SES to students in schools in year one of
improvement. We requested that States interested in participating in
this program submit proposals by June 19. In the proposals, each State
had to demonstrate that it met three key conditions related to NCLB
implementation: timely adequate yearly progress notification, SES
evaluation in progress, and State assessment systems in one of the top
three review categories. States could propose up to seven districts to
participate in the program. The Department is currently reviewing these
proposals and anticipates making a decision about this pilot.
Additionally, we are currently considering expanding the SES pilot that
allows districts in need of improvement to apply to become SES
providers.
You also recommend that the Department clarify what States can do
through the provider approval process to set parameters around program
design and costs. In the Department's June 2005 revisions to the SES
Non-Regulatory Guidance, we provide information to States about their
role in establishing certain program design criteria for providers to
meet. We discuss, for example, that a State could establish a range for
student/teacher ratios or for the rates that providers charge for their
programs. We also instruct States that they may develop a policy with
regard to providers' use of financial incentives and other gifts. We
note in the guidance that school districts may not impose requirements
on providers' program designs because doing so would undermine States'
authority to establish standards for provider approval. While, at this
time, the Department has not provided additional guidance to all States
on their authority in this area, we continue to respond to individual
State questions on the matter. Additionally, it is a topic we will
consider further addressing in our next set of revisions to the SES
guidance.
Your final set of recommendations discusses steps the Department can
take to improve Federal and State monitoring of SES. The Department
continues to improve its monitoring efforts of the Title I
requirements, including SES. Additionally, as outlined in the
Secretary's letter dated May 15, 2006, we urged States to work with
local educational agencies (LEAs) in their efforts to comply with SES
requirements and to closely monitor the LEAs' actions in this area.
With regard to this recommendation, you specifically recommend that the
Department require States to report information necessary to determine
the percentage and amount of Title I funds spent by districts to
provide SES. The Department recognizes the importance of collecting
information on how much districts are spending on SES (as well as how
much they are spending on public school choice-related transportation).
In the 2006-07 data collection for the Education Data Exchange Network
(EDEN)/EDFacts system, the Department is proposing that districts
report on their SES and public school choice spending. This will give
the Department data on spending trends across the country, as well as
help us identify districts that are doing either particularly well, or
are under-spending, on SES.
Finally, you recommend providing States with technical assistance on
how to evaluate the effects of SES on student achievement. The
Department has recognized the importance of high-quality State
evaluations for several years. As part of a grant to the American
Institutes for Research, the Department supported the development of an
issue brief to advise States on the evaluation process. (This issue
brief is available at: [Hyperlink,
http://www.tutorsforkids.org/documents/SES] Evaluation Issue Brief
004.pdf). The Department and the authors of this issue brief have
shared it widely and presented it at several national conferences.
Additionally, the Department has assigned the Comprehensive Center on
Innovation and Improvement the task of providing additional assistance
in this area. The Center will work with the authors of the original
issue brief to update it by this September and disseminate it to the
field, and the Center has hired the authors as technical advisors so
that they can provide ongoing technical assistance to States in the
area of evaluation. Finally, this fall at the Department's conference
with the CCSSO and the C.S. Mott Foundation, we will hold several in-
depth sessions on conducting evaluations to provide more technical
assistance to States.
Thank you again for taking the time to research and report on the SES
provisions of NCLB. The Department values the work that you have done
to provide rich and compelling information about the current status of
SES around the country. We will use the findings and recommendations
made in this report to improve our technical assistance to States and
districts and ultimately to improve the quality of SES implementation
around the country.
Sincerely,
Signed by:
Christopher J. Doherty:
Acting Assistant Deputy Secretary:
Office of Innovation and Improvement:
[End of section]
Appendix III: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
Marnie S. Shaul (202) 512-7215 shaulm@gao.gov Cornelia M. Ashby (202)
512-7215 ashbyc@gao.gov:
Acknowledgments:
Cindy Ayers, Assistant Director, and Rachel Frisk, Analyst-in-Charge,
managed this assignment and made significant contributions to all
aspects of this report. Cathy Roark, Ted Burik, and David Perkins also
made significant contributions. Kevin Jackson, Jean McSween, Jim
Ashley, and Jerry Sandau provided methodological expertise and
assistance; Rachael Valliere assisted with message and report
development; and Rasheeda Curry made contributions during study design.
In addition, Jessica Botsford assisted in the legal analysis.
[End of section]
Related GAO Products:
No Child Left Behind Act: Assistance from Education Could Help States
Better Measure Progress of Students with Limited English Proficiency.
GAO-06-815. Washington, D.C.: July 26, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic
Growth that Education's Initiatives May Help Address. GAO-06-661.
Washington, D.C.: July 17, 2006.
No Child Left Behind Act: Most Students with Disabilities Participated
in Statewide Assessments, but Inclusion Options Could Be Improved. GAO-
05-618. Washington, D.C.: July 20, 2005.
No Child Left Behind Act: Education Needs to Provide Additional
Technical Assistance and Conduct Implementation Studies for School
Choice Provision. GAO-05-7. Washington, D.C.: December 10, 2004.
