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Early Implementation of Supplemental Educational Services under the

No Child Left Behind Act

Year One Report

2004

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**Early Implementation of Supplemental**

**Educational Services under the**

**No Child Left Behind Act:**

**Year One Report**

Leslie M. Anderson

Lisa Weiner

Policy Studies Associates, Inc.

Washington, D.C.

*With the assistance of:*

Janie Funkhouser

Jeanine Hildreth

Elizabeth O'Driscoll

Michael Rubenstein

Karen Walking Eagle

Nick Winter

Policy Studies Associates, Inc.

Washington, D.C.

U.S. Department of Education

Office of the Under Secretary

2004

This report was prepared for the U.S. Department of Education under
Contract Number ED01CO0091 with SRI International. Collette Roney served
as the contracting officer's representative. The views expressed herein
do not necessarily represent the positions or policies of the Department
of Education. No official endorsement by the U.S. Department of
Education is intended or should be inferred.

**U.S. Department of Education**

Rod Paige

*Secretary*

June 2004

This report is in the public domain. Authorization to reproduce it in
whole or in part is granted. While permission to reprint this
publication is not necessary, the suggested citation is: U.S. Department
of Education, Office of the Under Secretary, Policy and Program Studies
Service, *Early Implementation of Supplemental Educational Services
under the No Child Left Behind Act: Year One Report*, Washington, D.C.,
2004.

To order copies of this report, write:

ED Pubs

Education Publications Center

U. S. Department of Education

P. O. Box 1398

Jessup, MD 20794-1398;

via fax, dial (301) 470-1244;

or via electronic mail, send your request to: <edpubs@inet.ed.gov>.

You may also call toll-free: 1-877-433-7827 (1-877-4-ED-PUBS). If 877
service is not yet available in your area, call 1-800-872-5327
(1-800-USA-LEARN); Those who use a telecommunications device for the
deaf (TDD) or a teletypewriter (TTY), should call 1-800-437-0833.

To order online, point your Internet browser to: www.edpubs.org.

This report is also available on the Department's Web site at
www.ed.gov/rschstat/eval/disadv/supplementalyear1 and
www.ed.gov/ods/ppss/reports.html - title.

On request, this publication is available in alternate formats, such as
Braille, large print, audiotape, or computer diskette. For more
information, please contact the Department's Alternate Format Center at
(202) 260-9895 or (202) 205-8113.

**Contents**

Executive Summary v

> States' Efforts to Implement Supplemental Educational Services vi
>
> The Districts' Role in Implementing Supplemental Services viii
>
> Supplemental Service Providers xiii
>
> Parents' Role in Supplemental Educational Services xv
>
> Lessons for the Future xvii

Introduction 1

> Overview of the Supplemental Educational Services Provisions of NCLB 2
>
> Evaluation Questions 2

States' Efforts to Implement Supplemental Educational Services 5

> Selecting Supplemental Service Providers 5
>
> Monitoring Providers 7

The Districts' Role in Implementing Supplemental Services 9

> District Efforts to Reach Parents 9
>
> Targeting Services 15
>
> The Role of Identified Schools 17
>
> District Management of Supplemental Service Providers 20
>
> District Funding for Supplemental Services 24

Supplemental Service Providers 29

> Getting Started 29
>
> Provider Curriculum and Instruction 30
>
> Provider Staff 31
>
> Monitoring Student Progress 32
>
> Communicating with Parents and Teachers 32
>
> Other Issues of Concern 33

Parents' Role in Supplemental Educational Services 35

> Parents' Assessment of Children's Educational Needs 35
>
> Parents' Criteria for Selecting Providers 36
>
> Parent Satisfaction with Provider Services 38
>
> Early Evidence of Effectiveness 38

Lessons for the Future 41

Appendix A: Characteristics of Sampled Schools A-1

**Tables**

Table 1: Supplemental Educational Services Eligibility and Participation
Levels

in District Case Study Sample ix

Table 2: Case Study Districts' Per Pupil Expenditures for Supplemental\
Educational Services xiii

Table 3: Characteristics of Supplemental Educational Service Providers,

by State, as of February 2003 7

Table 4: Characteristics of the District Case Study Sample 10

Table 5: Characteristics of Selected Supplemental Service Providers 27

Table IA: Characteristics of Sampled Schools for the Study of Early\
Implementation of the Supplemental Educational Services\
Provisions of NCLB A-1

**Executive Summary**

The No Child Left Behind Act (NCLB)[^1] expanded the range of choices
available to parents whose children attend Title I schools identified
for improvement. For example, children in schools not making adequate
yearly progress (AYP) for two consecutive years or more are now eligible
to transfer to another public school. Children from low-income families
enrolled in schools not making AYP for three years or more are eligible
to receive supplemental educational services, including tutoring,
remediation, and other academic instruction. According to NCLB, states
and school districts were required to implement the supplemental
educational services provisions at the beginning of the 2002-03 school
year. The U.S. Department of Education (ED) issued its draft
non-regulatory guidance in August 2002.[^2]

This study looks at early implementation of the supplemental services
provisions of NCLB through case studies of six states and nine school
districts and analyzes the ways in which some states and local school
districts have responded to the requirement to offer supplemental
services to parents and their children who attend Title I schools
identified for improvement. The study sample was purposefully selected
to include states and districts that appeared to be relatively far along
in implementing the supplemental services provisions in fall 2002, so
the study findings are not representative of implementation efforts
nationwide. This study of states and districts that were considered to
be further along than others was conducted to gain insights from these
efforts that could assist other states and districts.[^3]^,^ [^4]

Data collection for the study consisted of telephone interviews with
state administrators responsible for administering the supplemental
educational services provisions of NCLB. In addition, two-person teams
conducted site visits between January and March 2003 to each of nine
districts. Site visit teams conducted personal interviews with district
staff who had any involvement in planning or implementing supplemental
services. In addition, visits were made to up to three schools in each
district where site visit teams interviewed principals, conducted
teacher focus groups, and conducted either personal interviews or focus
groups with parents of children eligible to receive supplemental
educational services. Finally, the site visit teams interviewed up to
three supplemental service providers in each of the nine districts.

The study examines the successes and challenges that states, districts,
schools, and service providers experienced in implementing the
supplemental services provisions of NCLB. Key evaluation questions
include the following:

-   How are states and school districts working together to implement
    supplemental services?

-   How are states selecting providers?

-   How are school districts reaching out to and involving parents
    regarding supplemental services?

-   What services are provided?

-   What types of providers are offering and providing services?

-   What are the challenges and successes regarding implementation?

The first year report describes and analyzes important areas of activity
related to implementation of the supplemental educational services
provisions of NCLB. Specifically, it describes the early implementation
experiences of: (1) states; (2) school districts and schools; and (3)
supplemental service providers. In addition, it describes the
experiences of parents who, on behalf of their children, are attempting
to access available educational services. The final section of this
report presents some lessons drawn from the experiences of the case
study sites that could aid other states, districts, schools, and
providers as they work to implement the supplemental educational
services provisions of NCLB.

**States' Efforts to Implement Supplemental Educational Services**

Overall, administrators representing the six states included in the
study sample---usually Title I administrators---reported that they are
striving to respond to the new legislative requirement to implement
supplemental educational services. Nevertheless, the selection of
service providers has been slow and uneven. In addition, state
administrators have not yet developed systems for monitoring provider
performance.

**Selecting Supplemental Service Providers**

-   ***Most states included in the sample did not put forth much effort
    to encourage provider applications.*** As one state administrator
    explained, "We have not had the luxury to do advertising. Providers
    are finding us." Of the six states, five posted the provider
    application on their Web site or placed an advertisement in the
    newspaper. Administrators in one state also directly contacted a
    number of providers to encourage them to apply. Although the number
    of provider applications was as high as 288 in one of the six case
    study states, half of the states had fewer than 50 applicants, with
    one state receiving only 20 applications from potential providers.

-   ***Each of the six states generally followed the legislative
    requirements or the Department of Education's draft non-regulatory
    guidance with respect to establishing selection criteria for
    supplemental service providers.*** However, only four states
    required applicants to produce evidence of the connection between
    their programs to state academic standards. A fifth state required
    providers to ensure that its program was aligned with the school
    curriculum but made no mention of state standards. In addition,
    states varied in the extent to which they applied their criteria in
    selecting providers. Some states used reviewers and scoring rubrics
    to evaluate provider applications based on their selection criteria.
    Other states, however, dispensed with rubrics and selected providers
    based on their subjective notion of whether applications "appeared
    to be sound" or whether the state had past experience working with a
    provider. Most states pledged to shore up their rather
    loosely-applied selection criteria for the 2003-04 application
    process.

-   ***Several states in the case study sample rejected applicants who
    could not produce evidence of effectiveness in raising student
    achievement.*** The type of evidence of effectiveness states would
    accept was somewhat varied, however. One state required independent
    test data, school grades, and referral letters indicating family
    satisfaction with provider services. Another state simply asked for
    "evidence of recent successful experience in improving student
    academic achievement."

-   ***The majority of providers in each of the six states are private
    for-profit and nonprofit organizations.*** In addition, public
    schools and school districts are well-represented among the list of
    state-approved providers. However, although all six states have
    online providers, they represent a small percentage of
    state-approved supplemental service providers. Finally, only three
    of the six states have faith-based providers.

-   ***The range of state-approved supplemental service providers with
    respect to both location and service does not adequately match local
    need.*** Providers were often unable to serve the needs of rural
    areas as well as special education students and students with
    limited English proficiency.[^5] In addition, online providers were
    not available to some rural communities where Internet access or
    computer equipment was unavailable. The number of state-approved
    providers available to the nine districts in the study sample ranged
    from a low of two providers in a district to a high of 14 providers
    in a district.

> **Monitoring Providers**

***Most states included in the study sample have begun thinking about
ways to monitor provider performance, but none has yet collected any
data.*** For next year, two of the six states have hired or are planning
to hire external organizations to develop an instrument for the state
and relevant districts to use to monitor provider performance. The
majority of the six states included in the sample, however, have not yet
developed criteria for removing providers from approved lists.

**The Districts' Role in Implementing Supplemental Services**

District responsibilities include informing eligible parents about their
option to obtain supplemental educational services for their children,
entering into contracts with providers, and managing the costs of their
supplemental services program. Districts in the study sample reported
significant challenges in all of these areas.

#### District Efforts to Reach Parents

-   ***Most districts followed the legislative requirement to inform
    parents of the availability of supplemental educational services.***
    At a minimum, most districts mailed letters to parents---usually in
    English and translated into one other language---informing them of
    the supplemental services provisions and including, at a minimum,
    the names of the providers available to the district. Some
    districts, however, sent letters home with students rather than mail
    them. Several districts took the process one step further and posted
    advertisements in local newspapers informing the community about the
    availability of supplemental services. Two districts, however, did
    not send letters to parents notifying them of the availability of
    supplemental services for eligible students because the
    state-approved providers could not offer services that were
    accessible to these rural sites. Table 1 shows the number of schools
    in which students were eligible to receive supplemental services,
    the number of students who were eligible to receive services (and
    whose parents districts needed to contact), and the number of
    students who ultimately received services.

##### Table 1

**Supplemental Educational Services**

**Eligibility and Participation Levels in**

**District Case Study Sample**

+------------------------+----------+----------+----------+----------+
| **District Name**[^6]  | **Number | **Number | **Number | *        |
|                        | of       | of       | of       | *Percent |
|                        | Eligible | Eligible | Students | of       |
|                        | S        | St       | R        | Eligible |
|                        | chools** | udents** | eceiving | Students |
|                        |          |          | Se       | Served** |
|                        |          |          | rvices** |          |
+========================+==========+==========+==========+==========+
| **Brooktown School     | 3        | 900      | 138      | 15%      |
| District**             |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| **Cleartown School     | 3        | 140      | 0        | 0%       |
| District**             |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| **Las Cierras School   | 4        | 2,609    | 0        | 0%       |
| District**             |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| **Plainfield School    | 3        | 973      | 397      | 41%      |
| District**             |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| **Redding School       | 12       | 5,292    | 326      | 6%       |
| District**             |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| ## Rive                | 14       | 7,000    | 0        | 0%       |
| rside School District  |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| ## Smith               | 14       | 19,600   | 2        | \<1%     |
| ville School District  |          |          |          |          |
+------------------------+----------+----------+----------+----------+
| **Sunnydale School     | 59       | 4,50     | 1,900    | 32--42%  |
| District**             |          | 0--6,000 |          |          |
+------------------------+----------+----------+----------+----------+
| **Trainville School    | 5        | 2,600    | 510      | 17%      |
| District**             |          |          |          |          |
+------------------------+----------+----------+----------+----------+

-   ***Some districts went beyond the basic legislative requirements and
    took a very active approach to spearheading parent interest in
    supplemental services.*** For example, fearing that a full-scale
    recruitment process would yield more students than it could serve,
    one southern school district divided its outreach efforts into three
    phases, each intended to yield the most disadvantaged students
    within a category of schools. Another district hosted vendor fairs
    at the identified schools; used Title I district parent involvement
    funds to pay teachers to call parents to encourage them to apply for
    tutoring services; and encouraged principals and other school staff
    to conduct home visits to invite parents to take advantage of the
    supplemental services opportunity. Nevertheless, despite carefully
    planned, deliberate efforts to encourage participation in
    supplemental services, neither district succeeded in filling all the
    slots it expected to fund for supplemental services.

-   ***Contacting and communicating clearly with parents about the
    availability of supplemental services sometimes presented
    significant challenges to school districts.*** In some districts,
    many parent letters came back to the district office "return to
    sender; address unknown." This tended to happen in districts where
    there were very high mobility rates among families. A typical
    response to this problem was for districts, working with the
    schools, to send letters home with the students. In one district,
    providers noted that the district letter to parents was very
    difficult to understand (a sentiment echoed by teachers and
    principals). One provider said that when the letter went out, she
    received 10 phone calls from parents who did not understand what to
    do with the letter or when services would be provided. In another
    district, a universal complaint among school staff and providers was
    that the strategy used to inform parents was not suited to the
    population the program was trying to reach. Staff believed that
    using the media or telephone calls, rather than sending letters,
    would more effectively inform parents in their district about
    supplemental services.

-   ***Districts fear that although reaching parents was difficult this
    year, the challenges will multiply next year as the number of
    identified schools, and approved providers, increases.*** District
    leaders worry about the continuing challenge of giving parents
    informed choices; they have no idea what will happen next year when
    the number of schools identified for improvement will likely grow.

> **Targeting Services**

-   **Six of the nine districts in the case study sample targeted
    services for students based on poverty level and achievement.**
    Before determining whether services needed to be targeted or
    prioritized, several districts considered the number of students
    attending identified schools and the amount of Title I dollars
    available to fund the supplemental services provisions. For example,
    two districts anticipated a level of interest that would far exceed
    the dollars available to serve. Accordingly, they targeted the
    neediest students first, then loosened up selection restrictions as
    available slots went unfilled. Other districts determined the need
    to prioritize based on the initial response they received from the
    letters sent to parents.

-   ***Two districts prioritized services for poor, low-achieving
    students without knowing how much money they had available for
    supplemental services nor how many students that money would
    serve.*** Both districts seemed under the impression that they must
    identify students who are both poor and low-performing and were
    unfamiliar with the part of the legislation that specifies that
    performance need only be brought into the equation of defining
    eligibility for supplemental services if the district is unable to
    serve all low-income students who apply.

