June 1, 2006

HIGHLY QUALIFIED TEACHERS AND

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

MONITORING REPORT

**Massachusetts Department of Education**

**April 25-27, 2006**

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

Julie Coplin

Robert Stonehill

Darcy Pietryka (Westat)

**Massachusetts Department of Education (MA DOE):**

Robert Bickerton, Associate Commissioner, Center for Lifelong Learning
and Teaching

Carol Gilbert, Executive Director, Office of Educator Preparation and
Quality

Holly Shaughnessy, Assistant Director, Office of Educator Preparation
and Quality

Cathy Depradine, Program Coordinator, Title II, Part A

Simone Lynch, Teacher Quality Team Leader

David LeBlanc, Certified Government Financial Manager, Director of Audit
& Compliance

Ron Honesty, Administrator, Grants Management

Helene Bettencourt, Supervisor of Data Collection

**State Agency for Higher Education:**

E. Molly Laden

**Overview of Massachusetts:**

Number of Districts: 386

Number of Schools: 1,872

Number of Teachers: 73,394

### Allocations:

State Allocation (FY 2004[^1]) [\$51,935,737]{.underline} State
Allocation (FY 2005) [\$51,823,064]{.underline}

LEA Allocation (FY 2004) [\$48,845,560]{.underline} LEA Allocation (FY
2005) [\$48,739,592]{.underline}

"State Activities" (FY 2004) [\$1,285,410]{.underline} "State
Activities" (FY 2005) [\$1,282,621]{.underline}

SAHE Allocation (FY 2004) [\$1,285,410]{.underline} SAHE Allocation (FY
2005) [\$1,282,621]{.underline}

SEA Administration (FY 2004) [\$453,342]{.underline} SEA Administration
(FY 2005) [\$452,215]{.underline}

SAHE Administration (FY 2004) [\$66,015]{.underline} SAHE Administration
(FY 2005) [\$66,015]{.underline}

**Scope of Review:**

Like all State educational agencies (SEAs), the Massachusetts Department
of Education (MA DOE), 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 Massachusetts 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 April 25-27, 2006, at the
offices of the MA DOE. In addition to meeting with the MA DOE staff
noted above, as part of the review, the Department monitoring team met
with E. Molly Laden, SAHE Coordinator. The monitoring team met with
representatives of the Boston Public Schools and conducted conference
calls with representatives of the Somerset Public Schools and Shrewsbury
Public Schools.

