September 23, 2005

HIGHLY QUALIFIED TEACHERS AND

IMPROVING TEACHER QUALITY STATE GRANTS (ESEA TITLE II, PART A)

MONITORING REPORT

**Michigan Department of Education**

**September 6-8, 2005**

**U.S. Department of Education Monitoring Team:**

Elizabeth Witt

Julie Coplin

Darcy Pietryka (Westat)

**Michigan Department of Education (MDE)**

MaryAlice Galloway, Special Assistant to the Deputy Superintendent

Dr. Flora Jenkins, Director, Office of Professional Preparation Services
(OPPS)

Dr. Frank Ciloski, Supervisor, Client Services, OPPS

Dr. Catherine Smith, Supervisor, Program Preparation, OPPS

Krista Ried, Education Consultant, OPPS

Dr. Bonnie Rockafellow, Education Consultant, OPPS

Steve Stegink, Higher Education Consultant, OPPS

Sue Wittick, Higher Education Coordinator, OPPS

Linda Brown, Assistant Director, Office of School Improvement (OSI)

Betty Underwood, Assistant Director, OSI

Margaret Madigan, Supervisor, OSI

Judy Thelen, Department Analyst, OSI

Mary Ann Chartrand, Director, Office of Grants Coordination and School
Support (OGCSS)

Louis Burgess, Supervisor, OGCSS

Rick Floria, Director, Financial Management

Dan Schab, Michigan Teacher of the Year

**State Agency for Higher Education**

Cheryl Poole, Professional Development Consultant, OPPS

**Michigan Education Association**

Mary Anne Adams

**American Federation of Teachers (AFT) Michigan**

Lois Lofton Doniver

**Overview of Michigan:**

Number of Districts: 540

Number of Teachers: 110,000

+------------------------------------------+-------------+------------+
| ## Title II Funding Amounts              | **FY 2004** | **FY       |
|                                          |             | 2005**     |
+------------------------------------------+-------------+------------+
| Total State allocation                   | \$          | \$1        |
|                                          | 109,362,769 | 09,399,197 |
+------------------------------------------+-------------+------------+
| Allocation for local educational         | \$          | \$1        |
| agencies (LEAs)                          | 102,855,684 | 02,899,946 |
+------------------------------------------+-------------+------------+
| State educational agency (SEA) State     | \$2,706,729 | \          |
| Activities allocation                    |             | $2,707,630 |
+------------------------------------------+-------------+------------+
| State Agency for Higher Education (SAHE) | \$2,706,729 | \          |
| allocation                               |             | $2,707,630 |
+------------------------------------------+-------------+------------+

**Scope of Review:**

Like all State educational agencies (SEAs), the Michigan Department of
Education (MDE), as a condition of receiving funds under Title I, Part A
and Title II, Part A of the *Elementary and Secondary Education Act*
(ESEA), as amended by the *No Child Left Behind Act* (NCLB), provided an
assurance to the U.S. Department of Education (the Department) that it
would administer these programs in accordance with all applicable
statutory and regulatory requirements, including those in Title I, Part
A that concern "Highly Qualified Teachers" (HQT) and those that govern
the use of Title II, Part A funds. See **§**9304(a)(1) of the ESEA. One
of the specific requirements the Department established for an SEA's
receipt of program funds under its consolidated state application
(§9302(b)) was submission to the Department of annual data on how well
the State has been meeting its performance target for Performance
Indicator 3.1: "The percentage of classes being taught by 'highly
qualified' teachers (as the term is defined in §9101(23) of the ESEA),
in the aggregate and in 'high-poverty' schools (as the term is defined
in **§**1111(h)(1)(C)(viii) of the ESEA)."

The Department's monitoring visit to Michigan had two purposes. One was
to review the progress of the State in meeting the ESEA's highly
qualified teacher requirements. The second was to review the use of ESEA
Title II, Part A funds by the SEA, selected LEAs, and the State agency
for higher education (SAHE), to ensure that the funds are being used to
prepare, retain, and recruit high-quality teachers and principals so
that all children will achieve to a high academic achievement standard
and to their full potential.

The monitoring review was conducted from September 6-8, 2005, at the
offices of the MDE. In addition to meeting with the MDE staff noted
above, as part of the review, the Department monitoring team met with
Cheryl Poole, SAHE Coordinator. The monitoring team also met with Dr.
Margaret Ropp, Director, Center for Educational Performance and
Information (CEPI), and her staff members Tom Howell, Lynne Erickson,
and Dr. Oren Christmas. The monitoring team conducted conference calls
with representatives of Forest Hills Public Schools and Ironwood Public
Schools and conducted a site visit to Detroit Public Schools.