**The Role of Identified Schools**

-   ***Administrators in three of the nine districts tried to avoid
    burdening the schools with the implementation and coordination of
    supplemental services.*** Despite their best efforts, however, it
    seems implementation of supplemental services makes involving the
    schools nearly unavoidable. Indeed, two districts were ultimately
    forced to ask schools to assist them. One district, lacking a data
    system for collecting and storing districtwide student demographic
    and achievement data, needed schools to provide achievement data on
    the students whose parents expressed interest in supplemental
    services.

-   ***Most districts (six of nine) involve the schools identified for
    improvement in coordinating the provision of supplemental services
    to students.*** Several districts rely on the schools to recruit
    students and coordinate the delivery of supplemental services simply
    because they lack the staff capacity to administer this process
    centrally. Several schools reported playing a major role in
    notifying parents about the services available to their children.
    One school awarded the gift of a turkey to the teacher who turned in
    the most permission slips from parents. At another school in another
    district, the principal, assistant principal, counselor, and school
    secretary visited students' homes and held a meeting at a housing
    project to help parents complete application forms.

-   ***In spite of misgivings among some school staff, many principals
    and teachers are willing to help support implementation of
    supplemental services.*** Although NCLB does not specify a role for
    schools in implementing supplemental services, teachers in virtually
    every district expressed interest in knowing how they can help
    promote the program to parents. As many explained, classroom
    teachers are typically those who are best known to parents and it is
    they who will find it easiest to contact parents and convince them
    of the need for services. Teachers and principals are also needed to
    help parents distinguish among the myriad after-school programs
    offered in schools. Several teachers also expressed a willingness to
    communicate with providers about their students' progress.

#### District Management of Supplemental Service Providers

-   ***At least one district has put in place a system intended to
    manage the provider services available to schools.*** Several
    districts, however, have had limited activity managing, or even
    communicating with, providers. Managing providers is simpler when
    the number of providers is limited, and district management and
    oversight of supplemental service providers has been particularly
    easy in districts that have only one provider.

-   ***In some districts, providers indicated that they had had little
    interaction with the district about supplemental services and that
    this was frustrating.*** One provider described non-responsiveness
    on the part of the district. Another provider noted having problems
    getting names of participating students from the schools. "None of
    the lists matched. Some \[schools\] didn't make copies \[of the
    registration forms they collected\]."

-   ***Entering into contracts with service providers is new territory
    for the majority of districts in the study and is proving to be
    extremely time-consuming.*** According to the legislative
    requirements, districts are to enter into separate agreements with
    providers for each student a provider serves (i.e., to ensure that
    the specific needs and achievement goals of individual students are
    identified and addressed). Several district administrators said they
    had no real experience writing contracts for service providers. To
    the extent districts have contracts with service providers, they
    vary tremendously in scope and purpose. Some contracts lay out
    details regarding issues from parent involvement to anticipated
    student achievement. One district, however, in an effort to simplify
    the contracting process and to expedite the provision of services to
    students, wrote one contract to cover all the students that its one
    provider served.

-   ***Several districts struggled to define the terms of the provider
    contract.*** One district explained that the biggest challenge in
    writing the contract, for both the district and the provider, is
    knowing in advance the number of students who will be served. When
    entering into these contracts, providers often want some guarantee
    that a certain number of students will sign up for their services.
    This has implications for providers' staffing requirements.
    Nevertheless, this is a guarantee that districts were generally
    unable to provide.

-   ***If districts are attempting to measure provider performance at
    all this year---and many are not---their performance measures are
    usually "makeshift" or preliminary.*** That is, although the
    legislation assigns primary responsibility to the state for judging
    provider performance, most districts believe they must monitor
    providers because of the contractual agreements and believe they
    must ensure that providers are in compliance with those agreements.
    In addition, ED's draft non-regulatory guidance stated that district
    responsibilities include providing information the SEA needs to
    monitor the quality and effectiveness of the services offered by
    providers. However, one district administrator explained why
    districts are struggling to develop and apply fair measures of
    provider performance. For example, he asked, should districts use a
    common measure across all the providers? Another district
    administrator explained: "With tutors focusing on different skills,
    different subjects, different students, is this feasible or fair?
    Who carries primary responsibility for judging the quality of the
    tutors?"

```{=html}
<!-- -->
```
-   ***Most districts in the study sample pledge to have a clear
    accountability system for provider performance in place next
    year.*** At least one service provider outlined what she believes
    are reasonable guidelines for such a system. This provider, who was
    concerned that the very high student mobility rates in the district
    will make it difficult to fairly assess the program's effectiveness,
    made clear that her company will only make performance guarantees
    for students who are "full-cycle" (i.e., they have completed 45 or
    more hours of tutoring).

**District Funding for Supplemental Services**

-   ***The average district per-pupil expenditure for supplemental
    services was about \$865.*** However, the range in district per
    pupil expenditures ran from \$370 per student in one large central
    city to \$1,136 per student in a mid-size central city. Eight
    districts had determined their per-pupil expenditure for
    supplemental services; one had not. Table 2 shows the per-pupil
    expenditures calculated by the case study districts.

**Table 2**

**Case Study Districts' Per Pupil Expenditures**

**for Supplemental Educational Services**

+-----------------------------+----------------------------------------+
| **District Name**           | **Estimated Per Pupil Expenditure**    |
+=============================+========================================+
| **Brooktown School          | \$950                                  |
| District**                  |                                        |
+-----------------------------+----------------------------------------+
| **Cleartown School          | \$570                                  |
| District**                  |                                        |
+-----------------------------+----------------------------------------+
| **Las Cierras School        | No set amount---depends on provider    |
| District**                  |                                        |
+-----------------------------+----------------------------------------+
| **Plainfield School         | Max of \$1,036                         |
| District**                  |                                        |
+-----------------------------+----------------------------------------+
| **Redding School District** | \$986                                  |
+-----------------------------+----------------------------------------+
| **Riverside School          | \$1,136                                |
| District**                  |                                        |
+-----------------------------+----------------------------------------+
| ##                          | \$370                                  |
| Smithville School District  |                                        |
+-----------------------------+----------------------------------------+
| **Sunnydale School          | \$850 - \$1,000                        |
| District**                  |                                        |
+-----------------------------+----------------------------------------+
| **Trainville School         | \$940                                  |
| District**                  |                                        |
+-----------------------------+----------------------------------------+

-   ***The median number of hours of tutoring services that districts
    purchased per student among the sampled providers included in the
    case studies was about 40 hours, with an overall range of 28 to 228
    hours of tutoring services per student.*** Provider hourly costs
    ranged from \$5 to \$40 for one hour of tutoring services per
    student, with a median of \$22 per hour.

-   ***Because so few parents applied for supplemental services in
    2002-03, no district exhausted its budget.*** Indeed, the proportion
    of eligible students served ranged from less than 1 percent to 42
    percent (see Table 1). Districts in this study have untapped funding
    capacity to purchase supplemental services for many more students.
    Several districts expressed frustration about having so much money
    "tied up" for supplemental services while so few students requested
    them.

-   ***Several districts expressed concern about the administrative
    costs associated with implementing the supplemental services
    provisions.*** Several referred to the costs associated with mailing
    letters to parents. One district estimated that the cost of mailing
    letters to the families of students in just three identified schools
    was \$50,000 because the district had to find the parents'
    addresses, translate the letter into multiple languages, and send
    and resend the letters to parents who did not receive them on the
    first or second mailing. Another district sent out a mailing to
    almost 40,000 parents.

## 

## Supplemental Service Providers

Providers in the study sample were focused on recruiting students,
hiring staff, communicating with district administrators, teachers, and
parents, and delivering instructional services to students.
Nevertheless, providers face a number of challenges as they attempt to
respond to the demand for their services, none of which is likely to
diminish as they gain experience managing their programs in
collaboration with districts and schools.

**Getting Started**

***Providers in the study sample often lack sufficient notice from the
district regarding the number of students they will be expected to
serve.*** Also, providers said they need enough students requesting
services to make it a viable business proposition. That is, for many
providers, the cost of setting up their operations in a district cannot
be justified if only a handful of students request their services.
Indeed, several providers found themselves unable to offer services
because not enough parents had signed up. Providers in several districts
also talked about the difficulty they had getting final lists of
students from schools or districts.

**Provider Curriculum and Instruction**

-   ***The content and structure of provider tutoring services varies
    both within and across districts.*** According to ED's draft
    non-regulatory guidance, supplemental services may consist of
    academic assistance such as "tutoring, remediation and other
    educational interventions, provided that such approaches are
    consistent with the content and instruction used by the local
    education agency and are aligned with the state's academic content
    standards" (ED, 2002, p.1). Among the providers included in the
    study sample, most offer services that focus on reading instruction;
    however, the instructional approach in reading ranges from detailed
    diagnosis and scripted lessons to more general help with homework.
    Some provider services consist primarily of academic instruction
    while others offer a variety of activities, including homework help.

-   ***The extent to which providers coordinate their curricula with
    state or district standards is unclear.*** Few providers confirmed
    that their curricula were aligned with state or district standards
    and providers typically make only minor modifications to what
    appears to be their usually well-established program of services.
    Other providers, however, explained that their curricula were
    somewhat correlated with the regular classroom curricula or pointed
    out that their curricula were intended to prepare students for the
    state assessment. Finally, several providers explained that their
    services consisted of homework help.

-   ***Providers often must adapt their services to the dollars per
    child available through district supplemental service funding
    allocations. Typically, this requires increasing the student-teacher
    ratio and decreasing the number of sessions they would ordinarily
    provide.*** Several providers described adjusting the structure of
    their programs, usually by increasing the student-to-tutor ratio, to
    make the costs of program operations come within range of what the
    district was able to pay.

Provider Staff

Providers included in the study sample varied significantly with respect
to their staffing practices. Some providers use only certified teachers,
many of whom are or have been public school teachers. Other providers
use graduate students from local colleges and universities. Providers
often hire their tutors directly from the schools that students attend.
Several principals raised concerns about providers that hire teachers
directly from the schools identified for improvement.

**Monitoring Student Progress**

***Among the providers in the study sample that have begun offering
services, most have not yet fully defined their procedures for
monitoring and reporting student progress.*** Several providers plan to
schedule regular meetings, at varying intervals, with parents and
teachers as a part of their feedback process. One provider plans to meet
with and update parents and teachers every six weeks regarding student
progress whereas another provider intends to give student progress
reports to school leaders weekly and to parents twice in total. Still
another provider says it will administer tests and report the results to
parents on a quarterly basis.

**Communicating with Parents and Teachers**

Provider efforts to communicate with teachers and parents are extremely
varied and typically erratic. The nature of the communication tends to
be left to the judgment of the provider tutors. For example, one tutor
said that she carefully cultivates a good relationship with the teachers
of her students. "The relationship with the teacher depends on how you
approach the teacher. I call them and talk to them. If we had a whole
classroom, we couldn't \[call all of the teachers\]," she said.

Providers report making an effort to communicate with parents. Providers
admit that they are usually most in touch with those parents who
actively seek them out by stopping by before or after tutoring sessions.
Providers say that parents' work schedules and family responsibilities
often limit communication opportunities between providers and parents.
Providers also mentioned that language is often a barrier to effectively
communicating with parents.

**Parents' Role in Supplemental Educational Services**[^7]

Most parents of children eligible to receive supplemental educational
services are pleased to have the opportunity to enroll their child in a
tutoring program; these same parents also report satisfaction with their
children's schools and teachers.

#### Parents' Assessment of Children's Educational Needs 

-   ***Overall, the parents interviewed said they like and trust their
    children's schools and teachers even though the school is identified
    for improvement.*** Parents generally praised their schools and were
    happy with most of the teachers; parents were also well aware of the
    school's low performance. Parents often based their judgment of the
    school on the accessibility and personality of the teachers (e.g.,
    if he or she is caring and nice or not) and the school environment.

-   ***Most parents in the districts in this study chose to apply for
    supplemental services rather than transfer their child to another
    school, even when districts made efforts to educate parents about
    the choice option and explained that transportation would be
    provided.*** Most parents are familiar with their school and
    neighborhood and disliked the notion of sending their children
    "across town" to another school. In two of the districts,
    approximately 40 percent of eligible students received supplemental
    services. In the other seven districts included in the case study
    sample, the percent of eligible students served ranged from 0
    percent to 17 percent (see Table 1).

> **Parents' Criteria for Selecting Providers**

-   ***Parents included in the study report receiving varying amounts of
    information about their provider options.*** Some parents received
    only a letter from the district informing them of the supplemental
    services provisions of NCLB. Other parents were invited to and
    participated in district- or school-sponsored meetings intended to
    help them understand their options related to supplemental services.
    Some parents said they had heard about providers and services in the
    media. In other cases, parents received very little information on
    the topic. In one district, no parents who were interviewed were
    aware of their option for supplemental educational services.

-   ***Parents often rely on their children's teachers and schools to
    help them make decisions about supplemental educational services.***
    Many parents indicated that they were strongly influenced by their
    children's teachers regarding the need for supplemental services.

-   ***For most parents, transportation is the deciding factor in
    choosing among providers*.** Parents looked for providers who
    offered services at the school because they do not have
    transportation to take their children off-site. Many parents rely on
    public transportation to get where they need to go. Parents often
    chose providers based more on logistics and convenience than on
    educational concerns.

#### Parent Satisfaction with Provider Services

Parents whose children were already receiving services expressed
satisfaction with providers. Some parents, however, reported that the
time between services being offered to them and services being provided
was too long. They were concerned that their children would not receive
the maximum benefit from the program.

**Early Evidence of Effectiveness**

It is too early to report the actual effects of supplemental services on
those students who have begun working with service providers. For
example, in one district where tutoring started in January and testing
was scheduled for April, staff did not expect that measurable
improvements would become evident in such a short period of time.
However, some parents and teachers noted positive academic changes in
their students.

Lessons for the Future

Implementing the supplemental services provisions of NCLB has thrust
states, districts, schools, and providers into uncharted territory, and
most of the administrators interviewed would say it has been a learning
experience. State administrators, for example, have learned that the
provider application process must start sooner, require more information
about the range of services providers offer, and require more assurances
of provider competency and commitment. In addition, states have learned
that the application process must result in a wider range of applicants
with respect to the services they provide, the grade-levels they serve,
and the areas in which they work.

Districts have learned that they must more clearly articulate to parents
what the supplemental services provisions of the legislation offer them
and their children. They have also learned that they must make provider
services available to students sooner. In addition, districts have
learned that the process of contracting with providers is complicated
and time-consuming, yet they have few ideas about ways to lessen the
burden. Schools have learned that they know little about their role in
the implementation of supplemental services---they are usually willing
to do what they can to help but require more direction from the district
regarding how. Finally, most providers in the study sample had begun
providing supplemental services. Several providers described adjusting
the structure of their programs in order to make the cost of program
operations come within range of what the district was able to pay. What
no one has learned much about is how to monitor and evaluate provider
performance.

Finally, most administrators have learned that although start-up
activity this year was difficult and error-prone, most of the challenges
faced with respect to identifying providers, identifying schools,
identifying eligible students, and notifying parents will not go away
next year. That is, unlike other programs, these case study districts
believe that implementing supplemental services will present many of the
same challenges with each passing year. Every year, there will be new
providers, new schools, different numbers of students, and different
needs to serve. Nevertheless, the Year Two report will explore the
extent to which the supplemental services provisions of NCLB have gotten
any easier to implement and the extent to which states, districts,
schools, and providers have been able to build on their experiences of
the past year in implementing supplemental services in year two.

