**Iowa Department of Education**

**May 18 - 21, 2004**

**Scope of Review:** The U.S. Department of Education's (ED) Student
Achievement and School Accountability Programs (SASA) team monitored the
Iowa Department of Education (IDE) the week of May 18 - 21, 2004. This
was a comprehensive review of the IDE\'s administration of Title I, Part
A and B funds, as required by the Elementary and Secondary Education Act
of 1965 (ESEA), as amended by the No Child Left Behind Act of 2001
(NCLB).

In conducting this comprehensive review, the ED team carried out a
number of major activities. In reviewing the Part A program, the ED team
conducted an analysis of State assessments and State accountability
system plans, review of the effectiveness of the instructional
improvement and instructional support measures established by IDE to
benefit local educational agencies (LEAs) and schools, and review of
compliance with fiscal and administrative oversight requirements
required of the State educational agency (SEA). During the onsite
monitoring review, the ED team interviewed IDE personnel to determine
how the SEA is meeting its NCLB requirements in each of the three
monitoring areas (accountability, instructional support, and compliance
with fiduciary responsibilities). The ED team visited two LEAs -- the
Des Moines and Waterloo School Districts. During these two LEA visits
the ED team interviewed LEA and school administrative staff, visited
five schools operating schoolwide programs, one school operating a
targeted assistance program, two programs serving private school
children, and conducted a district-wide parent meeting at each LEA. The
ED team conducted conference calls to two additional LEAs (Davenport and
Central Decatur) following the onsite monitoring review to confirm
information gathered from the Des Moines and Waterloo School Districts
and at IDE.

In reviewing Part B of Title I (Even Start), the ED team examined the
State request for proposals, State Even Start guidance, State indicators
of program quality, and the most recent applications, local evaluations,
and expenditure reports from the Even Start programs in Bettendorf and
Iowa City. During the onsite review, the team visited those two local
Even Start programs and interviewed administrative and instructional
staff. Finally, the team interviewed the IDE's Even Start State
coordinator to confirm data collected at the two local sites and to
discuss State administration issues.

**Previous Audit Findings:** None

**Previous Monitoring Findings:** The Department of Education team last
reviewed

Title I, Part A programs in December 1997 as part of a Federal
integrated review initiative. IDE satisfactorily addressed all
compliance issues cited in the review in April 1998. ED has not
previously conducted a comprehensive review of the Even Start program in
Iowa.

Title I Monitoring

**Summary of Critical Monitoring Elements**

+---------+----------------------------------------+-----------+------+
| # Monit |                                        |           |      |
| oring A |                                        |           |      |
| rea 1:  |                                        |           |      |
| Account |                                        |           |      |
| ability |                                        |           |      |
+---------+----------------------------------------+-----------+------+
| **In    | **Critical element**                   | # Status  | #    |
| dicator |                                        |           | Page |
| N       |                                        |           |      |
| umber** |                                        |           |      |
+---------+----------------------------------------+-----------+------+
| C       | SEA has approved academic content      | Met       | N/A  |
| ritical | standards for all required subjects or | Req       |      |
| element | an approved timeline for developing    | uirements |      |
| 1.1     | them.                                  |           |      |
+---------+----------------------------------------+-----------+------+
| C       | The SEA has approved academic          | Met       | >    |
| ritical | achievement standards and alternate    | Req       |  N/A |
| element | academic achievement standards in      | uirements |      |
| 1.2     | required subject areas and grades or   |           |      |
|         | an approved timeline to create them.   |           |      |
+---------+----------------------------------------+-----------+------+
| C       | The SEA has approved assessments and   | Finding   | > 6  |
| ritical | alternate assessments in required      |           |      |
| element | subject areas and grades or an         |           |      |
| 1.3     | approved timeline to create them.      |           |      |
+---------+----------------------------------------+-----------+------+
| C       | The SEA has implemented all required   | Com       | > 6  |
| ritical | components as identified in its        | mendation |      |
| element | accountability workbook. NCLB report   |           |      |
| 1.4     | card requirements are addressed        |           |      |
|         | separately (1.5)                       |           |      |
+---------+----------------------------------------+-----------+------+
| C       | The SEA has published its annual       | Finding   | > 6  |
| ritical | report card and ensured that LEAs have |           |      |
| element | published annual report cards as       |           |      |
| 1.5     | required.                              |           |      |
+---------+----------------------------------------+-----------+------+
| C       | SEA indicates how funds received under | Met       | >    |
| ritical | Grants for State Assessments and       | req       |  N/A |
| element | related activities (§6111) will be or  | uirements |      |
| 1.6     | have been used to meet the 2005-06 and |           |      |
|         | 2007-08 assessment requirements of     |           |      |
|         | NCLB.                                  |           |      |
+---------+----------------------------------------+-----------+------+
| C       | SEA ensures that LEAs meet all         | Met       | >    |
| ritical | requirements for identifying and       | req       |  N/A |
| element | assessing the academic achievement of  | uirements |      |
| 1.7     | limited English proficient students.   |           |      |
+---------+----------------------------------------+-----------+------+