#### Summary of Monitoring Indicators

+----------+-------------------------------+----------------+--------+
| #        |                               |                |        |
| Monitori |                               |                |        |
| ng Area  |                               |                |        |
| 1: Highl |                               |                |        |
| y Qualif |                               |                |        |
| ied Teac |                               |                |        |
| her Syst |                               |                |        |
| ems & Pr |                               |                |        |
| ocedures |                               |                |        |
+----------+-------------------------------+----------------+--------+
| *        | **Description**               | # Status       | # Page |
| *Element |                               |                |        |
| Number** |                               |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Has the State developed and   | Recommendation | 7      |
| Element  | implemented procedures,       |                |        |
| 1.1      | consistent with the statutory |                |        |
|          | definition of highly          |                |        |
|          | qualified, to determine       |                |        |
|          | whether *all* teachers of     |                |        |
|          | core academic subjects are    |                |        |
|          | highly qualified (§9101(23))? |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Are all new elementary school | Met            | NA     |
| Element  | teachers (including special   | Requirements   |        |
| 1.2      | education teachers, as        |                |        |
|          | appropriate) required to pass |                |        |
|          | a rigorous State test in      |                |        |
|          | reading, writing,             |                |        |
|          | mathematics, and the other    |                |        |
|          | areas of the elementary       |                |        |
|          | school curriculum to          |                |        |
|          | demonstrate subject-matter    |                |        |
|          | competency                    |                |        |
|          | (§9101(23)(B)(II))?           |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Are all new middle and        | Finding        | 7      |
| Element  | secondary school teachers     |                |        |
| 1.3      | (including special education  |                |        |
|          | teachers, as appropriate)     |                |        |
|          | required to demonstrate       |                |        |
|          | subject-matter competency in  |                |        |
|          | each core academic subject    |                |        |
|          | they teach                    |                |        |
|          | (§9101(23)(B)(II)(ii))?       |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Are all veteran (i.e., those  | > Finding      | 8      |
| Element  | who are not new to the        | >              |        |
| 1.4      | profession) elementary school | >              |        |
|          | teachers (including special   | Recommendation |        |
|          | education teachers, as        |                |        |
|          | appropriate) required to      |                |        |
|          | demonstrate subject-matter    |                |        |
|          | competency by passing a       |                |        |
|          | rigorous State test or by     |                |        |
|          | completing the State's "High  |                |        |
|          | Objective Uniform State       |                |        |
|          | Standard of Evaluation"       |                |        |
|          | (HOUSSE) procedures           |                |        |
|          | (§9101(23)(C))?               |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Are all veteran middle and    | > Finding      | 9      |
| Element  | secondary teachers (including |                |        |
| 1.5      | special education teachers,   |                |        |
|          | as appropriate) required to   |                |        |
|          | demonstrate subject-matter    |                |        |
|          | competency in each core       |                |        |
|          | academic subject they teach?  |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | If the State has developed    | Met            | NA     |
| Element  | HOUSSE procedures, please     | Requirements   |        |
| 1.6      | provide a copy of the most    |                |        |
|          | current version(s). For each  |                |        |
|          | set of HOUSSE procedures the  |                |        |
|          | State has developed, please   |                |        |
|          | describe how it meets each of |                |        |
|          | the statutory requirements of |                |        |
|          | §9101(23)(C)(ii).             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | How does the SEA ensure that, | Finding        | 9      |
| Element  | since the beginning of the    |                |        |
| 1.7      | 2002-03 school year,          | Recommendation |        |
|          | districts hire only highly    |                |        |
|          | qualified teachers (including |                |        |
|          | special education teachers,   |                |        |
|          | as appropriate) to teach in   |                |        |
|          | Title I programs?             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | How has the SEA ensured,      | Finding        | 10     |
| Element  | since the beginning of the    |                |        |
| 1.8      | 2002-03 school year, that     | Recommendation |        |
|          | districts that use ESEA Title |                |        |
|          | II funds to reduce class size |                |        |
|          | hire only highly qualified    |                |        |
|          | teachers for such positions?  |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Does the SEA's plan establish | Finding        | 10     |
| Element  | annual measurable objectives  |                |        |
| 1.9      | for each LEA and school to    |                |        |
|          | ensure that annual increases  |                |        |
|          | occur:                        |                |        |
|          |                               |                |        |
|          | -   in the percentage of      |                |        |
|          |     highly qualified teachers |                |        |
|          |     at each LEA and school;   |                |        |
|          |     and                       |                |        |
|          |                               |                |        |
|          | -   in the percentage of      |                |        |
|          |     teachers who are          |                |        |
|          |     receiving high-quality    |                |        |
|          |     professional development  |                |        |
|          |     to enable them to become  |                |        |
|          |     highly qualified and      |                |        |
|          |     successful classroom      |                |        |
|          |     teachers                  |                |        |
|          |     (§1119(a)(2)(A))?         |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Does the SEA also have a plan | Recommendation | 11     |
| Element  | with specific steps to ensure |                |        |
| 1.10     | that poor and minority        |                |        |
|          | children are not taught at    |                |        |
|          | higher rates than other       |                |        |
|          | children by inexperienced,    |                |        |
|          | unqualified, and/or           |                |        |
|          | out-of-field teachers? Does   |                |        |
|          | the plan include measures to  |                |        |
|          | evaluate and publicly report  |                |        |
|          | the progress of such steps    |                |        |
|          | (§1111(b)(8)(C))?             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Has the State reported to the | Finding        | 11     |
| Element  | Secretary in its Consolidated |                |        |
| 1.11     | State Performance Report      | Recommendation |        |
|          | (CSPR) the number and         |                |        |
|          | percentage of core academic   |                |        |
|          | classes taught by highly      |                |        |
|          | qualified teachers, in the    |                |        |
|          | aggregate and in high-poverty |                |        |
|          | schools, consistent with the  |                |        |
|          | statutory definition of       |                |        |
|          | highly qualified              |                |        |
|          | (§1111(h)(4)(G); §9101(23))?  |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Does the State prepare and    | Finding        | 12     |
| Element  | disseminate to the public an  |                |        |
| 1.12     | Annual State Report Card      |                |        |
|          | (§1111(h)(1)(C)(viii))? If    |                |        |
|          | so, how is it disseminated?   |                |        |
+----------+-------------------------------+----------------+--------+