**Introduction**

The No Child Left Behind Act (NCLB), signed into law in January 2002,
expanded the range of choices available to parents whose children attend
Title I schools identified for improvement. For example, children in
schools not making adequate yearly progress (AYP) for two consecutive
years or more are now eligible to transfer to another public school.
Children from low-income families enrolled in schools not making AYP for
three years or more are eligible to receive supplemental educational
services, including tutoring, remediation, and other academic
instruction. According to NCLB, states and school districts were
required to implement the supplemental educational services provisions
at the beginning of the 2002-03 school year. The U.S. Department of
Education (ED) issued its draft non-regulatory guidance in August
2002.[^8]

This study looks at early implementation of the supplemental services
provisions of NCLB through a purposive sample of six states and nine
school districts[^9] and analyzes the ways in which states and local
school districts have responded to the expanded range of choices
available to parents and their children offered through NCLB. The study
sample was purposefully selected to include states and districts that
appeared to be relatively far along in implementing the supplemental
services provisions in fall 2002, so the study findings are not
representative of implementation efforts nationwide. This study of
states and districts that were considered to be further along than
others was conducted to gain insights from these efforts that could
assist other states and districts.[^10]^,^ [^11]

Data collection for the study consisted of telephone interviews with
state administrators responsible for administering the supplemental
educational services provisions of NCLB. In addition, two-person teams
conducted site visits between January and March 2003 to each of the nine
districts. Site visit teams conducted personal interviews with district
staff involved in planning or implementing supplemental services. In
addition, each team visited up to three schools in each district and
interviewed principals, conducted teacher focus groups, and conducted
either personal interviews or focus groups with parents of children
eligible to receive supplemental educational services. Finally, the site
visit teams interviewed up to three supplemental service providers in
each of the nine districts.

**Overview of the Supplemental Educational Services Provisions of NCLB**

Supplemental educational services are intended to increase the academic
achievement of students in low-performing schools. Specifically, NCLB
requires that supplemental services be consistent with the state's
academic content standards and with the instruction provided by the
school district. In addition, services must be provided outside of the
regular school day. School districts, in consultation with parents and
providers, must develop specific educational goals for each student.
Supplemental service providers measure the student's progress regularly
and report regularly on that progress to teachers and parents.

Supplemental educational services may be provided by a variety of
agencies, including for-profit and nonprofit entities, approved school
districts, faith-based organizations, and approved public or private
schools. Each state is required to develop criteria for selecting
providers and to provide school districts a list of available approved
providers in their geographic locations. School districts are
responsible for notifying parents of their children's eligibility to
receive supplemental educational services and for providing parents with
adequate information to select providers for their children. Parents may
select any approved provider in the area served by the school district
or within a reasonable distance of the school district. School districts
must make arrangements to reimburse providers directly for the services
they provide to eligible students.

All students from low-income families who attend Title I schools that
are in their second year or more of improvement, including those in
schools in corrective action and restructuring status, are eligible to
receive supplemental services. If funds are not sufficient to provide
supplemental educational services to each eligible student, the district
must give priority to the lowest-achieving eligible students.

Evaluation Questions

This study focuses on the successes and challenges states, districts,
schools, and service providers experienced in implementing the
supplemental educational services provisions of NCLB in the two years
following the enactment of the law. Key evaluation questions include the
following:

-   How are states and school districts working together to implement
    supplemental services?

-   How are states selecting providers?

-   How are school districts reaching out to and involving parents
    regarding supplemental services?

-   What services are provided?

-   What types of providers are offering and providing services?

-   What are the challenges and successes regarding implementation?

    This first year report describes and analyzes important areas of
    activity related to implementation of the supplemental educational
    services provisions of NCLB. Specifically, it describes the early
    implementation experiences of: (1) states, (2) school districts and
    schools, and (3) supplemental service providers. In addition, it
    describes the experiences of parents who, on behalf of their
    children, are attempting to access available educational services.
    The final section of this report presents some lessons drawn from
    the experiences of the case study sites that could aid other states,
    districts, schools, and providers as they work to implement the
    supplemental educational services provisions of NCLB.

**States' Efforts to Implement Supplemental**

**Educational Services**

Overall, administrators representing the six states included in the
study sample, usually Title I administrators, reported that they are
striving to respond to the new legislative requirement to implement
supplemental educational services. Nonetheless, the selection of service
providers has been slow and uneven. In addition, state administrators
have not yet developed systems for monitoring provider performance.

**Selecting Supplemental Service Providers**

Due to hiring freezes and spending caps, most of the six states included
in the study sample reported having limited staff capacity to do a
thorough job of attracting and vetting providers. Indeed, state efforts
to encourage provider applications, apply stringent criteria to provider
selection, and ensure variety in the location and type of provider were
meager.

***Most states included in the sample did not put forth much effort to
encourage provider applications.*** As one state administrator
explained, "We have not had the luxury to do advertising. Providers are
finding us." Similarly, an administrator in another state said they made
no special effort to encourage potential providers because they had
already received numerous inquiries. Although the number of provider
applications was as high as 288 in one of the six case study states,
half of the states had fewer than 50 applicants, with one state
receiving only 20 applications from potential providers.

Of the six states, five posted the provider application on their Web
site or placed an advertisement in the newspaper. Only one state went
beyond these measures to encourage provider applications. This southern
state sent letters to school districts encouraging them to apply or to
seek out providers who should be encouraged to apply to the state.
Administrators in this state also directly contacted a number of
providers to encourage them to apply. Of the six states in the study
sample, this southern state received the highest number of applications
from potential providers.

***Each of the six states in the case study sample generally followed
the legislative requirements or the Department of Education's draft
non-regulatory guidance with respect to establishing selection criteria
for supplemental service providers.*** All six states released requests
for proposals between May and September 2002. All six states required
providers to meet the following criteria---included in the legislation
or the draft non-regulatory guidance---for selection:

-   Provide evidence of program effectiveness.

-   Show intent to monitor student progress.

-   Show intent to ensure connections between the provider program and
    the program in the school.

-   Demonstrate intent to communicate with parents.

-   Provide evidence of financial and organizational capacity.

-   Provide evidence of compliance with local, state and federal health
    and safety standards.

-   Provide evidence of compliance with civil rights laws.

-   Provide evidence that all instruction and content are secular,
    neutral, and non-ideological.

However, although the legislation requires that providers ensure that
curriculum and instruction are aligned with state standards, only four
states specifically required applicants to produce evidence of the
connection between their program and state academic standards. One state
required providers to ensure that their program was aligned with the
school curriculum but made no mention of state standards. Finally, only
three states required that providers communicate with parents in their
native language.

Some states took the application process a step further than required by
the legislation, including additional selection criteria intended to
ensure that providers responded to local needs. For example, three
states required provider applicants to discuss their capacity to serve
eligible students (e.g., special education, English language learners,
etc.). Other states added criteria intended to ensure program quality.
All six states, for example, required providers to provide evidence of
qualified staff. In addition, two states required providers to produce
evidence of linkages between research and their program design. Finally,
in an effort to address liability and safety issues, four states
required that provider applicants produce evidence that their employees
have undergone background checks.

Most states in the case study sample rejected applicants who could not
produce evidence of effectiveness in raising student achievement. The
type of evidence of effectiveness states would accept was somewhat
varied, however. One state required independent test data, school
grades, and referral letters indicating family satisfaction with
provider services. Another state simply asked for "evidence of recent
successful experience in improving student academic achievement." Some
states rejected applicants that could not produce evidence of teacher
quality.

States included in the case study sample varied in the extent to which
they applied their criteria in selecting providers. Some states used
reviewers and scoring rubrics to evaluate provider applications based on
the state's selection criteria. Other states, however, dispensed with
rubrics and selected providers based on their subjective notion of
whether applications "appeared to be sound" or whether the state had
experience working with a provider in the past. Most states pledged to
shore up their rather loosely applied selection criteria for the 2003-04
application process.

Ultimately, the application process was not particularly selective in
two states, where 86 percent of their provider applicants were accepted.
Two more states accepted 65 percent of their applicants and the
remaining two states accepted 58 and 56 percent of their applicants. The
majority of providers in each of the six states are private, for-profit
and nonprofit organizations (Table 3). In addition, public schools and
school districts are well-represented among lists of state-approved
service providers. However, although all six states included in the
sample have approved online providers, they represent a small number of
state-approved supplemental service providers. Finally, only four of the
six states have faith-based providers.

##### Table 3

**Characteristics of Supplemental Educational**

**Service Providers, by State, as of February 2003**

  ------------ --------------- ---------------- ----------------- ------------ ----------- -----------
  **State**    **Number of                                                                 
               Providers, by                                                               
               Provider Type**                                                             

               **LEAs**[^12]   **Colleges and   **Faith-Based**   **Online**   **Other     **TOTAL**
               **and Public    Universities**                                  Private**   
               Schools**                                                                   

  State A      4               0                1                 3            6           14

  State B      124             1                3                 1            45          174

  State C      45              11               7                 10           51          124

  State D      16              0                4                 13           41          74

  State E      11              1                0                 2            8           22

  State F      2               1                0                 2            8           13

  **Total**    201             14               11                32           231         492
  ------------ --------------- ---------------- ----------------- ------------ ----------- -----------

***The range of state-approved supplemental service providers with
respect to both location and service does not adequately match local
need.*** Upon releasing the provider lists to districts in August or
September 2002, state administrators quickly learned that providers were
often unable to serve the needs of rural areas and were unable to serve
the needs of special education students and students with limited
English proficiency.[^13] In addition, online providers were not
available to some rural communities where Internet access or computer
equipment was unavailable. Still other providers opted to work only in
certain geographic areas rather than serving the district as a whole. In
addition, because few states required providers to specify in their
applications the number of contact hours and associated costs that they
were offering, districts would attempt to access provider services only
to discover that they were too expensive for the per-pupil dollar amount
the district could afford. Finally, one state administrator explained
that districts expressed concern about providers who may not be equipped
to adequately instruct "hard-to-teach" children, especially if they use
tutors who are not certified teachers, as is permissible under the law.

**Monitoring Providers**

***Most states included in the study sample have begun thinking about
ways to monitor provider performance, but none has yet collected any
data***. For next year, two of the six states have hired or are planning
to hire external organizations to develop an instrument for the state
and relevant districts to use to monitor provider performance. One state
will use the instrument to determine whether providers will be invited
to continue providing services. The majority of the six states included
in the sample, however, have not yet developed criteria for removing
providers from approved lists. Nevertheless, most states agree that
providers who fail to show gains in student achievement for two
consecutive years will be removed from state lists.

Finally, two states, stressing limited staff capacity, report that they
will not conduct any active monitoring, either formal or informal, of
provider performance despite the fact that the legislation requires all
states to monitor provider performance.

**The Districts' Role in Implementing Supplemental Services**

District responsibilities include identifying eligible students,
determining which providers on the state-approved provider list are
available to the district, informing parents of the available services,
collecting parent applications or signatures, coordinating provider
activities with schools, identifying funding sources, estimating
per-pupil expenditures, contracting with providers to provide services
to students who request them, and managing provider activity. Although
districts are not required to evaluate their providers, most districts
believe that they must collect data in order to ensure that the
providers are honoring the terms of their contractual agreement.

As Table 4 shows, districts vary tremendously in the number of schools
they have to work with, the number of providers they have available to
students, the number of students eligible to receive services, and the
number of students receiving services. Accordingly, districts have
approached implementation of supplemental services in a variety of ways.

District Efforts to Reach Parents

***Most districts included in the study sample followed the legislative
requirement to inform parents of the availability of supplemental
educational services.*** At a minimum, most districts mailed letters to
parents, usually translated into English and one other language,
informing them of the supplemental services provisions and including, at
a minimum, the names of the providers available to the district. Several
districts took the process one step further and posted advertisements in
local newspapers informing the community about the availability of
supplemental services. One district even had the letter printed on the
front page of the local newspaper and called it "free tutoring" instead
of supplemental services. It was not unusual for districts to send
letters to parents multiple times in an effort to generate interest in
supplemental services. Two districts in the study sample, however, did
not send letters to parents notifying them of supplemental services
because the state-approved providers could not offer services that were
accessible to these rural sites.

***Some districts went beyond the basic legislative requirements and
took a very active approach to spearheading parent interest in
supplemental services.*** For example, fearing that a full-scale
recruitment process would yield more students than it could serve, one
southern school district divided its outreach efforts into three phases,
each intended to yield the most disadvantaged students within the lowest
performing schools (see box on page 11).

**Table 4**

**Characteristics of the District Case Study Sample**

<table style="width:100%;">
<colgroup>
<col style="width: 7%" />
<col style="width: 13%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 10%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 7%" />
</colgroup>
<thead>
<tr class="header">
<th><strong>District Name</strong></th>
<th><strong>Demographics</strong></th>
<th><strong>Number of Eligible Schools</strong></th>
<th><strong>Date Received Provider List</strong></th>
<th><strong>Number of Providers in District</strong></th>
<th><strong>Date of Parent Notification</strong></th>
<th><strong>Student Eligibility Criteria for Services</strong></th>
<th><strong>Number of Eligible Students</strong></th>
<th><strong>Number of Students Receiving Services</strong></th>
<th><strong>Percentage of Eligible Students Served</strong></th>
<th><strong>Estimated Per Pupil Expenditure for Services</strong></th>
<th><strong>Date Services Began</strong></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td><h2 id="brooktown-school-district">Brooktown School
District</h2></td>
<td><p>Large Central City;</p>
<p>70,847 students;<br />
80% minority;<br />
27% LEP</p></td>
<td>3</td>
<td>September 2002</td>
<td>13</td>
<td>September 2002</td>
<td>Prioritized based on poverty and achievement</td>
<td>900</td>
<td>138</td>
<td>15%</td>
<td>$950</td>
<td>November 2002</td>
</tr>
<tr class="even">
<td><strong>Cleartown School District</strong></td>
<td><p>Rural;</p>
<p>2,091 students;<br />
72% minority;<br />
19% LEP</p></td>
<td>3</td>
<td>September 2002</td>
<td>2</td>
<td>None—services not accessible</td>
<td>Prioritized based on poverty and achievement</td>
<td>140</td>
<td>0</td>
<td>0%</td>
<td>$570</td>
<td>NA</td>
</tr>
<tr class="odd">
<td><h2 id="las-cierras-school-district">Las Cierras School
District</h2></td>
<td><p>Rural;</p>
<p>2,491 students;<br />
99% minority;<br />
75% LEP</p></td>
<td>4</td>
<td>October 2002</td>
<td>2</td>
<td>None—services not accessible</td>
<td>None—all eligible</td>
<td>2,609</td>
<td>0</td>
<td>0%</td>
<td>No set amount - depends on provider</td>
<td>NA</td>
</tr>
<tr class="even">
<td><h2 id="plainfield-school-district">Plainfield School
District</h2></td>
<td><p>Large Central City;</p>
<p>68,277 students;<br />
56% minority;<br />
7% LEP</p></td>
<td>3</td>
<td>August 2002</td>
<td>4</td>
<td><p>August</p>
<p>2002</p></td>
<td>Prioritized based on poverty, grade-level, and achievement</td>
<td>973</td>
<td>397</td>
<td>41%</td>
<td>Max of $1,036</td>
<td>January 2003</td>
</tr>
<tr class="odd">
<td><strong>Redding School District</strong></td>
<td><p>Mid-size Central City;</p>
<p>35,344 students;<br />
71% minority;<br />
1% LEP</p></td>
<td>12</td>
<td>August 2002</td>
<td>3</td>
<td><p>August</p>
<p>2002</p></td>
<td>None—all eligible</td>
<td>5,292</td>
<td>326</td>
<td>6%</td>
<td>$986</td>
<td>January 2003</td>
</tr>
<tr class="even">
<td><h2 id="riverside-school-district-1">Riverside School
District</h2></td>
<td><p>Mid-size Central City;</p>
<p>16,424 students;<br />
63% minority;<br />
12% LEP</p></td>
<td>14</td>
<td>September 2002</td>
<td>3</td>
<td><p>October</p>
<p>2002</p></td>
<td>Prioritized based on poverty and achievement</td>
<td>7,000</td>
<td>0</td>
<td>0%</td>
<td>$1,136</td>
<td>NA</td>
</tr>
<tr class="odd">
<td><h2 id="smithville-school-district-2">Smithville School
District</h2></td>
<td><p>Large Central City;</p>
<p>73,587 students;<br />
39% minority;<br />
7% LEP</p></td>
<td>14</td>
<td>October 2002</td>
<td>14</td>
<td><p>October</p>
<p>2002</p></td>
<td>None—all eligible</td>
<td>19,600</td>
<td>2</td>
<td>&lt;1%</td>
<td>$370</td>
<td>January 2003</td>
</tr>
<tr class="even">
<td><h2 id="sunnydale-school-district">Sunnydale School
District</h2></td>
<td><p>Large Central City;</p>
<p>117,207 students;<br />
91% minority;<br />
2% LEP</p></td>
<td>59</td>
<td>August 2002</td>
<td>6</td>
<td>November 2002</td>
<td>Phased in based on school and student performance</td>
<td>4,500–6,000</td>
<td>1,900</td>
<td>32–42%</td>
<td>$850 - $1,000</td>
<td>January 2003</td>
</tr>
<tr class="odd">
<td><strong>Trainville School District</strong></td>
<td><p>Large Central City;</p>
<p>52,850 students;<br />
77% minority;<br />
28% LEP</p></td>
<td>5</td>
<td><p>July</p>
<p>2002</p></td>
<td>12</td>
<td><p>August</p>
<p>2002</p></td>
<td>Prioritized based on poverty and achievement but served all who
requested services</td>
<td>2,600</td>
<td>510</td>
<td>17%</td>
<td>$940</td>
<td><p>April</p>
<p>2003</p></td>
</tr>
</tbody>
</table>