+---------+-------------------------------+-------------------+------+
| # Monit |                               |                   |      |
| oring A |                               |                   |      |
| rea 2:  |                               |                   |      |
| Instruc |                               |                   |      |
| tional  |                               |                   |      |
| Support |                               |                   |      |
+---------+-------------------------------+-------------------+------+
| **In    | # Critical element            | ### Status        | ##   |
| dicator |                               |                   | Page |
| N       |                               |                   |      |
| umber** |                               |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA designs and           | Met requirements  | N/A  |
| ritical | implements policies and       |                   |      |
| element | procedures that ensure the    |                   |      |
| 2.1     | hiring and retention of       |                   |      |
|         | highly qualified staff.       |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA provides, or provides | Commendation      | > 7  |
| ritical | for, technical assistance for |                   |      |
| element | LEAs and schools as required. |                   |      |
| 2.2     |                               |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA establishes a         | Recommendation    | > 7  |
| ritical | Committee of Practitioners    |                   |      |
| element | and involves the committee in |                   |      |
| 2.3     | decision making as required.  |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA ensures that the LEA  | Recommendation    | > 7  |
| ritical | and schools meet parental     |                   |      |
| element | involvement requirements.     |                   |      |
| 2.4     |                               |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA ensures that schools  | Finding           | > 7  |
| ritical | and LEAs are identified for   |                   |      |
| element | improvement, corrective       | Recommendation    |      |
| 2.5     | action, or restructuring as   |                   |      |
|         | required and that subsequent, |                   |      |
|         | required steps are taken.     |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA ensures that          | > Finding         | > 8  |
| ritical | requirements for public       |                   |      |
| element | school choice are met.        |                   |      |
| 2.6     |                               |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA fulfills the          | Met requirements  | N/A  |
| ritical | statutory requirements for    |                   |      |
| element | the provision of supplemental |                   |      |
| 2.7     | educational services (SES)    |                   |      |
|         | are met.                      |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA ensures that LEAs and | Met requirements  | N/A  |
| ritical | schools develop schoolwide    |                   |      |
| element | programs that use the         |                   |      |
| 2.8     | flexibility provided to them  |                   |      |
|         | by law to improve the         |                   |      |
|         | academic achievement of all   |                   |      |
|         | students in the school.       |                   |      |
+---------+-------------------------------+-------------------+------+
| C       | The SEA ensures that LEAs and | Met requirements  | N/A  |
| ritical | schools develop and maintain  |                   |      |
| element | targeted assistance programs  |                   |      |
| 2.9     | that meet all required        |                   |      |
|         | components                    |                   |      |
+---------+-------------------------------+-------------------+------+

+---------+--------------------------------------+-------------+------+
| # M     |                                      |             |      |
| onitori |                                      |             |      |
| ng Area |                                      |             |      |
|  3: Fid |                                      |             |      |
| uciary  |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| **In    | # Critical element                   | ### Status  | ##   |
| dicator |                                      |             | Page |
| N       |                                      |             |      |
| umber** |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA ensures that its component   | Rec         | 9    |
| ritical | LEAs are audited annually, if        | ommendation |      |
| element | required, and that all corrective    |             |      |
| 3.1     | actions required through this        |             |      |
|         | process are fully implemented.       |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA complies with the            | Met         | N/A  |
| ritical | allocation, reallocation, and        | r           |      |
| element | carryover provisions of Title I.     | equirements |      |
| 3.2     |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA complies with the            | Met         | N/A  |
| ritical | maintenance of effort provisions of  | r           |      |
| element | Title I.                             | equirements |      |
| 3.3     |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA ensures that the LEA         | Met         | N/A  |
| ritical | complies with the comparability      | r           |      |
| element | provisions of Title I.               | equirements |      |
| 3.4     |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA ensures that LEAs provide    | Findings    | 10   |
| ritical | Title I services to eligible         |             |      |
| element | children attending private schools.  |             |      |
| 3.5     |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA has a system for ensuring    | Met         | N/A  |
| ritical | and maximizing the quality,          | r           |      |
| element | objectivity, utility, and integrity  | equirements |      |
| 3.6     | of information disseminated by the   |             |      |
|         | agency.                              |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA has an accounting system for | Met         | N/A  |
| ritical | administrative funds that includes   | r           |      |
| element | (1) state administration, (2)        | equirements |      |
| 3.7     | reallocation, and (3) reservation of |             |      |
|         | funds for school improvement.        |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA has a system for ensuring    | Finding     | 9    |
| ritical | fair and prompt resolution of        |             |      |
| element | complaints.                          |             |      |
| 3.8     |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA ensures that the LEA         | Finding     | 10   |
| ritical | complies with the rank order         |             |      |
| element | procedures for the eligible school   |             |      |
| 3.9     | attendance areas.                    |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA conducts monitoring of its   | Rec         | 12   |
| ritical | subgrantees sufficient to ensure     | ommendation |      |
| element | compliance with Title I program      |             |      |
| 3.10    | requirements.                        |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The LEA complies with the provision  | C           | > 12 |
| ritical | for submitting an annual plan to the | ommendation |      |
| element | SEA.                                 |             |      |
| 3.11    |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA and LEA comply with          | Met         | N/A  |
| ritical | requirements regarding the           | r           |      |
| element | reservation of administrative funds. | equirements |      |
| 3.12    |                                      |             |      |
+---------+--------------------------------------+-------------+------+
| C       | The SEA ensures that Title I funds   | Met         | N/A  |
| ritical | are used only to supplement or       | r           |      |
| element | increase non-Federal sources used    | equirements |      |
| 3.13    | for the education of participating   |             |      |
|         | children and not to supplant funds   |             |      |
|         | from non-Federal sources.            |             |      |
+---------+--------------------------------------+-------------+------+

Area: Accountability

## Critical Element 1.3 -- The SEA has approved assessments and alternate assessments in required subject areas and grades or an approved timeline to create them

##  

[**Finding**:]{.underline} The ED team found that between 70% and 80% of
Black, Hispanic, LEP and students with disabilities, on average, were
being included in school and district administrations of the Iowa state
tests based on data provided by the IDE. Those percentages serve as
evidence that not all students are being included in test
administrations as required.

