HIGHLY QUALIFIED TEACHERS AND

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

MONITORING REPORT

**Illinois State Board of Education (ISBE)**

**June 11-12, 2008**

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

Elizabeth Witt

Carrie Murthy (Westat)

**Illinois State Board of Education (ISBE):**

Melina Wright, NCLB Liaison

Bob Bigham, Educator Preparation and Recertification Division

Lynne Robinson, Accountability Division

Paul Williams, External Assurances Division

Laurel Gibler, Educator Preparation and Recertification Division

Gayle Johnson, Division Administrator, Data Analysis & Progress
Reporting

Linda Jamali, Division Administrator, Certification

Dennis Williams, Educator Preparation and Recertification Division

Gina Hopper, Division Administrator, Federal Grants & Programs

James Lucky, Budget & Fiscal Division

Kim Lewis, Funding & Disbursements Division

Lisa LaBonte, Chief Internal Auditor

Mary Morrison, Funding & Disbursements Division

Kim Beachy, Funding & Disbursements Division

**State Agency for Higher Education:**

Rich Jachino, Associate Director, Grant Administration

Debbie Meisner-Bertauski, Associate Director, Academic Affairs

Dianne C. Gardner, Ph.D., Assistant Professor, SAHE consultant from
Illinois State University

W. Paul Vogt, Ph.D., Academic Research & Texts, SAHE consultant from
Illinois State University

**LEAs participating in the monitoring visit**

1.  Chicago Public Schools (telephone interview)

2.  Waukegan Public Schools (telephone interview)

3.  Brown Public Schools (telephone interview)

Overview:

Number of LEAs 873

Number of Schools 4,228

Number of Teachers 132,000

  ----------------------- ----------------------------- ------------------------ -----------------------------
  **State Allocation (FY  **\$117,385,222**             **State Allocation (FY   **\$116,333,721**
  2005**[^1]**)**                                       2006**[^2]**)**          

  LEA Allocation (FY      [\$110,400,802]{.underline}   LEA Allocation (FY 2006) [\$109,411,864]{.underline}
  2005)                                                                          

  "State Activities" (FY  [\$2,905,284]{.underline}     "State Activities (FY    [\$2,879,260]{.underline}
  2005)                                                 2006)                    

  SAHE Allocation (FY     [\$3,050,548]{.underline}     SAHE Allocation (FY      [\$3,023,223]{.underline}
  2005)                                                 2006)                    

  SEA Administration (FY  [\$1,028,588]{.underline}     SEA Administration (FY   [\$1,019,374]{.underline}
  2005)                                                 2006)                    

  SAHE Administration (FY [\$145,264]{.underline}       SAHE Administration (FY  [\$143,963]{.underline}
  2005)                                                 2006)                    
  ----------------------- ----------------------------- ------------------------ -----------------------------

**Scope of Review:**

Like all State educational agencies (SEAs), the Illinois State Board of
Education, 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 Illinois 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.

