September 7, 2004

**PROGRAM MONITORING REPORT -- NEVADA**

**Highly Qualified Teachers and ESEA Title II, Part A**

June 22-24, 2004

[U.S. Department of Education Monitoring Team]{.underline}

Robert Stonehill

Peggy Miles

Tamara Morse Azar (Westat)

[Nevada State Education Agency (SEA)]{.underline}

Keith Rheault, Superintendent of Schools

Chopin Kiang

Leslie James

[Local Educational Agency (LEA) Representatives (District)]{.underline}

Sue Cornfield (Lyon)

Jan Morrison (Washoe)

Ben Hayes (Washoe)

Joe de Braga (Elko)

Diane Efthimiou (Clark)

Ray Medina (Clark)

Christy Falba (Clark)

Lina Gutierrez (Clark)

[State Agency for Higher Education (SAHE) Coordinator]{.underline}

David Charlet

[SAHE Grant Recipients (District)]{.underline}

Alex Mendez (Nye)

Ray Medina (Clark)

The U.S. Department of Education (ED) has begun to monitor the progress
of the States in meeting the "Highly Qualified Teacher (HQT)"
requirement of *No Child Left Behind* (NCLB), in concert with reviewing
the uses of ESEA Title II, Part A, *Improving Teacher Quality State
Grants* funds at the State and local level. In the first such program
monitoring review, the ED team of Robert Stonehill, Peggy Miles, and
Tamara Morse Azar (Westat), visited the Nevada Department of Education
in Carson City, as well as several Nevada LEAs, from June 22-24, 2004.
As a secondary purpose to this visit, the ED team received feedback from
State and local officials about the appropriateness and adequacy of the
monitoring protocols that were developed for these purposes.

During the monitoring review, the team met with Nevada SEA staff
including Superintendent Keith Rheault, Assistant Superintendent of
Licensure Chopin Kiang, and ESEA Title II Coordinator Leslie James, as
well as many district officials (listed above) representing LEAs from
around the State.

The monitoring team met or conducted conference calls with staff from
five school districts, including the state's largest, Clark County. Sue
Cornfield, grant coordinator for Lyon County, and Jan Morrison and Ben
Hayes of Washoe County joined the meeting at the State Department. We
also conducted a conference call with Joe de Braga of Elko County. The
site visit continued to Las Vegas, where the team met with
representatives from Clark and Nye counties at the Clark County School
District offices. This strategy enabled the ED monitoring team to gain
insight into the challenges facing small rural districts as well as the
large urban areas.

Additionally, the team met with David Charlet, SAHE Grant Coordinator,
and spoke with two SAHE "Eligible Partnerships" competitive grant
recipients from Clark and Nye counties.

# HIGHLY QUALIFIED TEACHERS

The following table illustrates data on the percent of core academic
classes taught by highly qualified teachers, for the State and by
district as reported in the SEA and LEA protocol.

  --------------- ------------ ---------------- ------------------ -------------
  Percent of                                                       
  Classes Taught                                                   
  by Highly                                                        
  Qualified                                                        
  Teachers                                                         

                                                                    

                               **All            **High-Poverty**   **Low
                               Classrooms**                        Poverty**

  Statewide       Elementary   70.6             63.9               76.2

                  Secondary    51.4             25.9               71.9

                                                                    

  Lyon County     Elementary   95               n/a                n/a

                  Secondary    80               n/a                n/a

                                                                    

  Washoe County   Elementary   92               90                 92

                  Secondary    83               64                 84

                                                                    

  Elko County     Elementary   \*                                   

                  Secondary                                         

                                                                    

  Clark County    Elementary   64               61                 67

                  Secondary    34               27                 37

                                                                    

  \* Elko County                                                   
  reported that                                                    
  only 29 of                                                       
  their 653                                                        
  teachers were                                                    
  not highly                                                       
  qualified.                                                       

  \*\*Nye county                                                    
  did not provide                                                  
  a protocol.                                                      
  --------------- ------------ ---------------- ------------------ -------------

Approximately 1,580 teachers had completed the Nevada High Objective
Uniform State Standard of Evaluation (HOUSSE) procedures through October
2003. The data provided did not include special education teachers.

The Nevada teachers who have not yet met the HQT requirements include:

-   Teachers certified prior to 1989 when subject-area testing
    requirements were put in place;

-   Secondary teachers with a minor, previously permitted through State
    legislation;

-   Middle school teachers who are elementary certified and/or without
    content-area degrees; and

-   New teachers in the profession for less than three years with
    provisions on their license.