## 

[Citation:]{.underline} 20 U.S.C. 6316 §1116(b)(3)(C)(ix) requires the
participation in such assessments of all students.

#####  

[Further Action Required:]{.underline} IDE must clarify its guidance to
LEAs on student participation in State assessments (all students must be
tested), provide technical assistance to LEAs on student participation
on State tests and include a review of student participation rate data
in LEA monitoring conducted by the IDE.

## Critical Element 1.4 -- The SEA has implemented all required components as identified in its accountability workbook.

> **[Commendation:]{.underline}** IDE has designed and implemented the
> Iowa Accountability website which allows access to LEAs and the SEA
> for data entry related to student proficiency percentages and
> participation rates on State assessments used for NCLB accountability.
> Area Education Agencies (AEAs) have read-only access to the website
> and can monitor compliance with various NCLB and State requirements.
> This is an excellent tool that has been made available in a SEA that
> has a wide range of dates for administering its State assessment for
> NCLB purposes.

## Critical Element 1.5 -- The SEA has published its annual report card and ensured that LEAs have published annual report cards as required.

**[Finding:]{.underline}** The ED team found that LEA school report
cards are missing the State and LEA comparisons with school performance
on the other academic indicators required for NCLB accountability.

[Citation:]{.underline} 20 U.S.C. 6316 §1111(h)(2)(B)(ii)(II) requires
the SEA to ensure that each school provide information on the school
report cards that shows how student achievement on the statewide
academic assessments and other indicators of adequate yearly progress
compare to performance at the LEA and SEA levels.

[Further Action Required:]{.underline} IDE must provide guidance and
technical assistance to the LEAs on reporting the LEAs' performance on
the NCLB accountability and other academic indicators as well as the
State performance on the same indicators on the LEA report cards. IDE
must monitor district compliance with this requirement to ensure that
LEA report cards contain all of the information required by NCLB.

**Area: Instructional Support**

Critical Element 2.2 - The SEA provides, or provides for, technical
assistance for LEAs and schools as required.

> **[Commendation:]{.underline}** The Iowa Professional Development
> Content Network Web site, developed by the IDE, provides practitioners
> with easy access to high-quality research. The site offers reviews of
> research studies focused on specific instructional strategies and
> programs in both reading, mathematics, and science and encourages the
> use of scientifically based research.

**Critical Element 2.3 -- The SEA establishes a Committee of
Practitioners and involves the committee in decision making as
required.**

[Recommendation]{.underline}: The IDE's Title I Committee of
Practitioners has a roster of only five members. Since the purpose of
this committee is to advise IDE in carrying out its Title I
responsibilities statewide, including developing and monitoring the
implementation of the State's Title I plan, the ED team recommends that
the IDE expand its active membership to create participation that is
more representative of the entire State.

Critical Element 2.4 - The SEA ensures that the LEA and schools meet
parental involvement requirements.

**[Recommendation]{.underline}**: The ED team urges the IDE to review
its guidance to LEAs regarding effective parental involvement to more
strongly emphasize school-level involvement that engages parents in
their children's education. Although LEAs and schools appear to meet
parental involvement requirements, such as written parental involvement
policies and home-school compacts, they would benefit from more
direction and guidance about effective parental involvement strategies
that result in a positive impact on student achievement.

Critical Element 2.5 -- The SEA ensures that schools and LEAs are
identified for improvement, corrective action, or restructuring as
required and that subsequent required steps are taken.

**[Finding]{.underline}:** When schools do not make adequate progress
for two years in a row, they are required to write, or revise, a school
improvement plan. School improvement plans examined by the ED team
during and after the site visit (called 2-year action plans in Iowa) do
not contain all of the required elements.

The following required elements are missing from one or more of the
plans reviewed:

-   Specific annual measurable objectives for progress for each subgroup
    of students. Analyzing subgroup performance and establishing
    objectives to address the learning needs of subgroups that are not
    succeeding is especially important in schools identified for
    improvement.

-   Clear delineation of the responsibilities of the LEA, including
    technical assistance it will provide, in helping the school to exit
    from school improvement.

-   Strategies to promote effective parental involvement. These are
    identified in each school's schoolwide plan, but are mentioned in
    only one of the school improvement plans. If the SEA or LEA chooses
    not to combine plan requirements into a single format, then the plan
    must indicate that required strategies can be found in another
    document

-   Explanation of teacher mentoring activities

[Citation]{.underline}: 20 U.S.C. 6316 §1116(b)(3) requires each school
identified for school improvement to develop or revise a school plan.
The school plan must include at least the ten components described in
this section.