Another district included in the study sample exerted similar levels of
effort to encourage parents to enroll their children in supplemental
services. This district introduced several strategies to try to reach
parents, including the following:

-   Hosting a "vendor fair," held for one whole day at each of the three
    identified schools to give parents an opportunity to learn about the
    services offered. Both parents and staff were encouraged to interact
    with and learn more about each provider.

-   Using Title I district parent involvement funds to pay a stipend to
    teachers of students in the highest priority grades who were willing
    to call parents of low-achieving students, on their personal time,
    to encourage them to apply for tutoring services.

-   Encouraging principals and other school staff to conduct home visits
    to invite parents of students in the greatest need to take advantage
    of the supplemental services opportunity.

According to the district administrator, if they had not really "pushed"
in terms of reaching out to the parents of the most academically needy
and economically deprived students, they would not have served the
lowest achieving students. "We would have had \[average\] or
above-average kids enrolled in supplemental services primarily. We had
to put these students on hold while we tried to fill slots with those
with the highest need," he said.

Despite their carefully planned, deliberate efforts to encourage
participation in supplemental services, neither district succeeded in
filling all the slots it expected to fund for supplemental services.

***Once initial letters were sent to parents informing them of the
availability of supplemental services, districts' parent outreach
activity varied tremendously.*** Some districts relied on the schools to
follow-up with parents and encourage participation. For example, one
district sent applications for supplemental services to parents with
instructions for them to take the applications to school to request
services and to see what is available. The district included the state
list of providers with the application. Other districts followed-up with
parents by providing them with additional written information. For
example, after sending letters (in English, Spanish, and Hmong) to
parents to say that their child's school was eligible and some students
would be identified to receive supplemental services, one district sent
additional letters to individual parents or guardians inviting them to a
meeting to get an overview of the program and to listen to providers
describe their services. These meetings were held at all five identified
schools. Parents also received a table documenting the characteristics
of each provider's services (i.e., where services would be held,
personnel, frequency, structure, subject, accommodation of second
language learners, frequency of progress reports, attendance policy,
grade level served).

By contrast, another district waited until February before reconnecting
with families who had expressed interest in supplemental services after
receiving the initial introductory letter in October. Some parents who
had received a call from the district said they were told that they
would soon receive another packet of forms to complete so their children
could receive supplemental educational services. None had yet received
the forms at the time of the visit to the district.

***Problems in translation.*** One district reported that efforts to
reach parents were hindered by the lack of available resources for
translation services. This was particularly problematic because so much
information (e.g., written reminders, announcements, etc.) was sent home
to parents and there was already confusion, even among native English
language speakers, about the specifics of the supplemental services. The
need for ongoing communication was great but could not be adequately
provided because district resources with respect to translation services
were limited.

Another district explained that language and cultural problems make
communication difficult. "The students become the translators for their
parents, but they don't really understand what \[supplemental services\]
are about," explained one district administrator. "But if you can get
the parents to come to a meeting and understand, they will make sure
their kids show up."

***Contacting and communicating clearly with parents about the
availability of supplemental services sometimes presented significant
challenges to school districts.*** In some districts, many parent
letters came back marked "return to sender; address unknown." This
tended to happen in districts where there were very high mobility rates
among families. As one principal explained:

> *...\[M\]y clientele is very poverty-oriented and transient. Last year
> we had 54 percent transience within the district. I have up to 35
> homeless kids at one time. We feed from three homeless shelters.*

A typical response to this problem was for districts, working with the
schools, to send letters home with the students. In using this approach,
however, districts run the risk that the letters will be distributed
inconsistently. For example, in one case study district, some of the
schools sent letters to the homes of all children in the school, but in
others, letters were given to teachers who then distributed them to
those students whom they believed were most in need of help despite the
fact that teachers do not necessarily know which students met the
poverty criteria. In one school, for example, teachers were given six or
seven letters and told to identify the children who should receive them.
One teacher indicated that she selected her lowest achieving students
and those who spoke Spanish, but little English, because, "They need the
most help," she said. Another teacher, however, did not seem to
understand the selection criteria and selected students who were not the
lowest achieving in her class but whom she believed only needed a little
extra help to get up to grade level.

Another district provided information about supplemental services on the
last page of the October 2002 edition of its monthly newsletter. The
services were described as "before- or after-school tutoring, from
private individuals or organizations identified by the \[state\]." In
addition, the newsletter explained that the availability of supplemental
services was limited and that students "may be eligible" to receive
them. The newsletter did not include a list of approved providers.
Rather, parents were referred to the state Web site or to the school
office for information about service providers. Parents were told to
obtain application forms from their school office and that the deadline
for applying for services was November 2002. Focus group data from two
schools suggest that few teachers or parents understood the newsletter
information. As one parent explained, "You had to read between the lines
to know what was being offered." In addition, several parents noted that
few parents read all the way through district newsletters---if they read
them at all.

In another district, providers noted that the district letter to parents
was very difficult to understand (a sentiment echoed by teachers and
principals). One provider said that when the letter went out, she
received 10 phone calls from parents who wanted to sign their children
up for services right then; parents did not understand what to do with
the letter or when services would be provided. She called the district,
which acknowledged that parents were indeed confused by the letter. As
the superintendent explained:

> *People were confused when the letter went out to parents; we didn't
> have enough time to do parent information meetings. We will learn from
> that piece and will be able to start the information sharing earlier
> in the year.*

In yet another district, a universal complaint among school staff and
providers was that the strategy used to inform parents was not suited to
the population the program was trying to reach. The following comments
from a provider and a principal, respectively, illustrate the problems
with district efforts to notify parents:

> *\[The district\] did not properly notify parents. Using direct mail
> and notes \[sent\] home to parents is a poor way to communicate with
> \[low-income\] parents. Low-income parents respond to what they hear
> on television and radio. They should have invited parents using the
> media and telephone calls. If I could promote my program directly to
> students, I would have had a much better response.*
>
> *The brochures were too much.... My concern about it was whether
> parents understood the information. Some said no transportation will
> be provided. I'm not sure whether parents were sure about the
> implications \[of that\]. It was too much information. Parents'
> educational level is not too good. This was about 20 minutes \[worth\]
> of reading. Give parents what they need to know, what choices they
> have, big letters about \[lack of\] transportation, and the deadline.
> They could have saved a million dollars at the printer.*

***In one school district, central office administrators and school
staff alike maintain that parents are ill-equipped to negotiate the
system of supplemental services they are offered.*** One district
administrator explained that parents are unable to choose a provider on
their own and need the district to assist them. The district Title I
team expressed concern that the choice provisions of the law assume
middle class expectations for parents who are not middle class. One of
them said,

> *The law was constructed from a middle class viewpoint, believing that
> parents would look at a form and pick... We have middle class
> expectations for parents who don't have the background to respond and
> a lot of what we do perpetuates this.*

Central office administrators in this school district also reported that
communicating with parents by mail and imposing a deadline for a
response is not effective with their particular parent population. In
their district, it would be necessary to "approach parents in a way that
appreciates the pressures they are under." Administrators in this
district believed that deadlines do not mean a great deal to a parent
"worried about putting food on the table." The Title I director summed
up the challenges of communicating with and empowering parents:

The way it is set up is a nightmare for the district. We bring the
presenters and allow them to share the information with the parents but
the information is way over the parents' heads. One sounded like a car
sales pitch and used terminology parents don't understand. He had no
experience in talking to parents. He was the only provider who showed up
so parents selected him. It would be good if we could screen and narrow
options.

The Title I team in this district thought that nine providers was too
large a pool for parents to choose among. That is, they believed that
parents lacked the capacity to discriminate between the qualifications
and background of multiple providers.

***Districts fear that although reaching parents was difficult this
year, the challenges will multiply next year as the number of identified
schools, and approved providers, increases.*** Although district leaders
recognize that this year's start-up activities have taught them a great
deal about implementation of the supplemental services provisions, they
worry about the continuing challenge of giving parents informed choices.
Administrators have no idea what will happen next year when the number
of schools identified for improvement will likely grow. Two Title I
administrators shared their worries:

> *There will be approximately 30 schools and 15,000 students eligible
> for supplemental services next year \[compared to the 3 schools and
> 1,200 students currently eligible\]. That will mean a tremendous
> administrative burden for us.*
>
> *Just organizing the whole thing \[is difficult\]. I had the providers
> sit down with the principals so they could have input and talk about
> what each needed from the other. Now that services have started,
> \[communication and coordination among providers, principals, and
> parents\] is better. When we add schools, though, we'll have to do
> start-up again. We will probably have to sign new agreements each
> year.*

Targeting Services

**Six of the nine districts in the case study sample targeted services
for students based on poverty level and achievement.** According to ED's
draft non-regulatory guidance, all students from low-income families who
attend Title I schools identified for the second year of school
improvement, corrective action or restructuring are eligible to receive
supplemental services. However, if available district funds are
insufficient to provide supplemental educational services to eligible
students whose parents request services, the school district must give
priority to the lowest-achieving students.

Before determining whether services needed to be targeted or
prioritized, several districts considered the number of students
attending identified schools and the amount of Title I dollars available
to fund the supplemental services provisions. For example, two districts
anticipated a level of interest that would far exceed the dollars
available to serve. Accordingly, they targeted the neediest students
first, then loosened up selection restrictions as available slots went
unfilled. Other districts determined the need to prioritize based on the
initial response they received from the letters sent to parents. If the
response to the letters was greater than the number of students
districts estimated they were able to serve, then services were provided
to students with the lowest achievement. In at least three districts,
however, due to low levels of interest, all eligible students
(regardless of achievement) were allowed to receive services.

Examples of ways in which districts prioritized the allocation of
supplemental services include the following:

-   Parents of students performing two levels below their
    age-appropriate grade on the state assessment were contacted and
    encouraged to enroll in supplemental services.

-   Lowest achieving students in the highest need grade received
    priority for supplemental services. Lowest achieving students in two
    of the highest need subjects received second priority. Lowest
    achieving students in one of the highest need subjects received
    third priority. Lesser priority levels were assigned according to
    the following criteria: lowest achieving students in reading (any
    grade); lowest achieving students in math (any grade); lowest
    achieving students in language (any grade); lowest achieving
    students in vocabulary (any grade) and lowest achieving students in
    math applications (any grade).

-   Students in schools on probation and scoring in the lowest quartile
    on state assessments received highest priority, followed by students
    in schools on notice and scoring in the lowest quartile on state
    assessments. Third priority was given to all students attending
    probation schools, regardless of achievement.

One district, however, prioritized services for poor, low-achieving
students without knowing how much money it had available for
supplemental services or how many students that money would serve. Given
that less than 350 parents expressed interest in supplemental services,
it seems unlikely that this district could not meet the needs of every
eligible student. And yet, ultimately, only 166 students are currently
approved by the district to receive provider services. The same was true
in another district, where the students in the lowest quartile of
performance were targeted to receive services. Both districts were
unfamiliar with the part of the legislation that specifies that
performance need only be brought into the equation of defining
eligibility for supplemental services if the district is unable to serve
all students from low-income families who apply; administrators in these
two districts were under the impression that they must identify students
who are both poor and low-performing.

***District administrators raised several issues that suggest that the
legislation and subsequent guidance have been sources of both confusion
and consternation with respect to targeting services.*** For example,
one district was confused about whether it could serve students who were
not both high poverty and low achieving, misunderstanding that all
students from low-income families are eligible. The district
representative also believed that because the money and resources had
already been committed to supplemental services, it was only fair that
any student within the school who desired services receive them. "\[A
student\] should not be turned away if the space and capacity to serve
him or her exists," he said. Although districts are not precluded by the
law from serving students other than those from low-income families,
districts cannot count the cost of serving them as part of the 20
percent allocation they must set aside for supplemental services.

In a slight twist to the targeting issue, one district was unable to
provide services to at least 10 of the lowest achieving students in the
district because these students were not eligible. That is, these
students did not qualify for free or reduced-price school lunches, as is
required for eligibility. The district representative noted that this
seemed somewhat unfair, especially given the fact that, for various
reasons, some parents whose children would normally be eligible for free
lunches do not take advantage of the program out of pride and instead,
struggle to provide the lunches themselves. She described a heated
exchange with a parent who asked incredulously: "You mean I have to
apply for free lunch in order to get tutoring for my child?" she
demanded. The district representative agrees with this parent's
position, arguing that the lowest-achieving children in a schoolwide
program should have access to services regardless of their economic
condition as measured by application for free or reduced-price lunches
(under the National School Lunch Program administered by the U.S.
Department of Agriculture).