+----------+------------------------------+-----------------+--------+
| # Mo     |                              |                 |        |
| nitoring |                              |                 |        |
|  Area 2: |                              |                 |        |
|  Adminis |                              |                 |        |
| tration  |                              |                 |        |
| of ESEA  |                              |                 |        |
| Title II |                              |                 |        |
| , Part A |                              |                 |        |
+----------+------------------------------+-----------------+--------+
| *        | # Description                | ### Status      | #      |
| *Element |                              |                 | # Page |
| Number** |                              |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA allocate funds  | Met             | NA     |
| Element  | according to the statute,    | Requirements    |        |
| 2.1      | using the most recent Census |                 |        |
|          | Bureau data as described in  |                 |        |
|          | the Non-Regulatory Guidance  |                 |        |
|          | (§2121(a))?                  |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA require an      | Commendation    | 12     |
| Element  | application from each LEA    |                 |        |
| 2.2      | before providing Title II,   | Recommendation  |        |
|          | Part A funding? If yes, what |                 |        |
|          | information does the SEA     |                 |        |
|          | require in the LEA           |                 |        |
|          | application (§2122(b))?      |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | In particular, does the SEA  | Met             | NA     |
| Element  | require each LEA to describe | Requirements    |        |
| 2.3      | how the activities to be     |                 |        |
|          | carried out are based on the |                 |        |
|          | required local needs         |                 |        |
|          | assessment (§2122(b))?       |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have a          | Met             | NA     |
| Element  | procedure to determine the   | Requirements    |        |
| 2.4      | amount of funds each LEA     |                 |        |
|          | expended during the period   |                 |        |
|          | of availability?             |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have a          | Met             | NA     |
| Element  | procedure to regularly       | Requirements    |        |
| 2.5      | review the drawdowns of the  |                 |        |
|          | LEAs?                        |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have a written  | > Met           | NA     |
| Element  | policy on allowable          | > Requirements  |        |
| 2.6      | carryover funds?             |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | If an LEA cannot obligate    | > Met           | NA     |
| Element  | funds within the 27 months   | > Requirements  |        |
| 2.7      | of availability (which       |                 |        |
|          | includes the extra year of   |                 |        |
|          | availability permitted under |                 |        |
|          | the Tydings amendment), does |                 |        |
|          | the SEA have a procedure for |                 |        |
|          | reallocating these funds to  |                 |        |
|          | other LEAs?                  |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have records to | Met             | NA     |
| Element  | show that each LEA meets the | Requirements    |        |
| 2.8      | maintenance of effort        |                 |        |
|          | requirements?                |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA conduct         | Finding         | 13     |
| Element  | regular, systematic reviews  |                 |        |
| 2.9      | of LEAs to monitor for       | Recommendation  |        |
|          | compliance with Federal      |                 |        |
|          | statutes and regulations,    |                 |        |
|          | applicable State rules and   |                 |        |
|          | policies, and the approved   |                 |        |
|          | subgrant application?        |                 |        |
|          | (Please provide monitoring   |                 |        |
|          | plan and instruments         |                 |        |
|          | onsite.)                     |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA ensure that it  | Met             | NA     |
| Element  | and its component LEAs are   | Requirements    |        |
| 2.10     | audited annually, if         |                 |        |
|          | required, and that all       |                 |        |
|          | corrective actions required  |                 |        |
|          | through this process are     |                 |        |
|          | fully implemented?           |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Has the SEA identified and   | Finding         | 13     |
| Element  | provided technical           |                 |        |
| 2.11     | assistance to LEAs that are  |                 |        |
|          | not making progress toward   |                 |        |
|          | meeting their annual         |                 |        |
|          | measurable objectives in     |                 |        |
|          | meeting the highly qualified |                 |        |
|          | teacher challenge (§2141)?   |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Has the SEA provided         | Commendation    | 14     |
| Element  | guidance to the LEAs on      |                 |        |
| 2.12     | initiating consultation with |                 |        |
|          | nonpublic school officials   |                 |        |
|          | for equitable services? If   |                 |        |
|          | so, please provide           |                 |        |
|          | documentation of the         |                 |        |
|          | guidance at the time of the  |                 |        |
|          | visit.                       |                 |        |
+----------+------------------------------+-----------------+--------+