[Further Action Required]{.underline}: The IDE must clarify for its LEAs
and schools the requirements of the school improvement plan. In cases
where a school is both a schoolwide program school and a school
identified for improvement as the result of not making adequate yearly
progress (AYP) for two consecutive years, the school may create or
revise a single plan, since doing so allows the school to concentrate
its efforts on a single set of goals and strategies. However, if the IDE
allows schools to create one plan, it must ensure that the statutory and
regulatory components of school improvement plans as well as the
statutory and regulatory components of schoolwide program plans are
included in the document. The ED team requests a copy of the guidance
offered by the SEA on this issue and one copy of a revised plan from a
school identified for improvement.

[Recommendation]{.underline}: The ED team encourages the IDE to continue
its efforts to consolidate and streamline planning processes and
products required of schools and LEAs. To the degree possible, LEAs and
schools should be allowed to author a single, strong plan that not only
includes required content, but truly "drives the work" of the school and
its staff.

Critical Element 2.6 -- The SEA ensures that requirements for public
school choice are met.

[Finding]{.underline}: The ED team found that public school choice is
offered in Iowa schools identified for improvement. However,
documentation revealed that in the Waterloo school district choice was
limited to only low-performing, high-poverty students. Although the LEA
is required to give priority to low achieving students from low-income
families, choice must be offered to all students in the school so
identified.

[Citation]{.underline}: 20 U.S.C. 6316 §1116(b)(1)(E)(ii) states that
the LEA shall provide all students enrolled in the school with the
option to transfer to another public school served by the LEA that has
not been identified for improvement. In providing students the option to
transfer, the LEA shall give priority to the lowest achieving children
from low-income families.

[Further action required:]{.underline} The IDE must clarify in its
guidance to LEAs that all parents of children who attend a school
identified for improvement, corrective action, or restructuring must be
notified of their option to have their child attend another school in
the LEA that is not so identified. It must also provide to ED
documentation that parents in the Waterloo school district have been
notified of this right.

**Area: Fiduciary**

Critical Element 3.1: The SEA ensures that its component LEAs are
audited annually, if required, and that all corrective actions required
through this process are fully implemented.

**[Recommendation:]{.underline}** Although the IDE has a system of
receiving notices of Title I non-compliance from IDE\'s School Finance
Section to follow up on LEA single audits, notices of Title I audit
findings and questioned costs for LEAs visited by the ED team were not
submitted to IDE. Since States must use such fiscal control and fund
accounting procedures to ensure proper disbursement of, and accounting
for, Federal funds paid to the State, the IDE should ensure that audit
findings and questioned costs are resolved in a timely and appropriate
manner. This would particularly benefit LEAs identified as high-risk
grantees under the Single Audit Act. Procedures for resolving and
tracking audit findings should also be included in the State's Title I
reference manual so IDE staff can better utilize LEA audit data to
strengthen accountability.

Critical Element 3.8: The SEA has a system for ensuring fair and prompt
resolution of complaints.

[Finding]{.underline}: The IDE does not have a complaint policy or
procedures in place for Title I issues.

[Citation:]{.underline} 20 USC 7844 § 9304(a)(3)(C) of ESEA requires
States to adopt written procedures for the receipt and resolution of
complaints alleging violations of law in the administration of programs.
This provision is required under the general applicability of State
educational agency assurances, whereby a State educational agency, in
consultation with the Governor of the State, that submits a consolidated
State plan or consolidated State application, shall have on file with
the Secretary a single set of assurances, applicable to each program for
which the plan or application is submitted

[Further Action Required]{.underline}: IDE must develop and have
approved through its regular approval and adoption process a set of
written procedures for the receipt and resolution of complaints, and
provide ED with these procedures.

Critical Element 3.5: The SEA ensures that LEAs provide Title I services
to eligible children attending private schools; and

Critical Element 3.9: The SEA ensures that the LEA complies with the
rank order procedures for the eligible school attendance area.

[Findings]{.underline}: The ED team found that the LEAs it visited did
not allocate Title I, Part A funds to their schools in accordance with
the statute and regulations. The LEAs visited did not (1) establish an
amount it uses to allocate per poor child and (2) allocate Title I funds
to schools based on the number of poor children residing within the
school attendance area. Rather, the districts used a "weighted budget"
based on full time equivalent (FTE) teacher counts. While the FTE
weighted budget takes into account the number of students on free and
reduced lunches and the rank order of schools according to poverty,
district documents indicate that resources were allocated based on
teacher assignments rather than on the number of poor children. In
addition, the LEA failed to identify the amount it allocated per poor
child---a figure that is needed to determine how much is needed to
provide equitable services for eligible students attending private
schools.

[Citation]{.underline}: Section 1113 of the Elementary and Secondary
Education Act (ESEA) (20 U.S.C.6313) and § 200.78 of the Title I
regulations require that an LEA allocate

Title I, Part A funds to eligible school attendance areas in rank order,
based on the total number of children from low-income families in each
area or school. Poverty is the only factor an LEA may use to allocate
Title I funds to school attendance areas or schools. An LEA may not
allocate Title I funds based on an instructional model, educational
need, or teacher assignments.

[Further Action Required]{.underline}: The IDE must ensure through its
monitoring process that each LEA within the State rank its school
attendance areas and schools according to its poverty rates and
determine its Title I allocations based on the number of poor children
in accordance with section 1113 of ESEA and § 200.78 of the Title I
regulations. In addition IDE must ensure that an LEA allocate an
equitable amount of Title I funds for services to eligible private
school children.