**Summary of Monitoring Indicators**

+-----+------------------------------+-------------+------------+-----+
| St  |                              |             |            |     |
| ate |                              |             |            |     |
| Ed  |                              |             |            |     |
| uca |                              |             |            |     |
| tio |                              |             |            |     |
| nal |                              |             |            |     |
| Age |                              |             |            |     |
| ncy |                              |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| *   | **Requirement**              | *           | **Status** | **  |
| *Cr |                              | *Citation** |            | Pag |
| iti |                              |             |            | e** |
| cal |                              |             |            |     |
| Ele |                              |             |            |     |
| men |                              |             |            |     |
| t** |                              |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The State has established    | §9101(23)   | Met        | NA  |
| .1. | appropriate HQT requirements |             | Re         |     |
|     | for all teachers who teach   |             | quirements |     |
|     | core subjects.               |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The State has established    | §602(10) of | Reco       | 5   |
| .2. | appropriate HQT requirements | the IDEA    | mmendation |     |
|     | for *special* *education*    |             |            |     |
|     | *teachers who teach core     |             |            |     |
|     | academic subjects.*          |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | Teachers who are enrolled in | (34 CFR     | Met        | NA  |
| .3. | approved alternative         | 200.56      | Re         |     |
|     | certification programs AND   | (a)(2)(ii)) | quirements |     |
|     | who have already earned a    |             |            |     |
|     | bachelor's degree AND        |             |            |     |
|     | successfully demonstrated    |             |            |     |
|     | subject matter competence    |             |            |     |
|     | may be counted as highly     |             |            |     |
|     | qualified for a period of    |             |            |     |
|     | three years.                 |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that all     | §1119(a)(1) | Finding    | 5   |
| .4. | teachers hired after the     |             |            |     |
|     | first day of the 2002-2003   |             |            |     |
|     | school year to teach in      |             |            |     |
|     | Title I programs were highly |             |            |     |
|     | qualified at the time of     |             |            |     |
|     | hire.                        |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that all     | §21         | Met        | NA  |
| .5. | teachers paid with Title II, | 23(a)(2)(B) | Re         |     |
|     | Part A funds for class size  |             | quirements |     |
|     | reduction are highly         |             |            |     |
|     | qualified.                   |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that all     | §11         | Met        | NA  |
| .6. | LEAs that receive Title I    | 11(h)(6)(A) | Re         |     |
|     | funds notify parents of      |             | quirements |     |
|     | their right to request and   |             |            |     |
|     | receive information on the   |             |            |     |
|     | qualifications of their      |             |            |     |
|     | children's teachers.         |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that all     | §1111(h     | Finding    | 5   |
| .7. | schools that receive Title I | )(6)(B)(ii) |            |     |
|     | funds notify parents when    |             |            |     |
|     | their children are taught by |             |            |     |
|     | teachers who are not highly  |             |            |     |
|     | qualified.                   |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA reports annually to  | §11         | Finding    | 5   |
| I.A | the Secretary in the         | 11(h)(4)(G) |            |     |
| .1. | Consolidated Performance     |             |            |     |
|     | Report (CSPR) the number and |             |            |     |
|     | percentage of classes taught |             |            |     |
|     | by highly qualified          |             |            |     |
|     | teachers, in the aggregate   |             |            |     |
|     | and in high- and low-poverty |             |            |     |
|     | schools.                     |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has published an     | §1111(h)(   | Finding    | 6   |
| I.B | annual report card with the  | 1)(C)(viii) |            |     |
| .1. | required teacher             |             |            |     |
|     | information.                 |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has ensured that     | §11         | Met        | NA  |
| I.B | LEAs have published annual   | 11(h)(2)(B) | Re         |     |
| .2. | report cards with the        |             | quirements |     |
|     | required teacher information |             |            |     |
|     | for both the LEA and the     |             |            |     |
|     | schools it serves.           |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA ensures that each    | §2141(a)    | Finding    | 6   |
| I.A | LEA that has not met annual  | and         |            |     |
| .1. | measurable objectives for    | §2141(b)    |            |     |
|     | highly qualified teachers    |             |            |     |
|     | for two consecutive years    |             |            |     |
|     | has an improvement plan in   |             |            |     |
|     | place and that the SEA has   |             |            |     |
|     | provided technical           |             |            |     |
|     | assistance to the LEA in     |             |            |     |
|     | formulating the plan.        |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA enters into an       | §2141(c)    | Finding    | 6   |
| I.A | agreement on the use of      |             |            |     |
| .2. | funds with any LEA that has  |             | Reco       |     |
|     | not made progress toward     |             | mmendation |     |
|     | meeting its annual           |             |            |     |
|     | measurable objectives in     |             |            |     |
|     | meeting the highly qualified |             |            |     |
|     | teacher challenge for three  |             |            |     |
|     | consecutive years and has    |             |            |     |
|     | also failed to make AYP for  |             |            |     |
|     | three years.                 |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA has a plan in place  | §11         | Finding    | 7   |
| I.B | to ensure that poor and      | 11(b)(8)(C) |            |     |
| .1. | minority students are not    |             | Reco       |     |
|     | taught at higher rates than  |             | mmendation |     |
|     | other students by            |             |            |     |
|     | inexperience, unqualified,   |             |            |     |
|     | or out-of-field teachers.    |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA ensures that LEA     | §11         | Reco       | 7   |
| I.B | plans include an assurance   | 12(c)(1)(L) | mmendation |     |
| .2. | that through the             |             |            |     |
|     | implementation of various    |             |            |     |
|     | strategies, poor and         |             |            |     |
|     | minority students are not    |             |            |     |