+---------+---------------------------------+------------------+------+
| #       |                                 |                  |      |
| Monitor |                                 |                  |      |
| ing Are |                                 |                  |      |
| a 3: St |                                 |                  |      |
| ate Act |                                 |                  |      |
| ivities |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| **      | # Description                   | ### Status       | ##   |
| Element |                                 |                  | Page |
| N       |                                 |                  |      |
| umber** |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the State use its State    | Met Requirements | NA   |
| ritical | Activities funds to promote the |                  |      |
| Element | recruitment, hiring, training,  |                  |      |
| 3.1     | and retention of highly         |                  |      |
|         | qualified teachers and          |                  |      |
|         | principals?                     |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the State support          | Met Requirements | NA   |
| ritical | activities that focus on        |                  |      |
| Element | increasing the subject-matter   |                  |      |
| 3.2     | knowledge of teachers and that  |                  |      |
|         | assist teachers to become       |                  |      |
|         | highly qualified?               |                  |      |
+---------+---------------------------------+------------------+------+

+---------+---------------------------------+------------------+------+
| #       |                                 |                  |      |
| Monitor |                                 |                  |      |
| ing Are |                                 |                  |      |
| a 4: St |                                 |                  |      |
| ate Age |                                 |                  |      |
| ncy for |                                 |                  |      |
|  Higher |                                 |                  |      |
|  Educat |                                 |                  |      |
| ion (SA |                                 |                  |      |
| HE) Act |                                 |                  |      |
| ivities |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| **      | # Description                   | ### Status       | ##   |
| Element |                                 |                  | Page |
| N       |                                 |                  |      |
| umber** |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Did the SAHE manage a           | Commendation     | 14   |
| ritical | competition for eligible        |                  |      |
| Element | partnerships?                   |                  |      |
| 4.1     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the SAHE have procedures   | Met Requirements | NA   |
| ritical | to ensure that eligible         |                  |      |
| Element | partnerships include the        |                  |      |
| 4.2     | required members, i.e., an      |                  |      |
|         | institution of higher education |                  |      |
|         | and the division of the         |                  |      |
|         | institution that prepares       |                  |      |
|         | teachers and principals, a      |                  |      |
|         | school of arts and sciences,    |                  |      |
|         | and a high-need LEA?            |                  |      |
+---------+---------------------------------+------------------+------+