State officials did indicate that most of these teachers would be able
to demonstrate that they are highly qualified over the next two years,
either by successfully going through the State's HOUSSE procedures or by
taking an appropriate test.

Nevada uses the Praxis II content exams as one tool for teachers to
demonstrate competency. The Nevada SEA opened their HOUSSE criteria in
draft form to teachers, principals and other school administrators for a
period of open comments, in March 2003. During the subsequent HOUSSE
implementation, most districts -- through their human resources offices
-- went to the school level to conduct teacher reviews. Clark Country
went directly to school principals.

The SEA also created a verification form for meeting the HQT
requirements. The document has a section for the teacher's
qualifications and signature, the principal's verification and
signature, and the district human resources department verification.
Keeping such approvals on file, along with an explanation for how the
demonstration of competency was attained, meets the requirements of the
statute and provides documentation that the State's established
procedures conform to the Section 9101(23) requirements.

In providing this guidance, the SEA also plans to collect data on
high-quality professional development as a tool for ensuring districts
focused on the goals identified in the required needs assessments.
Additionally, the State is implementing high-quality professional
development for all teachers, rather than an effort to focus only on
those teachers who need to meet the highly qualified requirements. The
LEA professional development plans are integrated with school
improvement plans.

States provides guidance to LEAs on effective ways of coordinating
resources available for professional development from programs such as
*Title I* and *Title III*, ESEA Title V.

Note: Although the protocol reporting requirements required 2002-2003
data, Nevada is able to report current academic year (2003-2004) HQT
data. The State also plans to collect disaggregated secondary
content-area data that are captured in the licensure based certification
system.

**[Private Schools]{.underline}**

Statewide, Nevada has approximately 160 private schools. The Title II
coordinator believes that the State could improve its working
relationship and information sharing with the private school community.

Prior to receiving the next year's consolidated LEA applications, the
State of Nevada should consider providing guidance to its districts
about the required services for which the private school teachers,
principals, and other educational personnel are eligible. Funds from
Title II, *Part A* are subject to the uniform provisions of Section 9501
of the ESEA (*Participation by Private School Children and Teachers*).
It is important that the educational personnel receive educational
services on an equitable basis and in a timely manner.

**[LEA Review---Lyon County]{.underline}**

Sue Cornfield, coordinator for Federal programs in Lyon County, met with
the ED monitoring team at the SEA office in Carson City.

Lyon County reviewed the credentials and assignments of all of its 309
teachers, and reported that highly qualified teachers are teaching 90
percent of elementary classes and 85 percent of secondary classes.
Specifically, middle school teachers holding a K-8 certification are
still an issue for the district.

An item of note that came up in Lyon (and Elko as well) is that while
districts are not always using their Title II funds to ensure that
teachers who are not highly qualified receive the additional training
(or whatever) they need to become HQT, those districts do in fact ensure
that those services are provided, whether through Title V, Title I, or
through the district's own funds.

-   For paraprofessionals, the district bought study manuals and paid
    for the initial offering of the ETS ParaPro assessment.

-   Lyon County uses Title V funding for most of the professional
    development offered to teachers. Title II funds are focused on class
    size reduction efforts through hiring Reading Recovery teachers who
    are based in the three highest-need schools.

-   The district has also concentrated efforts on the School Improvement
    Process and adopting the Professional Learning Communities model.

**[LEA Review---Washoe County]{.underline}**

Washoe County representatives Jan Morrison, grant coordinator, and Ben
Hayes, evaluator, reviewed activities for the second-largest district in
Nevada. Washoe, which includes the city of Reno, has approximately
60,000 students in 81 schools. There are an additional 52 private and
charter schools.

The Washoe County human resources office used a data management system
to track more than 3,400 teachers through the highly qualified process.
The district reported that highly qualified teachers teach 92 percent of
elementary classes and 83 percent of secondary classes.

Disaggregated by high poverty, Washoe reported that highly qualified
teachers taught just 64 percent of secondary classes. However, this
number was for one middle school that fell in the high-poverty category,
prompting the district to suggest that the monitoring protocol be
adjusted so the data table can reflect the number of schools included in
each subcategory. (Note: the monitoring protocol has been revised
accordingly).

-   The district has focused professional development efforts on
    mentoring and induction programs, K-3 literacy, elementary and
    secondary English as a Second Language programs, the Principals'
    Leadership Academy, and middle-school class size reduction. For the
    Principal's Leadership Academy, the district pays a bonus to mentors
    and facilitators. The Teacher Mentoring Programs provides all novice
    teachers with a mentor.