The Role of Identified Schools

Neither the legislation nor ED's draft non-regulatory guidance sets any
expectation that schools would play a role in implementing the
supplemental services provisions of NCLB. Indeed, the legislation
appears to bypass schools entirely by requiring districts to communicate
directly with parents and providers regarding the supplemental services
provisions. Some districts have tried to leave out of the implementation
process identified schools whose students are eligible to receive
supplemental services. However, the practical realities of offering
supplemental services---before- and after-school services offered to a
population of students that is typically hard-to-reach---makes
implementation without involving schools difficult to accomplish.

***Administrators in three of the nine districts tried to avoid
burdening the schools with the implementation and coordination of
supplemental services.*** In one district, the Title I office handled
the entire recruitment process, and only asked schools to collect the
registration cards and send them to the Title I office. Title I
facilitators at the schools were available to answer questions, but the
two facilitators interviewed, and their principals, said they fielded
few questions from parents. The principal at one school said, "The Title
I office did the bulk of the work \[of recruiting parents and processing
applications\]. Our part was made smooth because of all the work the
Title I office did for us."

In another district, the efforts of district staff to avoid burdening
the schools were evident given that many of the teachers interviewed had
little or no knowledge of the supplemental services provisions. As
teachers in one district explained:

> *I didn't know what supplemental services was. I assumed it was
> me---in the classroom---that we have to work harder....*
>
> *We are all in the dark. Maybe the information was not filtered down
> correctly. We hear about so much, it sounds similar to many other
> services so we didn't know the difference.*

Despite these districts' best efforts, however, it seems implementation
of supplemental services makes burdening the schools nearly unavoidable.
Indeed, two districts were ultimately forced to ask schools to assist
them. One district, lacking a data system for collecting and storing
districtwide student demographic and achievement data, needed schools to
provide achievement data on the students whose parents expressed
interest in supplemental services. In that same district, schools were
burdened with many phone calls---in one case, hundreds---from anxious
parents who did not understand the district letter and feared their
child's school was closing. Other parents simply called to inquire about
the types of services that were going to be offered.

> *We had about 200 calls about the letter. Parents didn't understand
> it. They thought \[the district\] was closing \[the school\]. Getting
> parents to understand what \[supplemental services\] is was very
> difficult. They don't have a high education level.... When we started
> \[sending out the letters\] there was a lot of confusion. No one knew
> what the guidelines were. So \[the district\] sent the letter to
> everyone, low income or not. Then \[the district\] asked us to attach
> information---standardized testing data, how students were achieving
> in the classroom, etc.---to the parent applications the district
> received. It was a lot of work.*

In another district, the involvement of school staff changed once
services began. According to one principal, "It's working, but we made
it work." The principal reported having to change the work schedules of
five employees so the school would have maintenance and security staff
on-site until the program ends at 5:30. "My custodial staff doesn't
\[normally\] stay that late.... They are not happy," she said tersely.
Moreover, the provider asked that the principal remain on-site until 5
p.m. every night, but she refused.

***Most districts visited (six of nine) involve the schools identified
for improvement in coordinating the provision of supplemental services
to students.*** Several districts rely on the schools to recruit
students and coordinate the delivery of supplemental services simply
because they lack the staff capacity to administer this process
centrally. Several schools reported playing a major role in notifying
parents about the services available to their children. One school
awarded the gift of a turkey to the teacher who collected the most
parent permission slips. At another school in another district, the
principal, assistant principal, counselor, and school secretary visited
students' homes and held a meeting at a housing project to help parents
complete application forms.

In several districts, although schools were expected to participate in
the implementation process, teachers and principals were not entirely
clear about their responsibilities. For example, according to one
principal interviewed: "We didn't understand at first that we had to
give parents a choice of providers, that came out after the fact." As a
result, parents at this school learned about other available
supplemental service providers only after being told that only one
provider was available to serve their children.

***In spite of some misgivings among some school staff, many principals
and teachers are willing to help support implementation of supplemental
services.*** Although NCLB does not specify a role for schools in
implementing supplemental services, teachers in virtually every district
in the study sample expressed interest in knowing how they can help
promote the program to parents. Indeed, most school staff said they
recognize that schools play a significant role with respect to
implementation of the supplemental services provisions of NCLB. As many
explained, classroom teachers are typically those who are best known to
parents and who typically find it easiest to contact parents and inform
them of available services. Teachers and principals are also needed to
help parents distinguish among the myriad after-school programs offered
in schools. Several teachers also expressed a willingness to communicate
with providers about their students' progress. Teachers said the
following:

> *It would be nice to have communication with providers. I want to know
> what they're doing, how children are performing, what they see as the
> children's strengths and needs.*
>
> *I would like progress reported by e-mail weekly or biweekly. The
> chances of our meeting and talking with them are slim---no time, but
> some regular correspondence by e-mail---a way to comment back and
> forth. Something that's fast.*

***Relying on principals and teachers to coordinate supplemental
services may not always result in successful implementation. Some school
staff in at least four districts resented the program.*** One district
administrator observed that the supplemental services program had a
"demoralizing" effect. He said, "\[It implies\] we have to hire someone
else to help your kids succeed." This could account for the "wait and
see" attitude that many teachers have taken toward the program and the
attitude of neutrality or even resentment that was evident during some
of the teacher interviews:

> *\[I do not\] really think there is a need for this program because of
> the preexisting programs. I take it as an affront that students have
> to go to outside vendors. This is what the school should be providing.
> \[The providers\] are competition \[for us\].*
>
> *We have so many services. We have Title I summer school and reading
> for summer school. We provide breakfast and lunch. I haven\'t seen the
> need \[for supplemental services\].*

In all four districts, it was believed that the supplemental services
program had created some jealousies among teachers. Indeed, because most
schools had their own after-school programs in place, some believed the
current faculty could do the tutoring job with the extra resources---or
that the money would be better spent by hiring another teacher (even a
part-time teacher). The following teacher's sentiment was echoed by
many:

> *Every child could benefit from any help given regardless of the
> level. The reality is that \[teachers\] would love to have any
> assistance; we are so passionate about our kids. It just depends on
> how much additional services cost and whether that would be a good way
> to divert funds. I think that after school, the kids are tired. The
> kids are shutting down. I think it would be better to \[use the money
> to\] put an aide in the classroom. Give me one aide all day.*

This attitude among teachers sometimes created less than cordial
relationships between providers and school staff. In one district, the
provider noted that some principals were not very welcoming. For
example, the principal at one school never returned her telephone calls
or acknowledged her numerous requests to get on the agenda for staff
meetings. This made it difficult for her to reach out to teachers and
other school staff to inform them about the program. "We were put in his
school. It was not \[the principal's\] choice and he did not necessarily
want supplemental services in his school," she explained.

***School participation in the implementation of supplemental services
raises student participation. For example, when schools allow providers
to offer services at the school building, parents are more likely to
apply for those providers' services.*** In one district, parents picked
the provider that offered services at the school site over the one that
did not. In another district, all agreed that the convenience of having
tutoring on location in the schools is extremely important to parents
and students and everyone acknowledged that in the absence of
school-based after-school tutoring, attendance would be significantly
lower.

###### District Management of Supplemental Service Providers

District efforts to put in place procedures for managing supplemental
service providers are quite diverse. Establishing contracts with
providers has been particularly challenging for districts and some
providers. Some districts, however, have no providers yet and have not
anticipated a process for managing providers in the future.

***At least one district has put in place a system intended to manage
the provider services available to schools.*** Parents are allowed to
choose any provider offering services in their district. Some districts
arranged for providers to offer services on school campuses. In one
district where all but one of the providers sought to offer services at
the school site, the district attempted to install a system that would
prevent multiple providers from vying for space in the schools. The
Title I office divided the schools into three geographic zones and three
clusters within each zone. Each cluster had four to six schools, each
with a different provider assigned to the school. The brochure sent to
parents indicated which provider was assigned to their child\'s school.
They could select any provider serving a school in their cluster, but if
they picked a provider at a school their child did not attend, the
parents had to provide transportation to that school. This system worked
well enough but had its detractors. One provider complained that he had
a very difficult time getting his questions answered. "It was almost
like you had to feel your way.... It took weeks just to find out who the
contact in the district was.... It was like the blind leading the blind.
Everyone said, 'We can't give you a direct answer.'" He said that every
time he asked a question, the district had to check with the state,
which had to check with the Department of Education before he could get
an answer. Another provider noted having problems getting names of
participating students from the schools. "None of the lists matched.
Some \[schools\] didn't make copies \[of the registration forms they
collected\]. They didn't know. Some didn't send them at all."

***Several districts, however, have had limited activity managing---even
communicating with---providers, a situation some providers find
frustrates their efforts to provide services***. District management and
oversight of supplemental service providers has been particularly easy
in the cases where districts are only working with one provider. Among
districts with multiple providers, only one district's Title I director
said he is in frequent telephone contact with the providers to answer
questions, to pass on complaints from parents, or to give the provider
feedback. In other districts, providers indicated that they had had
little interaction with the district about supplemental services and
that this was frustrating. One provider described her experience with
the district as follows:

> *The district said they would call. November went by. At the beginning
> of December I called them, they said, 'Don't worry, they said, we're
> just setting up the program.' I said I needed more particulars so we
> can get ready, \[information such as\] the cost per child, if we would
> be able to do it within our system as far as providing services. They
> said they would call. In January, I called back, they said: 'Not to
> worry, we'll have a meeting.' Then they called the day before the
> meeting and said, 'Oh, we're having a meeting, it's at 2:00.' I
> couldn't go. They said they were going over some very important
> things. I asked if it would be possible for them to collect the
> information and send it to me or call me. They said they would try to
> but they didn't know what to expect. I have not heard from them
> since.*

Indeed, staff in this particular district did not appear particularly
knowledgeable about the service providers. The district supplemental
services coordinator said the following:

> I did not get descriptors of the services \[the providers\] offered. I
> don't know who was supposed to do that \[e.g., providers themselves,
> the district, or the state\]. We gave the names of all the providers
> \[in the letter\] and then it was the parents' responsibility to make
> contact with the providers. I don't know what emphasis \[the
> providers\] place on various subjects or tutoring services. Other
> providers may be e-learning providers, but I don't know much about
> them. I have no information on that. Individual providers will have to
> explain their services to the parents. It's a problem for parents who
> don't speak English.

***Entering into contracts with service providers is new territory for
most districts and is proving to be extremely time-consuming.***
According to the legislative requirements, districts are to enter into
separate contractual agreements with providers for each student a
provider serves (i.e., to ensure that the specific needs and achievement
goals of individual students are identified and addressed). Several
district administrators said they had no real experience writing
contracts for service providers. Several administrators said they turned
to their states for sample contracts, but that did not necessarily solve
their problems. One Title I director, for example, explained that the
state had sent them the sample contract that the Council of Chief State
School Officers had provided in their supplemental services toolkit, but
it was a contract for professional development services, not
supplemental services.

To the extent districts have contracts with service providers, they vary
tremendously in scope and purpose. Some contracts lay out details
regarding issues from parent involvement to anticipated student
achievement. One district, in an effort to simplify the contracting
process and expedite the provision of services to students, wrote one
contract to cover all the students that the provider served---setting
certain parameters for the kinds of services providers offered, how many
contact hours providers would guarantee in tutoring services to each
child served, and what gains in student performance the provider
guaranteed.

One administrator noted that the costs and time associated with writing
contracts, even when providers have boilerplate contracts available, is
already significant. "Each \[contract\] still has to be read, points
\[have to be\] clarified and reworded, and differences across school
sites have to be accounted for. We write the contract, run it by our
lawyers, and send it to the provider, who runs the contract by its
lawyers. Then, if there are any changes to the contract, we go through
that process all over again. Imagine going through this for every
individual child or for each of the 15 providers we expect to have next
year." Other districts noted the same types of concerns:

> *Getting contracts with providers could be a potentially lengthy and
> drawn out process because \[our\] school system uses the same
> attorneys that serve the entire city government. Our legal and
> contractual system is bound up in the city system and is therefore
> very slow moving.*

***Several districts struggled to define the terms of the provider
contract.*** One district explained that the biggest challenge in
writing the contract, for both the district and the provider, is knowing
in advance the number of students who will be served. When entering into
these contracts, providers often want some guarantee that a certain
number of students will sign up for their services. Although districts
are unable to provide these guarantees to service providers, this has
implications for providers' staffing requirements. In one district, for
example, efforts to contract with the sole provider available to the
district failed because the district could not guarantee a minimum of 95
students, as the provider required.

Two other districts were struggling to interpret the legislative
requirements regarding providers. One district was working under the
assumption that the legislation prohibits providers from charging
districts for sessions students do not attend and that providers may not
drop a student from their program. The district argued, "\[This\] will
make it very difficult to attract quality providers and is somewhat
unreasonable given that providers must pay their staff regardless of
whether a student shows up. The risk of substantial financial loss is
great." Similarly, another district administrator said she was
struggling with how to handle the intertwining issues of student
attendance, student achievement, and appropriate payments to providers
who make themselves available to tutor students but who, at the last
minute, may find themselves with no one in attendance. She defined the
ambiguities in the legislation as follows:

> *What happens if a student misses tutoring? Will the provider still be
> paid? Also, how can a provider be held accountable for the achievement
> level of a child who misses tutoring on a consistent basis? At one
> point should a child who is consistently absent be 'expelled' from the
> program to make room for another child who is eligible but who has
> been denied services because of limited resources?*

She said no specific guidance on these important implementation issues
has been provided yet. She warns that although these are not significant
problems now, they could become significant as the program grows and
more and more providers and students become involved.

Finally, two provider executives interviewed by telephone raised
concerns about the provider applications and contractual agreements that
the legislation requires. Both believed that more efficient application
and contracting processes were needed, particularly for providers that
were working in many districts and states. One executive pointed to the
value of having templates for application forms and contracts.

***Administrators and school staff in two districts raised concerns
about issues of safety and liability in allowing outside service
providers to use school facilities.*** In one district, a principal
talked about her concerns about tutors, who are typically unidentified,
walking into her school at the end of the day when she has no way of
identifying who they are. In addition, until she made an issue of it and
got them to stop, tutors were going home at the end of tutoring sessions
leaving students unsupervised in the building to wait for parents to
come for them. Two provider executives also raised concerns about
students' safety and well-being, explaining that providers are rarely
willing to take responsibility for the students they work with and that
schools do not necessarily have a dedicated person to ensure that
students leave the school safely and that the school building is secure.

***If districts are attempting to measure provider performance at all
this year---and many are not---their performance measures are usually
"makeshift" or preliminary.*** That is, although the legislation assigns
primary responsibility to the state for judging provider performance,
most districts believe that their contractual agreements require that
they monitor providers in order to ensure that providers are in
compliance. In addition, ED's draft non-regulatory guidance stated that
district responsibilities include providing information the SEA needs to
monitor the quality and effectiveness of the services offered by
providers. One district says it plans to call the parents and ask them
whether the services their children received were "worth it." As the
district administrator explained, "We just want them to tell us whether
the services were what \[their children\] needed."

Another district said that it doesn't have a provider evaluation system
in place yet, and is struggling with the notion of what a fair system
should look like. For example, because provider services are limited to
21-28 hours of tutoring over a two or three month period, state test
scores would not be a good measure of provider impacts. Another issue
the district is struggling with is whether it should use a common
measure across all of the providers. As the district administrator
explained, "With tutors focusing on different skills, different
subjects, different students, is this feasible or fair? Who carries
primary responsibility for judging the quality of the tutors?"