**[Area 1: Highly Qualified Teacher Systems & Procedures]{.underline}**

**[Critical Element 1.1:]{.underline} Has the State developed and
implemented procedures, consistent with the statutory definition of
highly qualified, to determine whether all teachers of core academic
subjects are highly qualified (§9101(23))?**

**[Recommendation:]{.underline}** The State offers a full-year license
for teachers with a bachelor's degree who have not yet fulfilled the
State's certification requirements. Some of these teachers have
demonstrated subject-matter competency and are enrolled in an approved
alternative route to certification and, thus, may be deemed as highly
qualified teachers (HQT). Others holding this license are not highly
qualified. The State also has an emergency license that is currently
being phased out. All teachers holding this license are appropriately
counted as non-HQT. Though the State correctly designates the HQT status
of teachers holding the full-year and emergency licenses, the State
should communicate more clearly to its LEAs which licensure options are
true emergency or waivers (i.e., non-HQT) and which are provisional or
transitional (i.e., HQT if other conditions are met). To that end, the
State should consider adding requirements to the full-year license to
make it a formal alternative route that meets the HQT requirements in
Section 200.56(a)(2) of the *Title I* regulations.

**[Critical Element 1.3:]{.underline} Are all new middle and secondary
school teachers (including special education teachers, as appropriate)
required to demonstrate subject-matter competency in each core academic
subject they teach (§9101(23)(B)(II)(ii))?**

**[Finding:]{.underline}** The State does not require new middle and
secondary school teachers of history, geography, civics/government, or
economics to demonstrate subject-matter competency in each of those
subjects they teach. The State allows middle and secondary social
studies teachers new to the profession to demonstrate subject-matter
competency by holding a general social studies endorsement; this
endorsement requires candidates to meet the State standards in all four
discrete areas of social studies. This broad-field endorsement may not,
however, provide adequate subject-matter preparation for each of the
subjects explicitly noted in the statute. New social studies teachers
may also pass a broad-field content-area assessment. This assessment,
similarly, may not provide adequate subject-matter preparation in each
of the core academic subjects explicitly noted in the statute.

**[Citation:]{.underline}** Section 9101(11) of the ESEA identifies
history, geography, civics/government, and economics as individual core
academic subjects. Section 9101(23)(B)(ii) of the ESEA requires new
teachers of core academic subjects to demonstrate subject-matter
competency in each core academic subject they teach.

**[Further Action Required:]{.underline}** The MDE must ensure that all
history, geography, civics/government, and economics teachers
demonstrate subject-matter competency in each of these subjects that
they teach no later than the end of the 2005-06 school year. If the MDE
has determined that the coursework requirement for an academic major in
social studies provides coursework "equivalent to a major" in each or in
a subset of these specific core academic subjects, it must specifically
explain the basis for this determination.

**[Critical Element 1.4:]{.underline} Are all veteran (i.e., those who
are not new to the profession) elementary school teachers (including
special education teachers, as appropriate) required to demonstrate
subject-matter competency by passing a rigorous State test or by
completing the State's "High Objective Uniform State Standard of
Evaluation" (HOUSSE) procedures (§9101(23)(C))?**

**[Finding:]{.underline}** The State considers all elementary teachers
who hold National Board for Professional Standards (National Board)
Certification, a master's degree, or have completed coursework
equivalent to a major to be highly qualified. These options are not ones
by which the statute allows elementary teachers who are not new to the
profession to demonstrate subject-area competence.

**[Citation:]{.underline}** Section 9101(23)(C) of the ESEA says that
veteran elementary teachers can demonstrate subject-matter competency
either by passing a rigorous State assessment of academic subject matter
or by using the high, objective, uniform, State standard of evaluation
(HOUSSE).

**[Further Action Required:]{.underline}** The MDE must revise its
procedures so that veteran elementary teachers may demonstrate
subject-knowledge competency only by passing a test or by satisfying the
requirements of the State's HOUSSE procedure.

**[Recommendation:]{.underline}** The MDE should revise its HOUSSE
procedures for veteran elementary school teachers to include factors
pertaining to National Board Certification or master's degrees. As part
of a State's HOUSSE procedures, either of these factors could be
sufficient to demonstrate subject-matter competency.