**[LEA Review---Elko County]{.underline}**

Joe deBraga, Director of Curriculum, Instruction, and Technology for
Elko County, participated in a conference call with the ED monitoring
team. The district reported that 29 of 653 teachers were not highly
qualified. These teachers primarily are in the areas of special
education and multi-subject teachers in rural areas.

The district needs assessment identified three target areas as its
highest priority needs. These are: (1) training in the "Teach for
Success" model, (2) time for collaboration of the Professional Learning
Communities, and (3) training in analyzing and disaggregating student
data.

Elko County was allocated \$322, 063 in FY 2003 Title II funds. The
majority of the funding was used for reducing class size. An additional
\$80,000 was transferred to Title V for increased flexibility. As noted
above, Elko did not rely exclusively on its Title II funding to provide
additional training to help teachers demonstrate they are highly
qualified.

-   One program paid for with Title V funds prepared and paid for
    teachers to take the Praxis content exams. This program was offered
    through Great Basin College in Elko.

**[LEA Review---Clark County]{.underline}**

The ED monitoring team traveled to Las Vegas to meet with Clark County
officials and review the district monitoring protocol. The team met with
Diane Efthimiou, Grant Development and Adminsitration; Ray Medina, Grant
Coordinator; Christy Falba, Director of Math, Science and Technology;
Lina Gutierrez, Executive Director of Human Resources; and additional
staff involved with HQT issues.

Clark County provided highly qualified teacher data from October 1,
2003, compiled from Human Resources information. The district counted
teachers twice if they held multiple certifications.

Clark County has experienced overwhelming growth in the past few years,
and relies heavily on out-of-state recruitment to fill the rapidly
growing number of positions. Clark County needs to hire more than 2,000
new teachers per year, and they recruit from 40 states and Department of
Defense schools. As a result, many of the new hires were not initially
certified in Nevada and lack certain licensure requirements.

The district reported that highly qualified teachers taught 64 percent
of elementary classes and 34 percent of secondary classrooms. For
elementary teachers, Clark explained that teachers who have not taken
the Praxis exam because they were certified before 1989 and those with
coursework provisions on their license (a common problem for
out-of-state applicants) make up the portion of teachers who are not
highly qualified. In secondary classes, the percent of classes taught by
highly qualified teachers is low because of its 10 middle schools, which
have teachers with multiple areas of licensure and teachers who have
only a minor in the subject areas they are teaching. (Note: Clark County
has a policy that ALL Title I teachers, not just the newly hired ones,
be highly qualified and has routinely been transferring non-HQT teachers
to non-Title I schools, often to new schools that are opening to
accommodate the rapid population growth of the area).

-   Paraprofessionals work toward their four-year bachelor's degree with
    a Title II funded program that offers tuition reimbursement to those
    with an Associate's degree.

-   Clark County uses Title II to fund a wide range of programs
    including but not limited to standards and assessment development
    and administration, leadership, curriculum development (e.g., social
    studies content programs), and training teachers to implement peer
    mediation programs in their classrooms. Through an evaluation of
    these uses, Clark recognized that they were unnecessarily
    transferring funds to Title V (e.g., in FY 2002, Clark transferred
    \$3.6 million of their \$9.7 million in Title II funding into Title
    V).

The district transference of funds does highlight a conflict with end
dates of the two programs. In Nevada, Title II funding ends September
30, while Title V funding expires June 30. The district and the State
will be re-examining these inconsistencies.

# ADMINISTRATION OF TITLE II FUNDS

## Needs Assessment

Nevada requires that each district submit a detailed needs assessment in
its sub-grant application. Applicants must include a description of the
district's strategy to have all teachers meet the HQT requirements by
the end of the 2005-2006 academic year; an assessment of professional
development needs based on student achievement; staff skills,
competencies, and knowledge needed to align to student performance;
hiring needs; class size reduction data; and private school
participation.

The SEA can review the LEAs' needs assessment to identify whether the
use of Title II, A funds are addressing the identified needs. Technical
assistance can be given if the LEA uses do not coordinate with the
results of this assessment.

**[Use of Funds]{.underline}**

[Class size reduction (CSR)]{.underline}

Nevada State law establishes CSR limits by grade, focused at the K-3
level. If districts choose to reduce beyond the State minimum, they must
show that Federal funds do not supplant the State money targeted for
CSR. In general, districts have continued to use the majority of Title
II funding for class size reduction. When the funds are used for class
size reduction, the SEA should encourage the LEAs to assess the
students' achievement scores to determine if the reduced class size was
effective in assisting students in increasing their level of
achievement.