**[Finding]{.underline}:** The LEAs visited by the ED team could not
provide documentation that they correctly reserved funds from their
Title I, Part A allocations for required activities such as
choice-related transportation and supplemental services, professional
development, services to homeless children and children in locally
operated neglected institutions.

[Citation]{.underline}: Under §200.77 of the Title I regulations an LEA
must reserve funds before allocating funds to its schools to---

-   Provide services comparable to those provided to children in
    participating school attendance areas and schools to serve\--

```{=html}
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```
-   Children in local institutions for neglected children; and

-   Eligible homeless children who do not attend participating schools,
    including providing educationally related support services to
    children in shelters and other locations where homeless children may
    live.

```{=html}
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```
-   Meet the requirements for choice-related transportation and
    supplemental educational services in sections 1116(b)(10) and
    1116(e)(6) of the Title I statute and §200.48 of the Title I
    regulations unless the LEA meets these requirements with non-Title I
    funds. The statute and regulations require that, unless a lesser
    amount is needed, an LEA spend an amount equal to 20 percent of its
    Title I, Part A allocation for this purpose. Of this amount, 5
    percent must support choice-related transportation, 5 percent must
    support providing supplemental educational services, and the
    remaining 10 percent may support the costs of providing either
    choice-related transportation or supplemental educational services.

-   Meet the professional development requirements of---

```{=html}
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```
-   Section 1116(c)(7)(A)(iii) of the Title I statute and
    §200.52(a)(3)(iii) of the Title I regulations if the LEA has been
    identified for improvement. An LEA must reserve at least 10 percent
    of its Title I, Part A allocation for this purpose; and

-   Section 1119(l) of the Title I statute and §200.60 of the Title I
    regulations to meet the needs of teachers who are not highly
    qualified. An LEA must reserve an amount for this purpose that
    ranges from at least 5 to no more than 10 percent of its Title I,
    Part A allocation for school years 2002-03 and 2003-04 and at least
    5 percent in subsequent years.

```{=html}
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```
-   Meet the requirements for parent involvement. An LEA that receives
    more than \$500,000 under Title I, Part A, subpart 2 must reserve at
    least 1 percent of its allocation for parental involvement
    activities. The LEA must distribute not less than 95 percent of the
    amount reserved for parent involvement to schools receiving Title I
    services.

-   Administer Part A programs for public and private school children,
    conduct other authorized activities, such as preschool programs,
    summer school and intersession programs, additional professional
    development, school improvement, and coordinated

services.

-   Provide, if appropriate, services to\--

> Children in local institutions for delinquent children.
>
> Neglected and delinquent children in community day school programs.

-   Provide, where appropriate under section 1113(c)(4) of the Title I
    statute, not more than 5 percent of its Part A allocation for
    financial incentives and rewards to teachers who serve students in
    Title I schools identified for school improvement, corrective
    action, and restructuring, for the purpose of attracting and
    retaining qualified and effective teachers.

[Further Action Required]{.underline}: The IDE must ensure through its
monitoring procedures that LEAs correctly reserve the amounts required
by the Title I statute and regulations before allocating funds to their
school attendance areas and schools.

Critical Element 3.10: The SEA conducts monitoring of its subgrantees
sufficient to ensure compliance with Title I program requirements.

## Recommendation: The ED team strongly recommends that the IDE develop and implement a timely and systematic process for monitoring its grantees. During the onsite review, only one LEA visited by the ED team had available a Title I monitoring report issued by IDE. The monitoring review that resulted in that report was conducted in 1999, thus the most significant areas of NCLB were not addressed. States must ensure that programs will be administered in accordance with all applicable statutes, regulations, program plans, and applications. States must adopt and use proper methods of administering Federal programs, including the correction of deficiencies in program operations that are identified through audits, monitoring, or evaluation. 

State monitoring policies and procedures should address the onsite
review process as well as a method for correcting areas of noncompliance
identified during State reviews. Data collected through the monitoring
process should also inform other State activities, such as technical
assistance, strategic planning, and effective school improvement
strategies. Most effective monitoring plans also include a mechanism for
incorporating data from single audits into the process.

Critical Element 3.11: The LEA complies with the provision for
submitting an annual plan to the SEA.

**[Commendation]{.underline}**: IDE\'s document, *Local Educational
Agency Title I Reference Manual: 2003-2004,* provides detailed guidance
for submitting the annual LEA plan through the State's Title I
electronic Internet application system. This reference manual provides
an excellent summary of Title I allocation trends and issues. Highlights
of Title I requirements and Congressional policy changes over time are
clearly presented, and critical issues, such as eligibility criteria,
Federal allocation factors, hold harmless provisions, and counting local
neglected and delinquent children are described. State contact officials
and Federal and State web resource sites are also included.