**[Critical Element 1.5:]{.underline} Are all veteran middle and
secondary teachers (including special education teachers, as
appropriate) required to demonstrate subject-matter competency in each
core academic subject they teach?**

**[Finding:]{.underline}** As noted in Critical Element 1.3, the State
does not require middle and secondary school teachers of history,
geography, civics/government, or economics to demonstrate subject-matter
competency in each of the four discrete areas of the statute. Thus,
veteran teachers of history, geography, civics/government, or economics
may not have demonstrated adequate subject-matter preparation for each
of the core academic subjects explicitly noted in the statute.

**[Citation]{.underline}:** Section 9101(23)(C) of the ESEA requires
middle or secondary school teachers not new to the profession to
demonstrate subject-matter competency in each of the core academic
subjects they teach by passing a content test, successfully completing
an academic major, coursework equivalent to a major, advanced
certification, a graduate degree, or by satisfying the State's HOUSSE
requirements.

**[Further Action Required:]{.underline}** The MDE must ensure that all
history, geography, civics/government, and economics teachers
demonstrate subject-matter competency in each of these subjects that
they teach no later than the end of the 2005-06 school year. If the MDE
has determined that the coursework requirement for an academic major in
social studies provides coursework "equivalent to a major" in each or in
a subset of these specific core academic subjects, it must specifically
explain the basis for this determination.

**[Critical Element 1.7:]{.underline} How does the SEA ensure that,
since the beginning of the**

**2002-03 school year, districts hire only highly qualified teachers
(including special education teachers, as appropriate) to teach in Title
I programs?**

**[Finding:]{.underline}** Though the State has implemented procedures
to ensure that LEAs hire only highly qualified teachers to teach in
Title I programs, the State is not able to ensure that districts have
hired only highly qualified teachers to teach in Title I programs.
Similarly, the State is not able to ensure that districts are properly
exercising their parental notification requirements.

**[Citation:]{.underline}** §1119(a)(1) of the ESEA requires that all
teachers hired after the first day of the 2002-03 school year to teach
in Title I programs must be highly qualified.

**[Further Action Required:]{.underline}** The MDE must submit a written
plan with specific procedures and a timeline for requiring LEAs in the
State to ensure that all teachers hired to teach in Title I programs
since the first day of the 2002-03 school year, including special
education teachers providing direct instruction in core academic
subjects, demonstrate, in a manner consistent with statute, that they
are highly qualified in each core academic subject they teach by no
later than the end of the 2005-06 school year.

**[Recommendation:]{.underline}** The State may wish to include
assurances pertaining to ESEA Title I hiring requirements in its
consolidated district application.

**[Critical Element 1.8:]{.underline} Has the SEA ensured, since the
beginning of the 2002-03 school year, that districts that use ESEA Title
II, Part A funds to reduce class size hire only highly qualified
teachers for such positions?**

**[Finding:]{.underline}** Though the State has implemented procedures
to ensure that LEAs pay only highly qualified teachers with ESEA funds
to reduce class size, the State is not able to ensure that districts
have, since the 2002-03 school year, paid only highly qualified teachers
with ESEA Title II funds to reduce class size.

**[Citation:]{.underline}** Section 2123(a)(2)(B) of the ESEA allows
LEAs to use ESEA Title II, Part A funds to pay highly qualified teachers
to reduce class size.

**[Further Action Required:]{.underline}** The MDE must submit a written
plan with specific procedures and a timeline for requiring LEAs in the
State to ensure that all teachers, including special education teachers
providing direct instruction in core academic subjects, paid with ESEA
Title II funds to reduce class size are highly qualified.

**[Recommendation:]{.underline}** The State may wish to include
assurances pertaining to the highly qualified status of teachers paid
with Title II, Part A funds for the purpose of Class Size Reduction in
its Consolidated Application.

**[Critical Element 1.9:]{.underline} Does the SEA's plan establish
annual measurable objectives for each LEA and school to ensure that
annual increases occur:**

-   **in the percentage of highly qualified teachers at each LEA and
    school; and**

-   **in the percentage of teachers who are receiving high-quality
    professional development to enable such teachers to become highly
    qualified and successful classroom teachers (§1119(a)(2)(A))?**

**[Finding:]{.underline}** The State has established benchmarks at the
state level only and does not have a written plan that establishes
annual measurable objectives for districts that can be used to measure
districts' progress toward having all teachers meet the highly qualified
requirements by the end of the 2005-06 school year. Further, the State
has not identified districts that are not making progress toward their
annual measurable objectives.