[Local-Flex]{.underline}

A noted pattern through the LEA reviews was that districts are taking
advantage of the statute's transferability provisions. For instance,
some of the districts indicated that they (e.g., Clark and Elko) had
transferred Title II funds into Title V (even though the activities
supported under Title V were already authorized Title II). The State had
established different expenditure deadlines for Title II and Title V
funds. This greater length of expenditure time appeared to be more of a
motivator to LEAs to transfer funds as were the appropriateness of the
services.

The transferability provisions allows the LEAs to use those funds for
any ESEA purpose consistent with the SEA's plan in order to meet the
State's definition of adequate yearly progress, improve student academic
achievement, and narrow achievement gaps. The ED team provided guidance
to the SEA and LEA officials on this issue. That is, the timeline for
expenditures is the same for Title II and Title V funds. In particular,
the General Education Provisions Act (GEPA), 20 U.S.C. 1221-1234i,
contains general statutory requirements applicable to most programs
administered by the Department, including *Title II and Title V*. The
so-called "Tydings amendment" provides grantees an additional year to
obligate funds under these programs.

Some interesting and innovative uses of Title II funds also emerged,
e.g.:

-   In a State-funded effort that will be shared with all districts,
    Clark County videotaped review courses in all content areas to
    prepare teachers for the appropriate Praxis exams. The classes were
    broadcast over the University of Nevada \-- Las Vegas cable channel
    and tapes will be sent to the districts. The courses were offered to
    teachers free of charge.

-   Nevada's Regional Professional Development Programs (RPDP) have
    begun targeted professional development for principals, and to move
    teachers into administration. Nevada also received a \$3.3 million
    grant from the Wallace Foundation to align principal development and
    student achievement outcomes.

-   Nevada offers financial incentives to teachers working toward
    National Board Certification. Teachers are eligible to receive up to
    \$2,300 for reimbursement of costs incurred through the application
    process. In 2003, 38 teachers earned their National Board
    Certification.

**[STATE AGENCY FOR HIGHER EDUCATION]{.underline}**

The Nevada SAHE received \$340,389 for competitive "eligible
partnership" funding. In 2003, the SAHE awarded five grants, ranging
from \$27,000 to \$103,000. The initial SAHE grants were awarded for 18
months. Grantees from Nye and Clark Counties discussed their projects
with the ED monitoring team.

Note: The SAHE has to work with the limitation that only one district in
the state, Clark County, qualifies as a high-need district, and a
considerable amount of discussion took place around the various roles
that Clark County could play in multiple grants.

All five programs that were funded for 2003 provide professional
development activities in the core academic subjects to ensure that
teachers are highly qualified. The programs are:

-   *Using Robotics to Teach Nevada/Washoe County Grade Eight Physics*.
    The project is aimed at middle school science teachers with large
    English language learner populations.

-   *Southern Nevada Biotechnology Training and Curriculum Development
    Project*. Faculty from Nevada State College Teacher Preparation
    Department, UNLV Department of Biological Science, and the
    biotechnology program at CCSN create a partnership with the Southern
    region's RPDP to develop focused professional development
    opportunities dedicated to support and enhance the biology
    background of ninth through twelfth grade teachers.

-   *Mount Charleston Learning Communities*. Nye and Clark Counties, in
    partnership with Nevada State College, will implement a professional
    learning community program at Mount Charleston Elementary School.

-   *Nevada Educators Really Doing Science (NERDS) IV*. The NERDS
    institute is designed to prepare teachers at all levels learn new
    science content by using the processes, skills and tools of science
    inquiry.

-   *Continuing to Focus on Mathematical Understanding through
    Assessment*. UNLV and Clark County work to continue site-based,
    sustained professional development for elementary school teachers in
    both content and pedagogy reflected in the Nevada Mathematics
    Standards.

### [SUMMARY]{.underline}

The ED monitoring team did not find any substantial problems with the
State's progress in addressing the HQT requirements or with its uses of
Title II funds. The State and local officials we met with are to be
commended for the level of their preparation and their candor in sharing
with us their current status and remaining challenges, and especially in
the seriousness with which they are taking the NCLB requirements that
all classes be taught by highly qualified teachers. In addition, the
State will be providing additional information to its districts
reminding them of their requirement to consult with the private schools
and ensure that participating schools receive equitable services.

The State has done a complete review of the status of all of its
teachers and has developed programs, using a variety of funding sources,
to ensure that all teachers who have not already been documented as HQT
will attain that designation within the next two years.

Although the ED team was somewhat surprised to find how much
transferability of funding was occurring at the local level -- sometimes
unnecessary because the activities supported would have been allowable
under either Title II or Title V -- such practices are allowed under the
statute and Non-Regulatory Guidance.

# CORRECTIVE ACTIONS

No corrective actions are required.