The one district that attempted to measure provider performance this
year opted to use a temporary and controversial standard. That is, the
district determined that the amount of time before the school year ended
was not sufficient to generate measurable Normal Curve Equivalent (NCE)
gains on the state assessment. Therefore, it is using report card grades
as its measure for evaluating the tutoring services. Under the terms of
the provider contracts, providers' students must demonstrate a
one-letter-grade improvement in the tutored subject areas on either
their 5th or 6th marking period report card. However, students must
attend at least 80 percent of the tutoring sessions in order to be
included in the evaluation. Providers are very unhappy with this
provision. The director of one provider service decried the subjective
nature of report card grades, "I can show you a teacher where 25 percent
of your grade is based on whether you attend a basketball game." Another
provider said, "What goes on in the regular classroom has the greatest
weight. How do you determine whether it is the after-school program that
is weak or the regular classroom teachers?" Title I staff defended the
use of report card grades as the only measure available to them given
the late start this year. Next year, the district expects to use NCE
gains as its measure of provider performance.

Finally, most districts pledge to have a clear accountability system for
provider performance in place next year and at least one service
provider outlined what she believes are reasonable guidelines. This
provider who was concerned that the very high student mobility rates in
the district will make it difficult to fairly assess the program's
effectiveness made clear that her company will only make performance
guarantees for students who are "full-cycle" (i.e., they have completed
45 or more hours of tutoring).

***Few districts, if any, have systems in place for tracking students
who are receiving services.*** Only one district seemingly recognized
the need to have a student tracking system and is currently working with
its research office to create an addendum to the district's
student-level management information system. The addendum will include
all relevant data about each student's participation in supplemental
services, including regular progress reports.

**District Funding for Supplemental Services**

NCLB establishes a joint funding mechanism for supplemental services and
Title I choice-related transportation of an amount up to or equal to 20
percent of a district's Title I,\
Part A, allocation, before any reservations. This means that the amount
of funding that a district must devote to supplemental educational
services depends in part on how much it spends on choice-related
transportation. However, if the cost of satisfying all requests for
supplemental services exceeds an amount equal to 5 percent of a
district's Title I, Part A, allocation, the district may not spend less
than that amount on those services. NCLB also sets the per-child cost
for supplemental services as the lesser of either the district's
per-child allocation under Part A of Title I or the actual cost of the
services.

***The average district per-pupil expenditure for supplemental services
was about \$865.*** However, the range in district per pupil
expenditures was from \$370 per student in one large central city to
\$1,136 per student in a mid-size central city (Table 4). Eight
districts had determined their per pupil expenditure for supplemental
services; one had not. Indeed, because this rural district had no
providers in the area, it had not considered what it would spend per
student when services became available.

***The amount of tutoring time that supplemental service dollars bought
varied somewhat both within and across the nine districts.*** As Table 5
shows, provider hourly costs range from \$5 to \$40 dollars for one hour
of tutoring services per student. In general, the more expensive the
provider, the fewer hours of tutoring services the district funding
buys. In addition, most providers offer small group tutoring sessions as
opposed to one-to-one or individualized instruction.

The processes districts have put in place to pay providers are something
of a mixed bag. One district said it pays each provider based on the
number of slots being filled, even if individual slots are filled by
more than one student. For instance, if a student attends for three
weeks, drops out, and is replaced two weeks later by someone on the
waiting list who finishes out the year, that counts as one slot being
filled, even though several sessions were missed. Thus, payment is not
based on attendance at individual sessions. Another district pays
providers in three installments: one-third when services begin,
one-third in the middle of the semester, and one-third at the conclusion
of the school year.

***Because so few parents applied for supplemental services in 2002-03,
no district in this study exhausted its budget.*** Indeed, the
proportion of eligible students served ranged from less than 1 percent
to 42 percent (Table 4). Districts appear to have untapped funding
capacity to purchase supplemental services for many more students.
Indeed, several districts expressed frustration about having so much
money "tied up" for supplemental services while so few students
requested such services.

Several district administrators expect next year's funding experiences
to be vastly different. Many expect that levels of participation in the
school choice option will increase substantially next year when more
schools are identified for improvement. This means that less funding
will be available for supplemental services. In addition, many
administrators expect that word-of-mouth communication will have taken
hold and that many more parents will apply for supplemental services for
their children.

***Several districts expressed concern about the administrative costs
associated with implementing the supplemental services provisions.***
Several referred to the costs associated with mailing letters to
parents. One district estimated that the cost of mailing letters to the
families of students in just three identified schools was \$50,000
because the district had to find the parents' addresses, translate the
letter into multiple languages, and send and resend the letters to
parents who did not receive them on the first or second mailing. A Title
I administrator in another district explained that the process of
preparing and sending out a mailing to almost 40,000 parents places a
significant burden on his staff.

At least two districts noted that they needed to hire more staff in
order to attend to the implementation of the program. One district
administrator believes that administration of this program requires a
full-time coordinator:

> *Given the volume of work, this program needs a full-time coordinator
> to: expedite communication among all the supplemental service
> providers; help ensure that letters are written and distributed in a
> more timely manner; and be the point person to whom vendors, parents,
> and school staff could turn for resolution of most supplemental
> services related issues.*

Several districts said they are forced to provide the additional staff
out of their district's administrative overhead budgets or to assign
existing staff the additional duties. Most district administrators
emphasized that the amount of staff time required to attend to program
implementation issues was vastly underestimated. For example, it took a
great deal of time and effort to make the necessary schedule
adjustments, address transportation and safety issues, and compile,
prioritize, and share academic assessment data for the purpose of
identifying and ranking students for supplemental services.

Table 5

Characteristics of Selected Supplemental Service Providers[^14]

+-------------+---------+-------+-------+--------+--------+-----------+
| # Provider  | # Ty    | # Cos | #     | # N    | **Tu   | **Service |
|             | pe of P | t of  | Numbe | umber  | toring | C         |
|             | rovider | Servi | r of  | of Stu | Fo     | apacity** |
|             |         | ces p | Conta | dents  | rmat** |           |
|             |         | er Co | ct Ho | Served |        |           |
|             |         | ntact | urs P |        |        |           |
|             |         |  Hour | er St |        |        |           |
|             |         |       | udent |        |        |           |
+=============+=========+=======+=======+========+========+===========+
| **Brooktown |         |       |       |        |        |           |
| School      |         |       |       |        |        |           |
| District**  |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Sylvan      | Private | \$21  | 45    | 138    | Small  | Not yet   |
| Education   | for     |       |       |        | group  | d         |
| Sol         | -profit |       |       |        |        | etermined |
| utions[^15] |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| **Cleartown |         |       |       |        |        |           |
| School      |         |       |       |        |        |           |
| District**  |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| **(NOTE)**  |         |       |       |        |        |           |
| District    |         |       |       |        |        |           |
| seeking     |         |       |       |        |        |           |
| federal     |         |       |       |        |        |           |
| waiver in   |         |       |       |        |        |           |
| order to    |         |       |       |        |        |           |
| become an   |         |       |       |        |        |           |
| approved    |         |       |       |        |        |           |
| s           |         |       |       |        |        |           |
| upplemental |         |       |       |        |        |           |
| service     |         |       |       |        |        |           |
| provider    |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| ## Las C    |         |       |       |        |        |           |
| ierras Scho |         |       |       |        |        |           |
| ol District |         |       |       |        |        |           |
|  {#las-cier |         |       |       |        |        |           |
| ras-school- |         |       |       |        |        |           |
| district-1} |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Kaplan K-12 | Online  | \$20  | 30    | 0      | In     | Depends   |
| Learning    |         |       |       |        | dividu | on school |
| Services    |         |       |       |        | alized | capacity  |
+-------------+---------+-------+-------+--------+--------+-----------+
| *           |         |       |       |        |        |           |
| *Plainfield |         |       |       |        |        |           |
| School      |         |       |       |        |        |           |
| District**  |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| EdSolutions | Private | \$5   | 228   | 111    | Small  | Not yet   |
|             | for     |       |       |        | group  | d         |
|             | -profit |       |       |        |        | etermined |
+-------------+---------+-------+-------+--------+--------+-----------+
| Project X   | Private | \$13  | 52-76 | 125    | Small  | Not yet   |
|             | for     | -\$19 |       |        | group  | d         |
|             | -profit |       |       |        | and    | etermined |
|             |         |       |       |        | in     |           |
|             |         |       |       |        | dividu |           |
|             |         |       |       |        | alized |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Club THINK  | Fait    | \$5   | 228   | 50     | Small  | 77        |
|             | h-based |       |       |        | group  |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| **Redding   |         |       |       |        |        |           |
| School      |         |       |       |        |        |           |
| District**  |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Bose        | Private | \$35  | 28    | 230    | Small  | Depends   |
| Learning    | for     |       |       |        | group  | on        |
| Center      | -profit |       |       |        |        | provider  |
|             |         |       |       |        |        | capacity  |
+-------------+---------+-------+-------+--------+--------+-----------+
| Sylvan      | Private | \$35  | 28    | 50     | Small  | Depends   |
| Learning    | for     |       |       |        | group  | on        |
| Center      | -profit |       |       |        | and    | provider  |
|             |         |       |       |        | in     | capacity  |
|             |         |       |       |        | dividu |           |
|             |         |       |       |        | alized |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Winners     | Private | \$35  | 28    | 46     | Small  | Depends   |
| Learning    | for     |       |       |        | group  | on        |
| Program     | -profit |       |       |        |        | provider  |
|             |         |       |       |        |        | capacity  |
+-------------+---------+-------+-------+--------+--------+-----------+
| **Riverside |         |       |       |        |        |           |
| School      |         |       |       |        |        |           |
| District**  |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Boys and    | No      | \$25  | 44    | 0      | Small  | Depends   |
| Girls Clubs | nprofit | -\$40 |       |        | group  | on        |
|             |         |       |       |        |        | provider  |
|             |         |       |       |        |        | capacity  |
+-------------+---------+-------+-------+--------+--------+-----------+
| Sylvan      | Private | \$40  | 36    | 0      | Small  | Not yet   |
| Learning    | for     |       |       |        | group  | d         |
| Center      | -profit |       |       |        | and    | etermined |
|             |         |       |       |        | in     |           |
|             |         |       |       |        | dividu |           |
|             |         |       |       |        | alized |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Key         | Private | Un    | Un    | 0      |        | Not yet   |
| Learning    | for     | known | known |        |        | d         |
| Systems     | -profit |       |       |        |        | etermined |
+-------------+---------+-------+-------+--------+--------+-----------+
| ## Smi      |         |       |       |        |        |           |
| thville Sch |         |       |       |        |        |           |
| ool Distric |         |       |       |        |        |           |
| t {#smithvi |         |       |       |        |        |           |
| lle-school- |         |       |       |        |        |           |
| district-3} |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Brown's     | Inde    | \$30  | As    | 2      | One-   | Up to 10  |
| Services    | pendent |       | many  |        | to-one | students  |
|             | Con     |       | as    |        |        | a day     |
|             | sultant |       | nece  |        |        |           |
|             |         |       | ssary |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Kaplan K-12 | Online  | \$20  | 30    | 0      | In     | Depends   |
| Learning    |         |       |       |        | dividu | on school |
| Services    |         |       |       |        | alized | capacity  |
+-------------+---------+-------+-------+--------+--------+-----------+
| ## S        |         |       |       |        |        |           |
| unnydale Sc |         |       |       |        |        |           |
| hool Distri |         |       |       |        |        |           |
| ct {#sunnyd |         |       |       |        |        |           |
| ale-school- |         |       |       |        |        |           |
| district-1} |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Project     | Su      | \$22  | 39    | 537    | Small  | Not yet   |
| Learn       | nnydale |       |       |        | group  | d         |
|             | School  |       |       |        |        | etermined |
|             | D       |       |       |        |        |           |
|             | istrict |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| EdSolutions | Private | \$7   | 130   | 431    | Small  | Not yet   |
|             | for     |       |       |        | group  | d         |
|             | -profit |       |       |        |        | etermined |
+-------------+---------+-------+-------+--------+--------+-----------+
| Mr. J's     | Inde    | \$25  | 39    | 36     | Small  | Not yet   |
| Tutorial    | pendent |       |       |        | group  | d         |
| Services    | Con     |       |       |        |        | etermined |
|             | sultant |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| *           |         |       |       |        |        |           |
| *Trainville |         |       |       |        |        |           |
| School      |         |       |       |        |        |           |
| District**  |         |       |       |        |        |           |
+-------------+---------+-------+-------+--------+--------+-----------+
| Sylvan      | Private | \$24  | 39    | 510    | Small  | Depends   |
| Education   | for     |       |       |        | group  | on school |
| Solutions   | -profit |       |       |        |        | capacity  |
+-------------+---------+-------+-------+--------+--------+-----------+

##    {#section-2 .unnumbered}

## Supplemental Service Providers

Supplemental services vary considerably in content and pedagogy across
the nine districts included in the study sample. Supplemental services
also vary in student-to-tutor ratios and duration and frequency of
services. Although some providers offer individualized instruction, most
providers included in the study sample offer group instruction, in which
student-to-tutor ratios range from 3:1 to 8:1. The duration and
frequency of services tends to range from one to one-and-a-half hours
twice a week for approximately one semester. Among the providers
included in the study sample, most offer services that focus on reading
instruction; however, the instructional approach in reading ranges from
detailed diagnosis and scripted lessons to more general help with
homework. Many providers have experience working with school-aged
children, but few provide the same array of services for the
supplemental services program as they do for their regular program.
Moreover, few providers have served primarily low-income students.
Providers must often adapt their services to the dollars per child
available through district supplemental service funding allocations.
Many providers offer tutoring services at the school sites. To be
economically feasible online providers must target their services to
students who will seek out facilities with Internet access.

Providers in the study sample were focused on developing contracts with
districts, hiring staff, communicating with district administrators,
teachers, and parents, and delivering instructional services to
students. Nevertheless, providers face a number of challenges as they
attempt to respond to the demand for their services, none of which is
likely to diminish as they gain experience managing their programs in
collaboration with districts and schools.

###### Getting Started

***Providers in the study sample often lack sufficient notice from the
district regarding the number of students they will be expected to
serve.*** Also, providers said they need enough students requesting
services to make it a viable business proposition. That is, for many
providers, the cost of setting up their operations in a district cannot
be justified if only a handful of students request their services.
Indeed, several providers found themselves unable to offer services
because not enough parents had enrolled. Providers in several districts
also found it difficult to get final lists of students from schools or
districts. The lack of advance notice about the number of students
providers would be expected to serve often caused providers, once they
had a signed contract from the district, to scramble to schedule
services and hire appropriate numbers of staff. As one provider
described:

> *Our capacity in this program \[at this school site\] is 30. It's too
> late this year to enroll more kids here. All the slots are filled. It
> would be easier in September \[to bring in new kids\]. Our capacity to
> serve more kids is not good for this year \[because we don't have
> enough staff\], but better for next year. Nevertheless, we would need
> more staff, and it would cost more initially, to buy more materials.*

For providers that do preliminary testing of students, the delays in
finalizing student lists is particularly problematic, as two providers
explained:

> *Every time we came in \[to the school\], we got a different list of
> students. We probably assessed 60 kids that \[we\] did not need to.*
>
> *The lists of participating students changed daily and hourly. In
> addition, the time we were given to make things happen was just not
> enough.*

Some providers in the study sample, however, are simply not equipped to
handle the demand for services. In several districts, providers
experienced more demand for their services than they could staff,
resulting in far fewer students receiving services than districts had
anticipated. Some providers found themselves having to restructure their
program due to insufficient staffing capacity; others had to turn
students away.