|     | taught at higher rates than  |             |            |     |
|     | other students by            |             |            |     |
|     | inexperienced, unqualified,  |             |            |     |
|     | or out-of-field teachers.    |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | Once hold harmless           | §2121(a)    | Met        | NA  |
| V.A | provisions are taken into    |             | Re         |     |
| .1. | consideration, the SEA       |             | quirements |     |
|     | allocated additional funds   |             |            |     |
|     | to LEAs using the most       |             |            |     |
|     | recent Census Bureau data    |             |            |     |
|     | found at                     |             |            |     |
|     | <http://www.census.gov/hh    |             |            |     |
|     | es/www/saipe/district.html>. |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has ensured that     | §2122(c)    | Met        | NA  |
| V.A | LEAs have completed          |             | Re         |     |
| .2. | assessments of local needs   |             | quirements |     |
|     | for professional             |             |            |     |
|     | development.                 |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | To be eligible for Title II, | §2122(b)    | Met        | NA  |
| V.A | Part A funds, LEAs must      |             | Re         |     |
| .3. | "submit an application to    |             | quirements |     |
|     | the State educational agency |             |            |     |
|     | at such time, in such        |             |            |     |
|     | manner, and containing such  |             |            |     |
|     | information as the State     |             |            |     |
|     | educational agency may       |             |            |     |
|     | reasonably require."         |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has ensured that     | §9521       | Met        | NA  |
| V.B | LEAs maintain effort.        |             | Re         |     |
| .1. |                              |             | quirements |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that LEA     | §2123(b)    | Met        | NA  |
| V.B | funds do not supplant other, |             | Re         |     |
| .2. | non-Federal funds.           |             | quirements |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA and LEAs are         | EDGAR       | Met        | NA  |
| V.B | audited, as required by      | §80.26      | Re         |     |
| .3. | EDGAR §80.26.                |             | quirements |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA regularly and        | EDGAR       | Reco       | 8   |
| V.B | systematically monitors LEAs | §76.770 and | mmendation |     |
| .4. | for compliance with Federal  | §80.40(a)   |            |     |
|     | statutes and regulations,    |             |            |     |
|     | applicable State rules and   |             |            |     |
|     | policies, and the approved   |             |            |     |
|     | sub grantee application, as  |             |            |     |
|     | required by EDGAR §76.770    |             |            |     |
|     | and §80.40(a).               |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that LEAs    | §9501       | Met        | NA  |
| V.B | comply with requirements     |             | Re         |     |
| .5. | with regards to services to  |             | quirements |     |
|     | eligible nonpublic schools.  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| V   | The SEA ensures that state   | §2113(c)    | Met        | NA  |
| .1. | level activity funds are     |             | Re         |     |
|     | expended on allowable        |             | quirements |     |
|     | activities.                  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| V   | The SEA ensures that state   | §2113(f)    | Met        | NA  |
| .2. | level activity funds do not  |             | Re         |     |
|     | supplant other, non-Federal  |             | quirements |     |
|     | funds.                       |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| *   |                              |             |            |     |
| *St |                              |             |            |     |
| ate |                              |             |            |     |
| Age |                              |             |            |     |
| ncy |                              |             |            |     |
| for |                              |             |            |     |
| Hig |                              |             |            |     |
| her |                              |             |            |     |
| Ed  |                              |             |            |     |
| uca |                              |             |            |     |
| tio |                              |             |            |     |
| n** |                              |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| *   | **Requirement**              | *           | **Status** | **  |
| *Cr |                              | *Citation** |            | Pag |
| iti |                              |             |            | e** |
| cal |                              |             |            |     |
| Ele |                              |             |            |     |
| men |                              |             |            |     |
| t** |                              |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 1\. | The SAHE manages a           | §2132 and   | Met        | NA  |
|     | competition to award grants  | §2133       | Re         |     |
|     | to carry out appropriate     |             | quirements |     |
|     | professional development     |             |            |     |
|     | activities.                  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 2\. | The SAHE works in            | §2132(a)    | Met        | NA  |
|     | conjunction with the SEA (if |             | Re         |     |
|     | the two are separate         |             | quirements |     |
|     | agencies) in awarding the    |             |            |     |
|     | grants.                      |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 3\. | The SAHE awards grants only  | §2131       | Met        | NA  |
|     | to eligible partnerships     |             | Re         |     |
|     | that include at least an     |             | quirements |     |
|     | 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.               |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 4\. | The SAHE ensures that each   | §2134       | Finding    | 8   |
|     | partnership awarded a grant  |             |            |     |
|     | engages in eligible          |             |            |     |
|     | activities.                  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 5\. | The SAHE has procedures in   | §2132(c)    | Met        | NA  |
|     | place to ensure that no      |             | Re         |     |
|     | partner uses more than 50    |             | quirements |     |
|     | percent of the funds in the  |             |            |     |
|     | grant.                       |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 6\. | The SAHE regularly and       | EDGAR       | Com        | 8   |
|     | systematically monitors      | §76.770 and | mendations |     |
|     | grantees for compliance with | §80.40(a)   |            |     |
|     | Federal statutes and         |             |            |     |
|     | regulations, applicable      |             |            |     |
|     | State rules and policies,    |             |            |     |
|     | and the approved sub grantee |             |            |     |
|     | application, as required by  |             |            |     |
|     | EDGAR §76.770 and §80.40(a)  |             |            |     |
+-----+------------------------------+-------------+------------+-----+