**Title I, Part B Monitoring**

**Summary of Critical Monitoring Elements**

+--------------+---------------------------------+--------------+----+
| # Monitorin  |                                 |              |    |
| g Area 1: Ac |                                 |              |    |
| countability |                                 |              |    |
+--------------+---------------------------------+--------------+----+
| **Element    | **Description**                 | # Status     | #  |
| Number**     |                                 |              | Pa |
|              |                                 |              | ge |
+--------------+---------------------------------+--------------+----+
| Critical     | SEA complies with the subgrant  | Re           | 16 |
| element 1.1  | award requirements.             | commendation |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA requires applicants to  | Re           | >  |
| element 1.2  | submit applications for         | commendation | 16 |
|              | subgrants with the necessary    |              |    |
|              | documentation.                  |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | In making non-competitive       | Finding      | >  |
| element 1.3  | continuation awards, the SEA    |              | 16 |
|              | reviews the progress of each    |              |    |
|              | subgrantee in meeting the       |              |    |
|              | objectives of the program and   |              |    |
|              | evaluates the program based on  |              |    |
|              | the indicators of program       |              |    |
|              | quality.                        |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA refuses to award        | Finding      | >  |
| element 1.4  | subgrant funds to an eligible   |              | 16 |
|              | entity if the agency finds that |              |    |
|              | the entity has not sufficiently |              |    |
|              | improved the performance of the |              |    |
|              | program, as evaluated, based on |              |    |
|              | the indicators of program       |              |    |
|              | quality.                        |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA develops, based on the  | Re           | >  |
| element 1.5  | best available research and     | commendation | 16 |
|              | evaluation data, indicators of  |              |    |
|              | program quality for Even Start  |              |    |
|              | programs.                       |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA uses the Indicators of  | Met          |    |
| element 1.6  | Program Quality to monitor,     | Requirements |    |
|              | evaluate, and improve local     |              |    |
|              | programs within the State.      |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA conducts monitoring of  | Re           | >  |
| element 1.7  | its subgrantees sufficient to   | commendation | 17 |
|              | ensure compliance with Even     |              |    |
|              | Start program requirements.     |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA ensures that projects   | Finding      | >  |
| element 1.8  | provide for an independent      |              | 17 |
|              | local evaluation of the program |              |    |
|              | that is used for program        |              |    |
|              | improvement.                    |              |    |
+--------------+---------------------------------+--------------+----+

+--------------+----------------------------------+------------+------+
| # Moni       |                                  |            |      |
| toring Area  |                                  |            |      |
| 2: Instructi |                                  |            |      |
| onal Support |                                  |            |      |
+--------------+----------------------------------+------------+------+
| **Element**  | # Description                    | ### Status | ##   |
|              |                                  |            | Page |
+--------------+----------------------------------+------------+------+
| Critical     | The SEA uses funds to provide    | Reco       | 17   |
| element 2.1  | technical assistance to LEAs to  | mmendation |      |
|              | improve the quality of Even      |            |      |
|              | Start family literacy services   |            |      |
|              | or comply with State indicators  |            |      |
|              | of program quality.              |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program assisted shall      | Met        | N/A  |
| element 2.2  | include the identification and   | re         |      |
|              | recruitment of families most in  | quirements |      |
|              | need and serve those families.   |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program shall include       | Met        | N/A  |
| element 2.3  | screening and preparation of     | re         |      |
|              | parents and enable those parents | quirements |      |
|              | and children to participate      |            |      |
|              | fully in the activities and      |            |      |
|              | services provided.               |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | SEA ensures that all families    | Met        | N/A  |
| element 2.4  | receiving services participate   | re         |      |
|              | in all four core instructional   | quirements |      |
|              | services.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program shall be designed   | Co         | 17   |
| element 2.5  | to accommodate the participants' | mmendation |      |
|              | work schedule and other          |            |      |
|              | responsibilities, including the  |            |      |
|              | provision of support services,   |            |      |
|              | when those services are          |            |      |
|              | unavailable from other sources.  |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program shall include       | Met        | N/A  |
| element 2.6  | high-quality, intensive          | re         |      |
|              | instructional programs that      | quirements |      |
|              | promote adult literacy and       |            |      |
|              | empower parents to support the   |            |      |
|              | educational growth of their      |            |      |
|              | children, and in preparation of  |            |      |
|              | children for success in regular  |            |      |
|              | school programs.                 |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each instructional staff of the  | Met        | N/A  |
| element 2.7  | program hired after January 8,   | re         |      |
|              | 2002 of whose salary is paid in  | quirements |      |
|              | whole or in part with Even Start |            |      |
|              | funds, meets the Even Start      |            |      |
|              | staff qualifications.            |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004,** a      | Met        | N/A  |
| element 2.8  | majority of the individuals      | re         |      |
|              | providing academic instruction   | quirements |      |
|              | shall have obtained an           |            |      |
|              | associate's, bachelor's or       |            |      |
|              | graduate degree in a field       |            |      |
|              | related to early childhood       |            |      |
|              | education, elementary school or  |            |      |
|              | secondary school education, or   |            |      |
|              | adult education.                 |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004, if       | Met        | N/A  |
| element 2.9  | applicable,** a majority of the  | re         |      |
|              | individuals providing academic   | quirements |      |
|              | instruction shall meet the       |            |      |
|              | qualifications established by    |            |      |
|              | the [State]{.underline} for      |            |      |
|              | early childhood education,       |            |      |
|              | elementary or secondary          |            |      |
|              | education, or adult education    |            |      |
|              | provided as part of an Even      |            |      |
|              | Start program or another family  |            |      |
|              | literacy program.                |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004,** the    | Met        | N/A  |
| element 2.10 | person responsible for           | re         |      |
|              | administration of family         | quirements |      |
|              | literacy services has received   |            |      |
|              | training in the operation of a   |            |      |
|              | family literacy program.         |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004**,        | Met        | N/A  |
| element 2.11 | paraprofessionals who provide    | re         |      |
|              | support for academic instruction | quirements |      |
|              | will have a secondary school     |            |      |
|              | diploma or its recognized        |            |      |
|              | equivalent.                      |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall include | Met        | N/A  |
| element 2.12 | special training of staff,       | re         |      |
|              | including child-care workers, to | quirements |      |
|              | develop the necessary skills to  |            |      |
|              | work with parents and young      |            |      |
|              | children.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall provide | Co         | 18   |
| element 2.13 | and monitor integrated           | mmendation |      |
|              | instructional services to        |            |      |
|              | participating parents and        |            |      |
|              | children through home-based      |            |      |
|              | programs.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall operate | Met        | N/A  |
| element 2.14 | on a year-round basis, including | re         |      |
|              | the provisions of some program   | quirements |      |
|              | services, including              |            |      |
|              | instructional and enrichment     |            |      |
|              | services, during the summer      |            |      |
|              | months.                          |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local program shall be       | Met        | N/A  |
| element 2.15 | coordinated with other relevant  | re         |      |
|              | programs under the Adult         | quirements |      |
|              | Education and Family Literacy    |            |      |
|              | Act, the Individuals with        |            |      |
|              | Disabilities Act, and Title I of |            |      |
|              | the Workforce Investment Act of  |            |      |
|              | 1988 and the Head Start program, |            |      |
|              | volunteer literacy programs, and |            |      |
|              | other relevant programs.         |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall use     | Finding    | 18   |
| element 2.16 | instructional programs based on  |            |      |
|              | scientifically based reading     |            |      |
|              | research for children and        |            |      |
|              | adults.                          |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local program shall          | Co         | 18   |
| element 2.17 | encourage participating families | mmendation |      |
|              | to attend regularly and to       |            |      |
|              | remain in the program a          |            |      |
|              | sufficient time to meet their    |            |      |
|              | program goals.                   |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall use     | Finding    | 18   |
| element 2.18 | reading-readiness activities for |            |      |
|              | preschool children based on      |            |      |
|              | scientifically based reading     |            |      |
|              | research.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local program shall, if      | Met        | N/A  |
| element 2.19 | applicable, promote the          | re         |      |
|              | continuity of family literacy to | quirements |      |
|              | ensure that individuals retain   |            |      |
|              | and improve their educational    |            |      |
|              | outcomes.                        |            |      |
+--------------+----------------------------------+------------+------+