#### Summary of Monitoring Indicators

+----------+-------------------------------+----------------+--------+
| # Mo     |                               |                |        |
| nitoring |                               |                |        |
|  Area 1: |                               |                |        |
|  Highly  |                               |                |        |
| Qualifie |                               |                |        |
| d Teache |                               |                |        |
| r System |                               |                |        |
| s and Pr |                               |                |        |
| ocedures |                               |                |        |
+----------+-------------------------------+----------------+--------+
| *        | **Description**               | # Status       | # Page |
| *Element |                               |                |        |
| Number** |                               |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Has the State developed and   | Recommendation | 7      |
| Element  | implemented procedures,       |                |        |
| 1.1      | consistent with the statutory | Commendation   |        |
|          | 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  | Met            | NA     |
| Element  | who are not new to the        | Requirements   |        |
| 1.4      | 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))?               |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Are all veteran middle and    | Finding        | 8      |
| 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 | For each set of HOUSSE        | Commendation   | 8      |
| Element  | procedures the State has      |                |        |
| 1.6      | developed, please describe    |                |        |
|          | how it meets each of the      |                |        |
|          | statutory requirements of     |                |        |
|          | §9101(23)(C)(ii).             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | How does the SEA ensure that, | Met            | NA     |
| Element  | since the beginning of the    | Requirements   |        |
| 1.7      | 2002-03 school year,          |                |        |
|          | districts hire only highly    |                |        |
|          | qualified teachers (including |                |        |
|          | special education teachers,   |                |        |
|          | as appropriate) to teach in   |                |        |
|          | Title I programs?             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | How has the SEA ensured,      | Met            | NA     |
| Element  | since the beginning of the    | Requirements   |        |
| 1.8      | 2002-03 school year, that     |                |        |
|          | 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 | Met            | NA     |
| Element  | annual measurable objectives  | Requirements   |        |
| 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 | 8      |
| 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        | 9      |
| Element  | Secretary in its Consolidated |                |        |
| 1.11     | 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))?  |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Does the State prepare and    | Finding        | 9      |
| 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 Requirements | NA   |
| Element  | according to the statute,      |                  |      |
| 2.1      | using the most recent Census   |                  |      |
|          | Bureau data as described in    |                  |      |
|          | the Non-Regulatory Guidance    |                  |      |
|          | (§2121(a))?                    |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | Does the SEA require an        | Met Requirements | NA   |
| Element  | application from each LEA      |                  |      |
| 2.2      | before providing Title II,     |                  |      |
|          | Part A funding? If yes, what   |                  |      |
|          | information does the SEA       |                  |      |
|          | require in the LEA application |                  |      |
|          | (§2122(b))?                    |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | In particular, does the SEA    | Met Requirements | NA   |
| Element  | require each LEA to describe   |                  |      |
| 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 procedure  | Met Requirements | NA   |
| Element  | to determine the amount of     |                  |      |
| 2.4      | funds each LEA expended during |                  |      |
|          | the period of availability?    |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | Does the SEA have a procedure  | Met Requirements | NA   |
| Element  | to regularly review the        |                  |      |
| 2.5      | drawdowns of the LEAs?         |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | Does the SEA have a written    | Met Requirements | NA   |
| Element  | policy on allowable carryover  |                  |      |
| 2.6      | funds?                         |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | If an LEA cannot obligate      | Met Requirements | NA   |
| Element  | funds within the 27 months of  |                  |      |
| 2.7      | 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 Requirements | NA   |
| Element  | show that each LEA meets the   |                  |      |
| 2.8      | maintenance of effort          |                  |      |
|          | requirements?                  |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | Does the SEA conduct regular,  | Recommendation   | 10   |
| Element  | systematic reviews of LEAs to  |                  |      |
| 2.9      | monitor for compliance with    |                  |      |
|          | Federal statutes and           |                  |      |
|          | regulations, applicable State  |                  |      |
|          | rules and policies, and the    |                  |      |
|          | approved subgrant application? |                  |      |
+----------+--------------------------------+------------------+------+
| Critical | Does the SEA ensure that it    | Met Requirements | NA   |
| Element  | and its component LEAs are     |                  |      |
| 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          | 10   |
| Element  | provided technical assistance  |                  |      |
| 2.11     | 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 guidance  | Met Requirements | NA   |
| Element  | to the LEAs on initiating      |                  |      |
| 2.12     | consultation with nonpublic    |                  |      |
|          | school officials for equitable |                  |      |
|          | services?                      |                  |      |
+----------+--------------------------------+------------------+------+

+---------+---------------------------------+------------------+------+
| #       |                                 |                  |      |
| Monitor |                                 |                  |      |
| ing Are |                                 |                  |      |
| a 3: St |                                 |                  |      |
| ate Act |                                 |                  |      |
| ivities |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| **      | # Description                   | ### Status       | ##   |
| Element |                                 |                  | Page |
| N       |                                 |                  |      |
| umber** |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the State use its State    | Commendation     | 10   |
| 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           | Finding          | 11   |
| 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 and
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 currently issues two
one-year emergency permits under the names of "Hardship waiver" and
"Temporary waiver." All teachers holding these waivers are appropriately
counted as non-highly qualified. Though the State correctly designates
the HQT status of teachers holding the emergency permits, and though the
emergency permits are not widely used, the State should continue to
eliminate its dependency on the one-year waivers to meet shortages. By
the end of the 2005-06 academic year, all teachers of core academic
subjects must meet the definition of highly qualified, which includes
holding full State certification.

**[Commendation:]{.underline}** The State should be commended for the
comprehensive alignment, pre-K-16, of its curriculum frameworks,
standards and certification requirements. The State re-vamped its
curriculum frameworks and then ensured alignment with its teacher
preparation program standards and its student content standards. The
result is a teacher training system that ensures that prospective
teachers know and are well prepared to teach to the content standards.

**[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}** At the secondary school level, the state
offers two license areas for new social studies teachers: history and
political science/political philosophy. To be granted a license in
either area, teachers must pass an assessment. Though the state
maintains that the assessments cover all four areas required by statute,
the assessments may not provide adequate subject-matter preparation for
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 MA DOE 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. (In doing
so, if the MA DOE has determined that the assessments adequately
represents all four content areas, it also will need to specifically
explain the basis for its determination.)