**Provider Curriculum and Instruction**

***The content and structure of provider tutoring services varies both
within and across districts.*** According to ED's draft non-regulatory
guidance, supplemental services may consist of academic assistance such
as "tutoring, remediation and other educational interventions, provided
that such approaches are consistent with the content and instruction
used by the local education agency and are aligned with the state's
academic content standards" (ED, 2002; p. 1). Among the providers
included in the study sample, most offer services that focus on reading
instruction; however, the instructional approach in reading ranges from
detailed diagnosis and scripted lessons to more general help with
homework. Some provider services consist primarily of academic
instruction while others offer a variety of activities. For example, one
provider begins each tutoring session with homework assistance, then
spends the next 30 minutes on guided reading of social studies, science,
or other content-based material. Other providers offer students snacks
and allow them to choose between reading- or math-related activities.
Several providers offer incentives, usually called tokens, to students
for attending tutoring sessions regularly, remaining engaged in their
tasks, and completing their work. At various intervals over the course
of several weeks, students can redeem their tokens at provider "stores"
where students can buy small toys, candy, pens and pencils, and other
small items. Other providers offer "creative projects" or various
enrichment or artistic activities. Finally, one provider uses Leap Pad
technology, as the following describes:

-   Leap Pad is a lap-top-sized electronic device into which students
    place colorful and creative worksheets that they complete using a
    special stylus. Their answers are recorded onto a cassette that
    slides out of the pad and can be plugged into the teacher's
    computer, which records all responses and tracks progress. This
    enables the teacher to analyze and print reports on each student for
    parents and teachers. Students spend the first few weeks completing
    skill assessments and learning to use the pads. They are then
    assigned a "Learning Path" based on their results. The Learning Path
    is essentially a sequence of worksheets that address specific
    academic weaknesses. The program is self-paced and requires minimal
    instruction by the teacher.

***The extent to which providers coordinate their curriculum with state
or district standards is unclear.*** According to the law, provider
services must be aligned with state academic content standards. When
asked, providers claimed that their curriculum was aligned with state
and district standards; however, it appeared that providers typically
make only minor modifications to their well-established program of
services and offered little concrete evidence of the specific ways in
which their curriculum was aligned with standards. Some providers
explained that their curriculum was somewhat correlated with the regular
classroom curriculum or pointed out that their curriculum was intended
to prepare students for the state assessment. A few providers mentioned
referencing state or district standards in their work. One provider said
she uses the standards to help her know what skills students need in
each subject to bring them up to grade level. Finally, several providers
explained that their services consisted of homework help.

One teacher's assessment of provider services, however, questions the
notion that provider services must be aligned with state or district
standards. This teacher explained that, although the provider was using
a curriculum that had little relation to what teachers were doing with
students in the regular classroom, the services were helping students:

> *\[The provider's\] strategies remind me of the way I learned how to
> read. I think \[the provider's\] strategies are better \[than ours\]
> because they focus on getting \[the words\] off of the page
> first---they don't leave out meaning, but it focuses on phonetics,
> which is logical to me. There is a phonetic component to our reading
> curriculum \[Balanced Literacy\], but it's not as strong and central
> as it is in the \[provider's curriculum\]. Lots of kids have no one at
> home who can read to them in English.*

Finally, several providers administer their own assessments to students
prior to providing services. Providers use the assessment data to gauge
individual student learning needs and to place students in the
appropriate learning group or provide students with the appropriate
learning materials.

***Providers often must adapt their services to the dollars per child
available through district supplemental service funding allocations.
Typically, this requires increasing the student-to-tutor ratio and
decreasing the number of sessions they would ordinarily provide.***
Several providers described adjusting the structure of their programs,
usually by increasing the student-to-tutor ratio, to make the costs of
program operations come within range of what the district was able to
pay. One provider indicated that he incurred significant "ramp-up costs"
(i.e., about \$40,000) associated with hiring additional staff and more
office space to operate his program in the district. As he explained,
"With the per student payment capped and no reimbursement for overhead,
only tutoring costs, it would be difficult to maintain the one-on-one
tutoring for everyone."

###### 

###### Provider Staff

Providers included in the study sample varied significantly with respect
to their staffing practices. Some providers use only certified teachers,
many of whom are or have been public school teachers. Other providers
use graduate students from local colleges and universities. Still other
providers have far less stringent staff requirements.

***Several providers hire their tutors directly from the schools their
students attend.*** Several principals raised concerns about providers
that hire teachers directly from the schools identified for improvement.
One Title I facilitator commented, "I have a philosophical problem with
a company that comes in and says we are going to fix you, but you have
to give us the people to do it." Some principals also worried about the
drain on teachers' energy. They argued that if teachers work all day in
their classrooms and then stay an additional two or three hours after
school for tutoring, they will begin to burn out much faster, making
them less effective as classroom teachers. In addition, this practice of
hiring teachers directly from the schools sometimes backfires for
providers. In one school, the principal was very surprised to learn that
a provider hired three of her teachers without asking for her opinion.
The principal explained that two of the teachers the provider hired were
among the weakest on her teaching staff.

By contrast, however, some principals preferred having their own
teachers in the building after hours providing tutoring instead of
strangers. One principal said, "If they were not my teachers, I would
not let them use the classrooms" and, "You need someone who knows these
kids.... If we didn't have internal people, this would not have worked."

**Monitoring Student Progress**

Among the providers in the study sample that have begun offering
services, most have not yet fully defined their procedures for
monitoring and reporting student progress. Several providers plan to
schedule regular meetings at varying intervals with parents and teachers
as a part of their feedback process. One provider plans to meet with and
update parents and teachers every six weeks regarding student progress
whereas another provider intends to give student progress reports to
school leaders weekly and to parents two times in total. Still another
provider says it will administer tests and report the results to parents
on a quarterly basis.

**Communicating with Parents and Teachers**

Provider efforts to communicate with teachers and parents are extremely
varied and typically erratic. The nature of the communication tends to
be left to the judgment of individual tutors. For example, one tutor
said that she carefully cultivates a good relationship with her
students' teachers. "The relationship with the teacher depends on how
you approach the teacher. I call them and talk to them. If we had a
whole classroom, we couldn't \[call all of the teachers\]." A teacher in
another school in another district described working with a tutor on her
student's behalf. She noted that her student was overwhelmed by having
two lists of sight words to learn (one from the provider and one from
the school). The classroom teacher asked the Sylvan tutor for her sight
word list and began using that list in her classroom. In addition,
communication between teachers and tutors in this district has led the
provider to add a new writing component to their curriculum in order to
align better with the district's literature-based curriculum.

Providers reported making an effort to communicate with parents,
sometimes hosting family nights to discuss student progress. However,
providers explained, parents do not usually attend these types of
events. Providers say that parents' work schedules and family
responsibilities often limit communication opportunities between
providers and parents. Providers admit that they are usually most in
touch with those parents who actively seek them out by stopping by
before or after tutoring sessions. Providers say they have little or no
contact with parents who, for various reasons, do not come personally to
pick up their children or who do not actively seek the providers out.
Providers also mentioned that language is often a barrier to effectively
communicating with parents.

**Other Issues of Concern**

***Some students may need extra incentives to participate in the
supplemental services program.*** At least two districts were meeting
some resistance among middle school students who felt self-conscious
about needing help and who were embarrassed to admit to their peers that
they are in a tutoring program. One middle school principal described
the problem:

> *I think there's an image problem \[with supplemental services\]...for
> kids who are slow. I've got kids who sneak into Sylvan because they
> don't want to be seen as dumb. We try to portray it as just another
> club we have; that it's no different from being in drama club...that
> they just chose that one. We offer the snacks \[in Sylvan\] that we do
> in other clubs...but kids talk. They're good at it. They're much more
> perceptive than we give them credit for.*

While absenteeism is somewhat of a problem in the elementary schools'
tutoring programs, it is a significant issue in middle school. In
addition, because middle school students have multiple teachers, it is
often difficult for tutors to identify individuals within the school who
are best able to help them address absenteeism and other behavioral
issues. One skeptical middle school teacher had the following to say:

> *Long-term, \[supplemental services\] is not going to help the kids
> who really need the help because those are the kids who won't go \[to
> receive tutoring services\] and parents won't make them go. The kids
> who need help are the ones who won't go. There's only so much school
> we can give kids.*

Finally, competition from sports and other after-school activities is
more pronounced in middle schools than in elementary schools, further
reducing middle school participation levels in supplemental services.
The following is one teacher's description of the myriad after-school
activities available to students in his middle school:

> *There are a million after-school programs here. There are also other
> tutoring programs after school---the college down the street offers
> tutoring services two days a week where college students come and
> tutor kids. There's also a homework club where kids can get tutoring.
> In addition, after school are all the sports activities. Our school
> also has two dozen after-school clubs such as the year book club, the
> drama club, cheer leaders, etc.*

***Students may "burn out" on tutoring if they never get a significant
break from their academic studies.*** In several districts, school staff
pointed out that students work from 8 a.m. until 5 p.m. without much of
a break in their academic schedule. As one teacher explained, "Kids are
in class or at lunch from the moment they get to school to the end of
the day (approximately 6 or 7 hours)." Some teachers expressed the
concern that to plunge these students into more academic tutoring after
school could be detrimental. "We are only into the third week with this
program and I have some kids who do not want to go anymore. It's too
long a day for most kids," stated one teacher. Another teacher
explained, "Kids need after-school, extra-curricular activities. They
need to develop their whole person."

***Online providers can reach only a subset of students and therefore do
not solve access problems in rural areas.*** To be economically
feasible, online providers must target their services to students who
will seek out facilities with Internet access. The result is a focus on
older and highly motivated students and typically excludes students
younger than ten-years-old, students who are limited English-proficient,
and those who are disabled. Indeed, several school staff stated that
online services were not appropriate for students most in need of
assistance. They noted that only higher-functioning students would have
the discipline to participate in a distance-learning program.
Furthermore, the youths to whom the program is targeted typically need
more hands-on, one-on-one assistance to progress. Therefore the
assumption that online providers can solve the access problems in rural
areas is problematic, as one district administrator explained:

> *If you are a parent of a third-grader and say, I want additional
> services and don't like your school, the online provider cannot serve
> their child. If I'm a parent of a middle-schooler, I have some
> options. Some parents are excited about the option. \[Only\] high
> school and middle school students have options \[to use online
> providers\].*

In addition, using an online provider option does not necessarily result
in limited involvement on the part of districts or schools. At one site,
the Title I director reported that the online provider was planning to
have 20 students work in the school's computer lab without supervision.
"They called and said, 'You can provide a supervisor, right?'" The
district had to find funds to provide supervision during that time.

**Parents' Role in Supplemental Educational Services**[^16]

Most parents of children eligible to receive supplemental educational
services are pleased to have the opportunity to enroll their child in a
tutoring program; these same parents also report satisfaction with their
children's schools and teachers. Transporting children to and from
supplemental services is one of parents' chief concerns with the
program; parents prefer programs that provide transportation for
children or those that are offered at students' schools. Many parents
did not receive information from their districts that helped them
understand the services available to them. For many parents, their
children's teachers are their most trusted source for deciding whether
to enroll their children in a tutoring program.

###### Parents' Assessment of Children's Educational Needs 

***Overall, the parents interviewed said they liked and trusted their
children's schools and teachers, even though the schools are all
identified for improvement.*** In addition, parents seemed to value the
special programs and services schools offered before and after the
school day to help low performing students. Because parents were
generally satisfied with their children's schools and because they
wanted to keep their children close to home, most parents chose the
supplemental services option rather than school choice.

Parents generally praised their schools and were happy with most of the
teachers; parents were also well aware of the school's low performance.
Parents often based their judgment of the school on the accessibility
and personality of the teachers (e.g., if he or she is caring and nice
or not) and the school environment. In one of the few schools in the
study where parents were dissatisfied with the school, it was because it
did not have a very "family-friendly" atmosphere.

Parents appreciated schools' existing school-day and after-school
programs designed to help low achieving students improve their skills.
In one district, elementary school parents were especially pleased that
the school was implementing Accelerated Reading and other corrective
reading programs, explaining that their children were reading more since
the school began the programs. In another district, parents had high
praise for an after-school program in which regular classroom teachers
work with low achieving students to improve their skills for the state
assessment.

***Most parents in the districts in this study chose to apply for
supplemental services rather than transfer their child to another
school, even when districts made efforts to educate parents about the
choice option and explained that transportation would be provided.***
Most parents are familiar with their school and neighborhood and
disliked the notion of sending their children "across town" to another
school. One of the parents interviewed, although aware of her choice
options, said she would not send her child to another school because, "I
like the teachers here. It would be really iffy \[at another school\]. A
teacher would have to be really disappointing. And the principal is very
good about shifting your child to another class." In addition, some
parents said they were uncomfortable or uninterested in sending their
children to an unfamiliar neighborhood. As one parent explained, "We
live really close. I live a block away. Why would we want to send our
kids halfway across town?"

**Parents' Criteria for Selecting Providers**

Some parents were better informed than others about supplemental
services and about their provider options; this largely hinged on school
and district efforts to provide them with information. In some cases,
English-speaking parents had more access to information than did
limited-English speaking parents. A number of parents did not
distinguish between supplemental services and programs already offered
by their schools. Parents often look to their children's teachers to
help them decide what services best fit their child's needs, but in the
end, transportation and easy accessibility were the primary factors
affecting parents' choice of a provider.

***Parents included in the study reported receiving varying amounts of
information about their provider options.*** Some parents received only
a letter from the district informing them of the supplemental services
provisions of NCLB. Other parents were invited to and participated in
district- or school-sponsored meetings intended to help them understand
their options related to supplemental services. Some parents said they
had heard about providers and services in the media. In other cases,
parents received very little information on the topic. For example, one
parent who was already looking for a tutor for her child said that she
"just happened to see the flyer \[from the district\] and read between
the lines." In another district, no parents interviewed were aware of
their option for supplemental educational services. In one district,
administrators reported that parents who had received letters,
participated in meetings, and heard about the program in the media were
more likely to have applied for services for their children.

Due to language barriers, some parents did not fully understand their
option to select supplemental services for their children. While
districts with large limited English proficient populations usually sent
letters home in English as well as the major languages their students
spoke, many limited English proficient parents indicated that they
received their letter only in English and did not understand it. Some
parents are not literate in either English or their native language.
Some parents also said that there was no one at their school with whom
they could communicate. In one district, the Spanish-speaking parents
interviewed (through an interpreter) only knew about the services
because school staff encouraged them to register their children.

Language differences can also present problems in providers'
communication with parents. One provider said, "Even with the phone
calls we make, we can only speak with parents who speak English because
our Spanish is not good enough to communicate by phone." Administrators
in several districts expressed concern that as supplemental services
expand into more and more schools where lesser-spoken languages are
prevalent and districts and schools lack translators, communicating with
parents could become particularly problematic.