+--------------+-----------------------------------+------------+-----+
| # M          |                                   |            |     |
| onitoring Ar |                                   |            |     |
| ea 3: SEA Fi |                                   |            |     |
| duciary resp |                                   |            |     |
| onsibilities |                                   |            |     |
+--------------+-----------------------------------+------------+-----+
| **Element    | # Description                     | ### Status | #   |
| Number**     |                                   |            | # P |
|              |                                   |            | age |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA complies with the         | Met        | N/A |
| element 3.1  | allocation requirements for State | re         |     |
|              | administration and technical      | quirements |     |
|              | assistance, and award of          |            |     |
|              | subgrants.                        |            |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA ensures that subgrantees  | Met        | N/A |
| element 3.2  | comply with statutory and         | re         |     |
|              | regulatory requirements on uses   | quirements |     |
|              | of funds and matching.            |            |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA complies with the         | Met        | N/A |
| element 3.3  | cross-cutting maintenance of      | re         |     |
|              | effort provisions.                | quirements |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA ensures timely and        | Finding    | 19  |
| element 3.4  | meaningful consultation with      |            |     |
|              | private school officials on how   |            |     |
|              | to provide Even Start services    |            |     |
|              | and benefits to eligible          |            |     |
|              | elementary school students        |            |     |
|              | attending non-public schools and  |            |     |
|              | their teachers or other           |            |     |
|              | personnel, and local programs     |            |     |
|              | provide an appropriate amount of  |            |     |
|              | those services and benefits       |            |     |
|              | through an eligible provider.     |            |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA has a system for ensuring | Met        | N/A |
| element 3.5  | fair and prompt resolution of     | re         |     |
|              | complaints.                       | quirements |     |
+--------------+-----------------------------------+------------+-----+

**Title I Part B -- Even Start**

Area: Accountability

Critical Elements 1.1 and 1.2--Complying with Subgrant Award
Requirements

[Recommendation]{.underline}: In order to fund projects that more
strongly meet the purposes of the Even Start program, ED recommends that
the IDE increase the focus of the application package on the quality of
the educational services that will be delivered to families.

Critical Elements 1.3 and 1.4 -- Use of State Indicators for Making
Non-Competitive Continuation Awards and Refusal of Award to Grantees not
making Sufficient Progress

[Finding]{.underline}: During discussions with IDE staff, the ED team
learned that the State-developed indicators of program quality are not
being fully used for their intended purposes. IDE does not consider all
of the required indicators of program quality when determining if
subgrantees are making sufficient progress in order to make continuation
awards. In addition to not using all the required indicators of quality,
IDE does not evaluate programs against the program objectives outlined
in the original applications when making continuation awards.

[Citation]{.underline}: 20 U.S.C. 6381g(b)(3), Section 1238(b)(3) of
ESEA, requires States to use their indicators of program quality and to
review the progress of each program in meeting its program objectives to
determine if projects are making sufficient progress and to make
decisions about continuation awards.