No Child Left Behind Act: Improvements Needed in Education's Process
for Tracking States' Implementation of Key Provisions. GAO-04-734.
Washington, D.C.: September 30, 2004.
No Child Left Behind Act: Additional Assistance and Research on
Effective Strategies Would Help Small Rural Districts. GAO-04-909.
Washington, D.C.: September 23, 2004.
Disadvantaged Students: Fiscal Oversight of Title I Could Be Improved.
GAO-03-377. Washington, D.C.: February 28, 2003.
Title I Funding: Poor Children Benefit Though Funding Per Poor Child
Differs. GAO-02-242. Washington, D.C.: January 31, 2002.
FOOTNOTES
[1] In this report, we refer to Title I, Part A of ESEA as "Title I."
Other Parts of Title I (Parts B, C, and D) are targeted at specific
populations or purposes and are commonly referred to by their program
names, such as Even Start.
[2] State testing has been phased in, whereby from 2002-2004 states
were required to administer tests at least once in grades 3-5, 6-9, and
10-12. Beginning in 2005-2006, states must administer annual tests in
grades 3-8, and at least once in grades 10-12. Testing for science
proficiency will begin in 2007-2008.
[3] Measures for elementary and middle schools may include, but are not
limited to, attendance, grade-to-grade retention rates, or changes in
the percentage of students completing gifted and talented programs.
[4] In addition, NSLP allows certain schools and districts with high
percentages of low-income families to certify students as eligible for
free and reduced price lunches about once every 4 years. These
alternatives to the traditional requirements for annual certification,
known as "Provision 2" and "Provision 3," reduce local paperwork and
administrative burden. Education has determined that, for purposes of
identifying students as "economically disadvantaged" for SES, school
officials may deem all students in Provision 2 and Provision 3 schools
as "economically disadvantaged." See policy memo: U.S. Department of
Agriculture, Food and Nutrition Service, "No Child Left Behind Act
(NCLB)," School Meals (Washington, D.C.: Feb. 2003),
http://www.fns.usda.gov/end/governance/policy-memos/2002-02-20.htm
[5] Only 1 percent of students eligible for school choice elected to
transfer to another school during the 2003-2004 school year. See GAO,
No Child Left Behind Act: Education Needs to Provide Additional
Technical Assistance and Conduct Implementation Studies for School
Choice Provision, GAO-05-07 (Washington, D.C.: Dec. 10, 2004).
[6] A district calculates the Title I per pupil allocation by dividing
its total Title I, Part A allocation by the number of children residing
within the district aged 5-17 who are from families below the poverty
level, as determined by the most recent Census Bureau estimates from
the Department of Commerce.
[7] Certain states did not submit SES recipient information to
Education through their NCLBA Consolidated State Performance Reports
for all years. See notes to figure 1 for details. Further, Education
did not collect data on the number of students eligible for SES in 2002-
2003, and therefore an estimate of the SES participation rate is
unavailable for that year.
[8] In addition to our analysis, the Center on Education Policy
reported that within districts required to offer SES, the percentage of
all schools required to offer SES rose from 27 percent of schools in
2002-2003 to 65 percent of schools in 2005-2006. See the Center on
Education Policy, From the Capital to the Classroom, Year 4 of the No
Child Left Behind Act (Washington D.C.: March 2006), for more
information.
[9] These district estimates have a margin of error that exceeds plus
or minus 8 percentage points. See table 9 in appendix I for more
information.
[10] We did not review the academic achievement records of students
receiving SES or independently verify this information obtained through
the district survey.
[11] Many of the district estimates included in this paragraph have a
margin of error that exceeds plus or minus 8 percentage points. See
table 9 in appendix I for more information.
[12] In addition to our analysis, the Center on Education Policy
reported that that as of August 2005, more than half of approved SES
providers were private, for-profit entities. See the Center on
Education Policy, From the Capital to the Classroom, Year 4 of the No
Child Left Behind Act (Washington D.C.: March 2006), for more
information.
[13] GAO previously reported that some states have difficulty notifying
schools of their status in meeting proficiency goals in a timely
fashion in part because of the time involved in identifying and
correcting errors in student assessment data. See GAO, No Child Left
Behind Act: Improvements Needed in Education's Process for Tracking
States' Implementation of Key Provisions, GAO-04-734 (Washington D.C.:
Sept. 30, 2004), for more information.
[14] This district estimate has a margin of error that exceeds plus or
minus 8 percentage points. See table 9 in appendix I for more
information.
[15] This district estimate has a margin of error that exceeds plus or
minus 8 percentage points. See table 9 in appendix I for more
information.
[16] GAO previously reported that geographic isolation created
difficulties for rural districts in implementing SES. Specifically,
rural district officials stated that traveling long distances to meet
providers was not a viable option and use of online providers was
challenging in some small rural districts where it was difficult to
establish and maintain Internet service. See GAO, No Child Left Behind
Act: Additional Assistance and Research on Effective Strategies Would
Help Small Rural Districts, GAO-04-909 (Washington D.C.: Sept. 23,
2004), for more details.