**Area I: HQT Definitions and Procedures**

**[Critical Element I.2]{.underline}: The State has established
appropriate HQT requirements for *special* *education* *teachers who
teach core academic subjects.***

**[Citation]{.underline}:** §602(10) of the *IDEA*

**[Recommendation]{.underline}:** The State data collection systems
cannot distinguish between special education teachers who teach students
assessed at grade level and those who teach exclusively students who are
assessed to alternate standards. As the State revises its data
collection system to collect accurate classroom-level data (see II.A.1
and II.B.1, below), it should ensure that the revised data system can
collect these special education data in order to ensure that all
teachers have subject-matter competency at the appropriate level.

**[Critical Element I.4]{.underline}: The SEA ensures that all teachers
hired after the first day of the 2002-2003 school year to teach in Title
I programs were highly qualified at the time of hire.**

**[Citation]{.underline}:** §1119(a)(1)

**[Finding]{.underline}:** The State cannot ensure that all teachers
hired by LEAs after the first day of the 2002-03 school year to teach in
Title I programs were highly qualified at the time of hire. Two of the
three LEAs interviewed indicated that they had hired teachers who were
not highly qualified for Title I positions.

**[Further Action Required]{.underline}:** Within 30 business days, the
State must submit to the Department a written plan with specific
procedures and a timeline the State will implement to ensure that all
teachers paid with Title I funds are highly qualified. Also, the State
must provide the Department with evidence that it is taking these
corrective actions.