20 U.S.C 6381g(b)(4), Section 1238(b)(4) of ESEA, allows States to
refuse to award subgrant funds to an eligible entity if the agency finds
that the eligible entity has not sufficiently improved the performance
of the program, as evaluated, based on the indicators of program quality
developed by IDE under Section 1240.

[Further Action Required]{.underline}: The SEA must ensure that the
indicators of program quality required in the statute are used by IDE to
make continuation award decisions.

Critical Element 1.5 -- Developing Indicators of Program Quality

[Recommendation]{.underline}: ED recommends that the SEA strengthen the
data collection process and the measures used to determine progress
against the Even Start indicators of program quality. ED also recommends
that the IDE strengthen the measures used to determine progress for
children in the development of language and literacy skills enrolled in
the early childhood education component. Currently children's movement
from one level to another level on an observational assessment
determines progress. It is unclear how progress from one level to the
next level on this measure is based on scientifically based reading
research or predictive of children\'s later achievement on State content
standards or State achievement standards. ED recommends that the SEA
choose a valid and reliable measure for each age group for use in
determining progress against this required indicator and that the
measure(s) be based on scientifically based reading research. The
measures should be designed to assess reliably those language and early
literacy skills that are linked by scientifically based reading research
to later reading outcomes.

Critical Element 1.7 -- Monitoring of Projects to ensure compliance with
Even Start program requirements

[Recommendation]{.underline}: IDE should develop a monitoring plan to
ensure all Even Start programs are monitored consistently and develop a
monitoring instrument that includes all required indicators and the 15
program elements of Even Start.

Critical Element 1.8 -- Independent Local Evaluation

[Finding]{.underline}: The local evaluations reviewed by the ED team did
not provide analysis of the data generated and did not include
recommendations for improvement.

[Citation]{.underline}: 20 U.S.C. 6381d(15), Section 1235(15) of ESEA,
requires that each program provide for an independent evaluation of the
program to be used for program improvement.

[Further Action Required]{.underline}: IDE must ensure that local
programs improve the quality of the local evaluations, which should
include an analysis of the data generated by the project and
recommendations for improvement.

Area: Instructional Support

Critical Element 2.1 -- State Use of Funds for Technical Assistance

[Recommendation]{.underline}: IDE's technical assistance efforts do not
appear to be tailored to the needs of each individual local project. ED
recommends that IDE's technical assistance efforts be targeted on areas
identified for improvement through the State performance indicators
during monitoring, or identified by local evaluators in the local
evaluation reports.

Critical Element 2.5 -- Flexible Scheduling

[Commendation]{.underline}: The IDE has encouraged (and the program site
visited demonstrated) flexibility in scheduling to accommodate various
parents' schedules, and removing obstacles by providing necessary
services such as childcare and transportation and outreach into the
community.

Critical Element 2.13 -- Provision of Home-Based Instruction

[Commendation]{.underline}: The program visited demonstrated its focus
on literacy and outreach to the families in the community participating
in its Even Start program through the successful implementation of La
Familia Inventory in conjunction with such activities as literacy book
bags.

Critical Element 2.16 and 2.18 -- Use of Scientifically Based Reading
Research and Reading-Readiness Activities are based on Scientifically
Based Research

[Finding]{.underline}: The local Even Start project in Iowa City did not
include a coherent instructional approach to teaching reading readiness
skills in the early childhood component of the family literacy program.
Also, based on materials reviewed during the interviews with project
staff in Iowa City, the ED team found that instructional services did
not appear to be based on scientifically based reading research.

[Citation]{.underline}: 20 U.S.C. 6381d(10), Section 1235(10) of ESEA,
requires that each program use instructional programs based on
scientifically based reading research for children and adults, to extent
that the research is available.

20 U.S.C. 6381d(12), Section 1235(12) of ESEA, requires that each
program include reading-readiness activities for preschool children
based on scientifically based reading research, to the extent available,
to ensure that children enter school ready to learn to read.

20 U.S.C. 6368(6), Section 1208(6) of ESEA, defines "scientifically
based reading research" as used in the Even Start statute (20 U.S.C.
6381a(e)(4), Section 1231a(e)(4) of ESEA.)

[Further Action Required]{.underline}: Local projects must use the
applicable statutory definition of "scientifically based reading
research" to ensure that instructional activities and services are based
on scientific research. The State coordinator should provide training in
this area for local project staff.

Critical Element 2.17 -- Attendance and Retention

[Commendation]{.underline}: The program visited credits its
participation rate to its outreach efforts to the families in the
community, its flexibility to accommodate schedules and offering support
services such as providing daycare.

Critical Element 3.4 -- Timely and Meaningful Consultation and Provision
of Equitable Services to Private School Children

**[Finding]{.underline}: The** IDE is not ensuring that the local
programs provide for the equitable participation of students enrolled in
non-public schools.

[Citation]{.underline}: 20 U.S.C. 7881 - 7886, Sections 9501 - 9506 of
ESEA, require recipients of Federal funds to provide eligible school-age
children who are enrolled in private elementary and secondary schools,
and their teachers or other educational personnel, educational services
and benefits under those programs on an equitable basis. Eligible
entities must provide the equitable services after timely and meaningful
consultation with the appropriate private school officials.

[Further Action Required:]{.underline} The IDE must ensure that all Even
Start projects meaningfully consult with private school officials in
order to provide Even Start services and benefits to eligible private
school students and their teachers or other educational personnel on an
equitable basis.