**[Citation]{.underline}:** Section 1119(a)(2)(A) of the ESEA requires
each SEA to develop a plan to ensure that all teachers teaching core
academic subjects within the State are highly qualified by the end of
the 2005-06 school year. This plan must establish annual measurable
objectives for each LEA and school that includes an annual increase in
the percentage of highly qualified teachers at each LEA and school and
the percentage of teachers receiving high-quality professional
development.

**[Further Action Required:]{.underline}** The MDE must submit a written
plan with specific procedures and a timeline for implementing this
requirement. The revised plan must include, among other things, annual
measurable objectives for each LEA and school that includes an annual
increase in the percentage of highly qualified teachers in each LEA and
school and in the percentage of teachers receiving high-quality
professional development.

**[Critical Element 1.10:]{.underline} Does the SEA also have a plan
with specific steps to ensure that poor and minority children are not
taught at higher rates than other children by inexperienced, unqualified
and out-of-field teachers? Does the plan include measures to evaluate
and publicly report the progress of such steps (§1111(b)(8)(C))?**

**[Recommendation:]{.underline}** Though the State has a plan with steps
to ensure that poor and minority children are not taught at higher rates
than other children by inexperienced, unqualified, or out-of-field
teachers in its State Board Strategic Plan, the plan is not particularly
detailed. The State also has several programs in place to address the
needs of its high-priority LEAs, many of which are populated largely by
poor and minority children. The monitoring team recommends that the
State use the elements in the State Board Strategic Plan and the
programs it already has in place to assist high-priority LEAS to create
a more comprehensive plan to ensure that poor and minority children are
not taught at higher rates than other children by inexperienced,
unqualified, or out-of-field teachers. Programs and activities should be
examined in a unified way to ensure that they work together and to
eliminate any duplication of effort.

**[Critical Element 1.11:]{.underline} Has the State reported to the
Secretary in its Consolidated State Performance Report (CSPR) the number
and percentage of core academic classes taught by highly qualified
teachers, in the aggregate and in high-poverty schools, consistent with
the statutory definition of highly qualified (§1111(h)(4)(G);
§9101(23))?**

**[Finding:]{.underline}** Though the State reported highly qualified
teacher data, in the aggregate and in high-poverty schools, the State
was not able to report class-level data; it is only able to provide data
as a percentage of full-time-equivalent (FTE) teachers. The monitoring
team met with Michigan's Center for Educational Performance and
Information (CEPI), the agency that compiles the State's data, to
explain the reporting requirements. CEPI will work with MDE, which will
in turn work with LEAs, to remedy the problem.

**[Citation]{.underline}:** Section 1111(h)(4)(G) of the ESEA requires
each SEA annually to report to the U.S. Secretary of Education on the
percentage of classes (in core academic subjects) taught by highly
qualified teachers in the State, local educational agency, and
school[^1] (a summary of which §1111(h)(5) requires the Secretary
annually to report to Congress).

**[Further Action Required:]{.underline}** The MDE must submit a written
plan with specific procedures and a timeline for reporting to the
Secretary through the Consolidated State Performance Report in a manner
consistent with the statutory requirements, as required by §1111(h).

**[Recommendation:]{.underline}** The State may wish to use its State
Activity funds to update its data collection system to meet the
reporting requirements for the CSPR and Annual State Report Card.

**[Critical Element 1.12:]{.underline} Does the State prepare and
disseminate to the public an Annual State Report Card
(§1111(h)(1)(C)(viii))? If so, how is it disseminated?**

**[Finding:]{.underline}** Though the State prepares and disseminates an
Annual State Report Card, the State did not report the percentage of
classes not taught by HQT. Rather, the State reported the percentage of
HQT in core academic classes (see Critical Element 1.11, above). In
addition, the State did not report the percentage of teachers teaching
with emergency or provisional credentials.

**[Citation:]{.underline}** Section 1111(h)(1)(C)(viii) of the ESEA
requires each SEA to include in its Annual State Report Card data on the
percentage of classes in the State not taught (in core academic
subjects) by highly qualified teachers, in the aggregate and
disaggregate by high-poverty (as the term is defined in
§1111(h)(1)(C)(viii) of the ESEA) compared to low-poverty schools.

**[Further Action Required:]{.underline}** The MDE must report to the
public and to the Department, as required by §1111(h)(1)(C)(viii), the
percentage of classes *not* taught by highly qualified teachers at all
grade levels (and disaggregated by high- and low-poverty schools), as
required for the Annual State Report Card. The MDE must also report the
percentage of teachers with emergency or provisional credentials.