[17] This district estimate has a margin of error that exceeds plus or
minus 8 percentage points. See table 9 in appendix I for more
information.
[18] The other states included five that did not respond to the
applicable survey question. A similar number of states did not respond
to the other survey questions discussed in this paragraph.
[19] In addition to our analysis, the Center on Education Policy case
studies also found that in some cases, approved providers that
initially expressed interest in serving a certain district later
decided not to provide services because too few students enrolled. See
the Center on Education Policy, From the Capital to the Classroom, Year
4 of the No Child Left Behind Act (Washington D.C.: March 2006), for
more information.
[20] Similar to states, districts reported on monitoring activities
through our survey in early 2006;
therefore, while some had already begun to monitor providers, others
reported on their plans to monitor providers before the end of the 2005-
2006 school year. The increases in monitoring reflect both those
districts that had already begun monitoring activities and those
planning monitoring activities for later in 2005-2006. Because our data
were collected during the middle of the 2005-2006 school year, we do
not know whether the estimated percentage of districts that planned to
complete these activities before the end of the year did so.
[21] The district estimate has a margin of error that exceeds plus or
minus 8 percentage points. See table 9 in appendix I for more
information.
[22] Further, the federal SES guidance suggests that student
performance can be measured in a variety of ways, including with
provider assessments or state or district standardized assessments.
However, the guidance does not discuss the limitations of using
different approaches to conduct such evaluations.
[23] At the time of our survey, several additional states, including
Louisiana and Pennsylvania, were in the process of drafting an SES
evaluation report that would assess the impact of SES providers serving
students in their states in previous years, but the reports were not
yet available to the public.
[24] In addition, at least two school districts, Chicago and
Minneapolis, have taken steps to evaluate SES, but we found that their
evaluation efforts have also not yet produced a conclusive assessment
of SES's impact on student academic achievement.
[25] Only one state reported withdrawing approval from one of its
providers because that provider's program was generally ineffective.
However, this provider's program was found to be ineffective because
the provider did not deliver services to all of the students it
enrolled. This state also indicated that it had not yet completed an
evaluation of SES's effect on student academic achievement.
[26] States have only reported the number of students eligible for SES
since the 2003-2004 CSPR. Also, for the 2004-2005 CSPR, Education gave
states the option to also report the number of students who applied for
SES.
[27] States audited were Delaware, Illinois, Indiana, Michigan, New
Jersey, and Nevada.
[28] California districts audited were Los Angeles Unified, Oakland
Unified, Salinas Union High School, San Diego City Schools, and
Stockton Unified.
[29] As discussed earlier, OIG found all six of the states it visited
to be deficient with respect to parent notifications. In addition, in
our analysis of OESE Title I monitoring reports issued as of June 2006,
we found that OESE cited 9 of the 40 states it had visited for SES non-
compliance with respect to district parent notifications.
[30] See the Center on Education Policy, From the Capitol to the
Classroom: Year 4 of the No Child Left Behind Act (Washington D.C.:
March 2006).
[31] Ibid.
[32] We compared our state survey data to data on SES reported by
Education in the Evaluation of Title I Accountability Systems and
School Improvement Efforts: Findings From 2002-03 (Washington, D.C.:
Nov. 2005) and the National Assessment of Title I: Interim Report
(Washington, D.C.: Feb. 2006). We also compared our survey data to data
on SES reported by the Center on Education Policy in From the Capital
to the Classroom: Year 3 of the No Child Left Behind Act (Washington,
D.C.: March 2005) and From the Capital to the Classroom: Year 4 of the
No Child Left Behind Act (Washington, D.C.: March 2006).
[33] We compared our district survey data to data on SES reported by
Education in the Evaluation of Title I Accountability Systems and
School Improvement Efforts: Findings From 2002-03 (Washington, D.C.:
Nov. 2005) and the National Assessment of Title I: Interim Report
(Washington, D.C.: Feb. 2006). We also compared our survey data to data
on SES reported by the Center on Education Policy in From the Capital
to the Classroom: Year 3 of the No Child Left Behind Act (Washington,
D.C.: March 2005) and From the Capital to the Classroom: Year 4 of the
No Child Left Behind Act (Washington, D.C.: March 2006).
[34] The seven multi-state providers we spoke with were Babbage Net
School, Cambridge Educational Services, Catapult Learning, Huntington
Learning Center, Newton Learning, Platform Learning, and University
Instructors.
[35] At the time of our survey, seven states were unable to provide
2004-2005 data on SES recipients and students eligible to receive SES.
By the time Education required states to submit the 2004-2005 CSPR
reports in March 2006, six of these states had provided this data to
Education; we, therefore, used this data to supplement their responses
to our survey. The seventh state, New Jersey, was unable to provide
this data to Education by the time 2004-2005 CSPRs were due;
therefore, New Jersey data is not included in the 2004-2005
participation analysis included in this report.
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