**[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}** At the secondary school level, the state
offers two license areas for veteran social studies teachers: history
and political science/political philosophy. To be granted a license in
either area, teachers must pass an assessment. Though the state
maintains that the assessments cover all four areas required by statute,
the assessments may not provide adequate subject-matter preparation for
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 MA DOE 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. (In doing
so, if MA DOE has determined that the assessments adequately represent
all four content areas, it also will need to specifically explain the
basis for its determination.)

**[Critical Element 1.6:]{.underline} For each set of HOUSSE procedures
the State has developed, please describe how it meets each of the
statutory requirements in §9101(23)(C)(ii).**

**[Commendation:]{.underline}** The State's HOUSSE procedures are an
individual professional development plan tied to content-area
professional development, certification renewal, State standards and
both the school and district improvement plans.

**[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/or 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 is engaged in many
activities to ensure that poor and minority children are not taught at
higher rates than other children by inexperienced, unqualified and/or
out-of-field teachers, the monitoring team recommends that the State
create a comprehensive plan to unify and centralize efforts while
controlling for 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's HQT definitions are in
compliance with statute (with the possible exception of social studies
teachers), the State has issued Guidance allowing HQT designation to
veteran elementary school teachers who have completed 50 percent or more
of their HOUSSE requirements. Thus, the State's HQT data are potentially
over-reported on the CSPR. However, because the State has aligned its
HOUSSE requirements with its five-year re-certification requirements and
has required content-area assessments for licensure since 1998, the
instances of over-reporting, if any, are relatively insignificant. All
teachers in this subset will complete 100 percent of their HOUSSE
requirements by the end of the 2005-06 school year.

**[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[^2]
(a summary of which §1111(h)(5) requires the Secretary annually to
report to Congress).

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

**[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}** As noted in Critical Element 1.11, though the
State's HQT definitions are in compliance with statute (with the
possible exception of social studies teachers), the State issued
Guidance allowing HQT designation to veteran elementary teachers who
have completed 50 percent or more of their HOUSSE requirements. Thus,
the State's HQT data are potentially over-reported on the SEA annual
report cards. The instances of over-reporting, if any, are relatively
insignificant. All teachers in this subset will complete 100 percent of
their HOUSSE requirements by the end of the 2005-06 school year.

In addition, the State reports the percentage of classes taught by HQT
rather than the inverse and does not include professional qualifications
or the percentage of teachers teaching with emergency or provisional
credentials on its Annual State Report Card.

**[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 MA DOE 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. Other required data must also
be reported. In addition, HQT data must be included in school report
cards.

##### Area 2: Administration of ESEA Title II, Part A

**[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?**

**[Recommendation:]{.underline}** Though the State monitors its
districts for compliance with federal statutes and regulations, the
State should create a comprehensive monitoring plan to ensure that all
districts are monitored in a thorough and timely manor.

**[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}** Though the State set annual measurable
objectives for each LEA in the State to monitor progress in meeting the
HQT deadline, it has not identified and provided technical assistance to
LEAs to enable them to meet 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.

**[Further Action Required:]{.underline}** The State must submit a
written plan with specific procedures and a timeline for implementing
this requirement.

##### Area 3: State Activities

**[Critical Element 3.1:]{.underline} Does the State use its State
Activities funds to promote the recruitment, hiring, training, and
retention of highly qualified teachers and principals?**

**[Commendation:]{.underline}** The State has created an infrastructure
for the creation of alternative routes sponsored by groups that include
districts, charter schools, institutions of higher education and
not-for-profit organizations. This infrastructure creates a mechanism by
which local agencies may create "grow-your-own" teacher preparation
programs to address specific local needs while adhering to all State
standards.

##### Area 4: State Agency for Higher Education (SAHE) Activities

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

**[Finding:]{.underline}** The SAHE must ensure that eligible
partnerships serve only highly qualified paraprofessionals; though no
projects currently serve non-highly qualified paraprofessionals, past
grants did provide services to paraprofessionals seeking to become
highly qualified. The SAHE must ensure that future eligible partnerships
serve only highly qualified paraprofessionals.

**[Citation:]{.underline}** Section 2134(a)(1)(A) of the ESEA allows
that an eligible partnership may use the subgrant funds for professional
development activities in core academic subjects to serve
paraprofessionals only if they are highly qualified.

**[Further Action Required:]{.underline}** For the next round of
allocations to eligible partnerships, the SAHE must ensure that all
partnerships serve only highly qualified paraprofessionals.

[^1]: FY 2004 funds are those that became available to the State on July
    1, 2004.

[^2]: 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.