**[Area 2: Administration of ESEA Title II, Part A]{.underline}**

**[Critical Element 2.2]{.underline}: Does the SEA require an
application from each LEA before providing Title II, Part A funding? If
yes, what information does the SEA require in the LEA application
(§2122(b))?**

**[Commendation:]{.underline}** The State has created the Michigan
Electronic Grants System (MEGS), an online data collection tool that
State entities, including LEAs and the SAHE, may use for grant
applications, budget information, and application reviews. Currently,
LEAs submit their Consolidated Applications and the SAHE reviews grant
applications through this grants system.

**[Recommendation:]{.underline}** The State may wish to include
assurances pertaining to Title I and Title II, Part A Class Size
Reduction hiring in its consolidated district application.

**[Critical Element 2.9:]{.underline} Does the SEA conduct regular,
systematic reviews of LEAs to monitor for compliance with Federal
statutes and regulations, applicable State rules and policies, and the
approved subgrant application? (Please provide monitoring plan and
instruments onsite).**

**[Finding:]{.underline}** Though the State conducts LEA monitoring
reviews with a programmatic focus, it does not conduct regular,
systematic reviews of LEAs to monitor for compliance with Federal
statutes and regulations, including Title I and Title II, Part A Class
Size Reduction hiring. Moreover, due to budget constraints and staff
downsizing, the MDE does not have a comprehensive monitoring plan in
effect.

**[Citation:]{.underline}** Section 76.770 of the Education Department
General Administrative Regulations (EDGAR) requires that "Each State
shall have procedures for reviewing and approving applications for
subgrants and amendments to those applications, for providing technical
assistance, for evaluating projects, and for performing other
administrative responsibilities the State has determined are necessary
to ensure compliance with applicable statutes and regulations."
Furthermore, §80.40(a) requires that States

\"monitor grant and subgrant supported activities to assure compliance
with applicable Federal requirements and that performance goals are
being achieved.\"

**[Further Action Required:]{.underline}** The MDE must submit a written
plan with specific procedures and a timeline for conducting regular,
systematic reviews of all LEAs to ensure compliance with Federal statute
and regulations, applicable State rules and policies, and the approved
subgrant application. The MDE is encouraged to use monitoring
instruments sufficiently comprehensive to determine that subgrantees
comply with program requirements and make progress toward meeting all
objectives of their applications. Simply reviewing audit or annual
reports is not acceptable. 

**[Recommendation:]{.underline}** The State may wish to require
information on complying with Federal statutes and regulations,
including Title I and Title II, Part A Class Size Reduction hiring, in
its LEA monitoring protocol.

**[Critical Element 2.11:]{.underline} Has the SEA identified and
provided technical assistance to LEAs that are not making progress
toward meeting their annual measurable objectives in meeting the highly
qualified teacher challenge (§2141)?**

**[Finding:]{.underline}** The State has established benchmarks at the
state level only. Accordingly, the SEA has not identified LEAs that are
not making progress toward attaining their annual measurable objectives
in meeting the highly qualified teacher challenge, nor has it provided
technical assistance.

**[Citation]{.underline}:** Section 1119(a)(2)(A) of the ESEA requires
each SEA to develop a plan to ensure that all teachers teaching core
academic subjects within the State are highly qualified by the end of
the 2005-06 school year. See Critical Element 1.9 for more information.

**[Further Action Required:]{.underline}** The MDE must submit a written
plan with specific procedures and a timeline for implementing this
requirement. See Critical Element 1.9 for more information.

**[Critical Element 2.12:]{.underline} Has the SEA provided guidance to
the LEAs on initiating consultation with nonpublic school officials for
equitable services?**

**[Commendation:]{.underline}** The State should be commended for its
strong guidance on providing for equitable participation by nonpublic
schools. The State has created a *Technical Assistance Packet: Working
with Private Schools* that is specific to Title II, Part A requirements.

**[Area 4: State Agency for Higher Education (SAHE)
Activities]{.underline}**

**[Critical Element 4.1:]{.underline} Did the SAHE manage a competition
for eligible partnerships?**

**[Commendation:]{.underline}** The SAHE should be commended for moving
up its Request for Proposal dissemination, application deadline, and
pre-award notification. The additional time this allows grantees should
be beneficial in planning and budgeting for activities.

[^1]: The Department currently is requiring States to report data on
    classes taught by highly qualified teachers at the State level only.
    However we reserve the right to require this information in future
    annual State reports to

    the Secretary.