***Many parents do not see a difference between supplemental services
and other after-school programs offered by their child's school.*** Some
parents expressed confusion about the difference between what schools
were already offering and supplemental services. In parents' eyes, these
schools already had tutoring available. For example, in one district,
children who are identified as low performers for the state assessment
receive after-school tutoring from regular day teachers for 35 minutes
per day, two days per week, at the school; many parents interviewed
talked about their satisfaction with this program. In another district
that already had numerous other local, state, and federally funded
after-school programs, these programs have continued to operate even as
the supplemental services program was introduced. As a result, in the
eyes of many parents, NCLB's supplemental services program is just
another "supplemental service" (in the generic sense) that is available
to students. In another district, parents interviewed for this study did
not understand what "supplemental services" were. Once it was explained
to them, several parents noted that their schools already offer
after-school and before-school programs, some of which are referred to
as "tutoring" programs, which may account for some of the confusion
about what supplemental services are.

***Parents often rely on their children's teachers and schools to help
them make decisions about supplemental educational services.*** Many
parents indicated that they were strongly influenced by their children's
teachers regarding the need for supplemental services. For example, one
parent said her son had not been reading very well and the teacher told
her he needed to go to a particular service provider: "I got a letter
and was told to sign it," she said, and so she did. Another parent said,
"My daughter is fine in all subjects. I don't know why they selected her
for tutoring.... But if the teacher says I should send her to tutoring,
I will send her." In many cases, parents also relied on the school to
help them decipher the sometimes confusing provider information and make
their final choices.

Parents' knowledge of provider services varied. Some parents knew about
the different provider services offered. In some cases, parents worked
with their school and teachers to select the best provider for their
children. In other cases, parents were simply provided with the names of
the providers available. A number of parents who chose one particular
provider did so based solely on that provider's television
advertisements. "We're going by what we think and what we hope," one
parent said of her choice of provider. Some parents were bewildered by
the range of choices offered them.

***For most parents, transportation is the deciding factor in choosing
among providers***. Parents looked for providers who offered services at
the school because they did not have transportation to take their
children off-site. Parents often chose providers based more on logistics
and convenience than on educational concerns. For example, in one
district, many parents opted for a provider that offers to transport
children to its center and then back home to their door. There are also
logistical difficulties for parents who lack transportation and who need
to make arrangements for daily childcare for their children (i.e.,
tutoring on some but not all days makes childcare difficult to organize
for parents who need a consistent and reliable five-day-per-week
arrangement). Finally, the absence of transportation makes it difficult
for children to make their way home after tutoring if their parents are
unable to pick them up. Walking after dark, even short distances, to
one's home is out of the question in the dangerous neighborhoods that
typically surround inner-city schools, according to several school
principals and district administrators.

**Parent Satisfaction with Provider Services**

Parents whose children were already receiving services expressed general
satisfaction with providers. However, some parents reported that the
amount of time that elapsed between the services being offered to them
and services being provided was too long. These parents were concerned
that their children would not receive the maximum benefit from the
program.

***Parents are satisfied with the services their children have received
so far.*** In districts where children were receiving services, the
parents expressed satisfaction with the services. One parent said that
she was pleased with the provider and the progress her child was making.
She receives regular written and verbal progress reports from the
provider and is pleased that the provider reviews her child's grades and
test scores. Another parent said the following:

> *I love it, I do! My older daughter is in third grade. This program
> helped her on a broad spectrum of what can be accomplished. With my
> first-grader, he didn't know how to read. This program helps him stay
> focused---both my kids love to come. It's so cool. I knew my
> first-grader needed help---I would try to help him, but I would get
> frustrated with him. I was more of a hindrance than a help. The
> teachers keep him motivated.*

***Parents want services delivered sooner.*** Parents in one district
where students have not yet begun receiving services expressed
dissatisfaction with the amount of time it has taken for the district to
actually begin providing services; they expected services to begin soon
after they sent their initial responses back to the district letter in
October. One parent said, "Where is this help? My son is struggling."
Another parent said, "They should have started earlier in the school
year instead of this late. It will still help them but not as much as if
it had started at beginning of the school year."

In a school in another district, several weeks passed between the time
parents were notified that they were eligible and the time tutoring
began. This gap resulted in a substantial drop in the number of
participants (from 50-60 down to 15-20) actually receiving tutoring.
This suggests that the opportunity simply may not stay on parents' radar
screen for long.

###### Early Evidence of Effectiveness

It is too early to report the actual effects of supplemental services on
those students who have begun working with service providers. For
example, in one district where tutoring started in January and testing
was scheduled for April, staff did not expect that measurable
improvements would become evident in such a short period of time.
However, in one district, parents said that their children were reading
better and or getting better grades since starting tutoring:

> *I have noticed improvement and his teacher says he reads a lot
> better.*
>
> *He's been in tutoring since the end of October. His reading has
> improved a lot---now he's reading chapter books. He likes
> shopping---using the tokens he earns through Sylvan.*

In another district, several teachers commented on the increased
confidence exhibited by students who are receiving provider services.
Referring to one such student, a teacher noted: "He's a laid-back guy,
but he shows more tenacity now; he's not afraid to read something new or
pick up more challenging reading."

**Lessons for the Future**

Implementing the supplemental services provisions of NCLB has thrust
states, districts, schools, and providers into uncharted territory, and
most of the administrators interviewed would say it has been a learning
experience. State administrators, for example, have learned that the
provider application process must start sooner, require more information
about the range of services providers offer, and require more assurances
of provider competency and commitment. In addition, states have learned
that the application process must result in a wider range of applicants
with respect to the services they provide, the grade-levels they serve,
and the areas in which they work.

Districts have learned that they must more clearly articulate to parents
what the supplemental services provisions of the legislation offer them
and their children. They have also learned that they must make provider
services available to students sooner after notifying parents. In
addition, districts have learned that the process of contracting with
providers is complicated and time-consuming, yet they have few ideas
about ways to lessen the burden. Schools have learned that they know
little about their role in the implementation of supplemental
services---they are usually willing to do what they can to help but
require more direction from the district regarding how. Subsequently,
most providers in the study sample had begun providing supplemental
services. Several providers described adjusting the structure of their
programs in order to make the cost of program operations come within
range of what the district was able to pay. What no one has learned much
about is how to monitor and evaluate provider performance.

Finally, most administrators have learned that although start-up
activity this year was difficult and error-prone, most of the challenges
faced with respect to identifying providers, identifying schools,
identifying eligible students, and notifying parents will not go away
next year. That is, unlike other programs, these case study districts
believe that implementing supplemental services will present many of the
same challenges with each passing year. Every year, there will be new
providers, new schools, different numbers of students, and different
needs to serve.

The following are some of the questions or concerns raised by states,
districts, schools, and providers with respect to implementing the
supplemental services provisions of NCLB. These questions suggest areas
in which support is needed:

-   **Evaluation**: What criteria should states use to evaluate provider
    performance? What are some useful benchmarks for assessing provider
    quality and impact? Is it appropriate for school districts to judge
    provider performance? What data does the state use to evaluate
    provider performance? Are districts required to collect evaluation
    data on provider performance and transmit it to the state or are
    states expected to collect their own evaluation data?

-   **Contractual obligations:** Must a district enter into a contract
    with a provider it deems to be underperforming simply because the
    state has not removed a provider from the state list of approved
    providers? Must districts enter into separate contracts with
    providers for each student served?

-   **Funding**: What is the process districts should use to determine
    how much funding they will need to set aside for the choice-related
    transportation and supplemental services provisions? Some districts
    set aside the full 20 percent of their Title I allocation, whereas
    others only set aside 5 percent of their allocation for
    choice-related transportation and 5 percent for supplemental
    services. The legislation states that districts should set aside the
    full 20 percent unless "a lesser amount is needed to comply with
    \[choice-related transportation\] and to satisfy all requests for
    supplemental educational services under subsection (e)." However,
    some districts set aside various percentages of their Title I
    allocation prior to determining the level of interest or "satisfying
    all requests for supplemental educational services."

-   **Role of schools:** What is the school's responsibility with
    respect to recruiting parents; coordinating transportation to
    provider facilities; offering space to providers; monitoring student
    attendance, activity, and performance; and communicating with
    parents and providers about student performance?

The Year Two report will examine these questions as well as explore the
extent to which the supplemental services provisions of NCLB have gotten
easier to implement and the extent to which states, districts, schools,
and providers have been able to build on their experiences of the past
year in implementing supplemental services in year two.

Appendix A

Characteristics of Sampled Schools

Table 1A

Characteristics of Sampled Schools for the

Study of Early Implementation of the

Supplemental Educational Services Provision of NCLB

+----------------------+------+--------+--------+-------+------------+
| # School             | # Nu | # Per  | # Perc | # P   | **Number   |
|                      | mber | cent P | ent Mi | ercen | of         |
|                      |  of  | overty | nority | t LEP | Eligible   |
|                      | Stud |        |        |       | Students   |
|                      | ents |        |        |       | Receiving  |
|                      |      |        |        |       | Services** |
+----------------------+------+--------+--------+-------+------------+
| **Brooktown School   |      |        |        |       |            |
| District**           |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Los Pajaros          | 628  | 89%    | 99%    | 42%   | 48         |
| Elementary School    |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Soheap Elementary    | 335  | 95%    | 97%    | 34%   | 40         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| West St. Middle      | 705  | 80%    | 87%    | 20%   | 50         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| **Cleartown School   |      |        |        |       |            |
| District**           |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Riley Elementary     | 641  | 79%    | 76%    | 15%   | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Thomas Elementary    | 708  | 75%    | 71%    | 23%   | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Cather Middle School | 729  | 64%    | 68%    | 17%   | 0          |
+----------------------+------+--------+--------+-------+------------+
| ##                   |      |        |        |       |            |
| Las Cierras School D |      |        |        |       |            |
| istrict {#las-cierra |      |        |        |       |            |
| s-school-district-2} |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Springfield          | 568  | 84%    | 99%    | 61%   | 0          |
| Elementary School    |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Elm Elementary       | 491  | 84%    | 99%    | 79%   | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Martinez High School | 700  | 76%    | 99%    | 82%   | 0          |
+----------------------+------+--------+--------+-------+------------+
| **Plainfield School  |      |        |        |       |            |
| District**           |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Johnson Elementary   | 432  | 100%   | 81%    | 0     | 73         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Pine St. Elementary  | 513  | 100%   | 70%    | 18%   | 157        |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Potter Elementary    | 488  | 90%    | 83%    | 0     | 167        |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| **Redding School     |      |        |        |       |            |
| District**           |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Moon River           | 403  | 74%    | 61%    | 0     | 24         |
| Elementary School    |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Ngyuen Elementary    | 643  | 69%    | 87%    | 0     | 38         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Walker Middle School | 891  | 69%    | 84%    | 0     | Approx. 20 |
+----------------------+------+--------+--------+-------+------------+
| ## Riverside School  |      |        |        |       |            |
|  District {#riversid |      |        |        |       |            |
| e-school-district-2} |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Fairfield Elementary | 810  | 80%    | 85%    | 84%   | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Palomar Elementary   | 577  | 78%    | 71%    | 11%   | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| King Elementary      | 667  | 57%    | 80%    | 16%   | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| #                    |      |        |        |       |            |
| # Smithville School  |      |        |        |       |            |
| District {#smithvill |      |        |        |       |            |
| e-school-district-4} |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Hendricks Elementary | 852  | 77%    | 64%    | 15%   | 1          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Blue Bay Elementary  | 857  | 60%    | 35%    | 7%    | 0          |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Marshall Junior High | 1    | 69%    | 68%    | 7%    | 1          |
| School               | ,239 |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| ## Sunnydale School  |      |        |        |       |            |
| District  {#sunnydal |      |        |        |       |            |
| e-school-district-2} |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Maple Elementary     | 516  | 85%    | 99%    | 0     | 15         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Rivera Elementary    | 730  | 99%    | 99%    | 0     | 40         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| **Trainville School  |      |        |        |       |            |
| District**           |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Morrison Elementary  | 761  | 88%    | 83%    | 54%   | 100        |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Bass Elementary      | 295  | 95%    | 86%    | 49%   | 100        |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+
| Jackson Middle       | 641  | 73%    | 80%    | 20%   | 60         |
| School               |      |        |        |       |            |
+----------------------+------+--------+--------+-------+------------+

[^1]: Public Law No. 107-110.

[^2]: The guidance has been finalized and is now available at
    [www.ed.gov/policy/elsec/guid/suppsvcsguid.doc](http://www.ed.gov/policy/elsec/guid/suppsvcsguid.doc).

[^3]: The six states included in the study sample were selected based on
    whether states had provider lists in place as of late October or
    early November 2002. States that had finalized their provider lists
    were contacted and asked to identify districts that were either
    already offering supplemental services to students or were about to
    begin offering services. From that list of recommended districts,
    the nine selected for this study were those that were furthest along
    in implementing the supplemental services provisions of the
    legislation.

[^4]: This report contains both stronger and weaker examples of
    implementation of the supplemental services provisions of NCLB. The
    examples used here should not necessarily be interpreted as model
    approaches to the implementation of supplemental services. Rather,
    these are examples of ways in which some states and districts have
    responded to the supplemental services requirements of the law.

[^5]: In cases where there are no approved providers available to
    provide supplemental services to disabled or limited English
    proficient students, the district needs to provide supplemental
    services, either directly or through a contract.

[^6]: To protect their confidentiality, pseudonyms have been used for
    all the states, districts, schools, and most of the service
    providers that participated in this study.

[^7]: Parents in eight districts participated in focus groups for this
    study. In one of these eight districts, only two parents
    participated. Parents in the ninth district had not yet been
    informed of their provider options and were not asked to participate
    in interviews.

[^8]: The guidance has been finalized and is now available at
    [www.ed.gov/policy/elsec/guid/suppsvcsguid.doc](http://www.ed.gov/policy/elsec/guid/suppsvcsguid.doc).

[^9]: To protect their confidentiality, pseudonyms have been used for
    all the states, districts, schools, and most of the service
    providers that participated in this study.

[^10]: The six states included in the study sample were selected based
    on whether states had provider lists in place as of late October or
    early November 2002. States that had finalized their provider lists
    were contacted and asked to identify districts that were either
    already offering supplemental services to students or were about to
    begin offering services. From that list of recommended districts,
    the nine selected for this study were those that were furthest along
    in implementing the supplemental services provisions of the
    legislation.

[^11]: This report contains both stronger and weaker examples of
    implementation of the supplemental services provisions of NCLB. The
    examples used here should not necessarily be interpreted as model
    approaches to the implementation of supplemental services. Rather,
    these are examples of ways in which some states and districts have
    responded to the supplemental services requirements of the law.

[^12]: Local Education Agencies.

[^13]: In cases where there are no approved providers available to
    provide supplemental services to disabled or limited English
    proficient students, the district needs to provide supplemental
    services, either directly or through a contract.

[^14]: This table provides available information regarding selected
    supplemental services providers. Not all providers, however, were
    serving students at the time the data were collected for this study.

[^15]: Sylvan Learning Systems Inc. has two major businesses that
    provide supplemental educational services: Sylvan Learning Centers
    and Sylvan Education Solutions. Sylvan Learning Centers provide
    tutoring services at their own private facilities. Students receive
    individualized instruction or small group instruction of 3:1
    students to tutors. Sylvan Education Solutions is a sister company
    to Sylvan Learning Centers and provides tutoring services to
    students directly in public and private schools, as well as through
    community-based organizations. The program serves children in small
    groups averaging around 6:1 students to tutors.

[^16]: Parents in eight districts participated in focus groups for this
    study. In one of these eight districts, only two parents
    participated. Parents in the ninth district had not yet been
    informed of their provider options and were not asked to participate
    in interviews.