**[Critical Element I.7]{.underline}: The SEA ensures that all schools
that receive Title I funds notify parents when their children are taught
by teachers who are not highly qualified.**

**[Citation]{.underline}:** §1111(h)(6)(B)(ii)

**[Finding]{.underline}:** Because the State is not collecting verified
classroom-level HQT data, as discussed below, the State cannot ensure
that all schools receiving Title I funds notified parents when their
children were being taught for four or more consecutive weeks by
teachers who were not highly qualified.

[Further Action Required]{.underline}: Within 30 business days, the
State must submit to the Department a plan and a timeline for ensuring
that Title I schools send out the required letters in the upcoming
school year, and beyond.

**Area II: HQT Data Reporting and Verification**

**[Critical Element II.A.1]{.underline}: The SEA reports annually to the
Secretary in the Consolidated Performance Report (CSPR) the number and
percentage of classes taught by highly qualified teachers, in the
aggregate and in high- and low-poverty schools.**

**[Citation]{.underline}:** §1111(h)(4)(G)

**[Finding]{.underline}:** The State is not reporting accurate HQT data
in the Consolidated State Performance Report (CSPR). The State collects
self-reported HQT data in one data collection and assignment-level data
in another. Because the HQT data are self-reported and not verified by
the State, and because the two data systems are not collaborative, the
State cannot report accurate classroom-level HQT data.

**[Further Action Required]{.underline}:** To correct data errors in the
CSPR, the State must, within 30 business days, provide the Department
with a plan and timeline for correcting its HQT data reporting system.
If the State is able to submit correct data for the 2007-08 in the
December 2008 CSPR, it should do so. If the data system cannot be
corrected before December 2008, the State's submitted plan and timeline
must provide an assurance that the data submitted for the 2008-09 school
year in the December 2009 CSPR will be accurate.

**[Critical Element II.B.1]{.underline}: The SEA has published an annual
report card with the required teacher information.**

**[Citation]{.underline}:** §1111(h)(1)(C)(viii)

**[Finding]{.underline}:** The State is not reporting accurate HQT data
in its Annual Report Cards. The State collects self-reported HQT data in
one data collection and assignment-level data in another. Because the
self-reported HQT data are not verified by the State, and because the
two data systems are not collaborative, the State cannot report accurate
classroom-level HQT data.

**[Further Action Required]{.underline}:** To correct data errors in its
Annual Report Card, the State must, within 30 business days, provide the
Department with a plan and timeline for correcting its HQT data
reporting system. If the State is able to include correct data for the
2007-08 in its next Annual Report Card, it should do so. If the data
system cannot be corrected in time to correct the next Annual Report
Card, the State's submitted plan and timeline must provide an assurance
that the data included in the 2008-09 Annual Report Card will be
accurate.

**Area III: HQT Plans**

**[Critical Element III.A.1]{.underline}: The SEA ensures that each LEA
that has not met annual measurable objectives for highly qualified
teachers for two consecutive years has an improvement plan in place and
that the SEA has provided technical assistance to the LEA in formulating
the plan.**

**[Citation]{.underline}:** §2141(a) and §2141(b)

**[Finding]{.underline}:** Because the State is not collecting verified
classroom-level HQT data, it cannot accurately determine whether each
LEA has met annual measurable goals for highly qualified teachers for
two consecutive years. Therefore, the State cannot meet the requirements
for §2141(a) and §2141(b).

**[Further Action Required]{.underline}:** Within 30 days, the State
must provide a written plan and a timeline for correctly identifying
which LEAs have not met annual measurable objectives for two consecutive
years. The State must also provide a plan and a timeline for ensuring
that any identified LEAs have the required improvement plan in place.
The plan submitted by the State must also describe how the SEA will
provide technical assistance to the LEAs in formulating and implementing
their required plans.

[]{.mark}

**[Critical Element III.A.2]{.underline}: The SEA enters into an
agreement on the use of funds with any LEA that has not made progress
toward meeting its annual measurable objectives in meeting the highly
qualified teacher challenge for three consecutive years and has also
failed to make AYP for three years.**

**[Citation]{.underline}:** §2141(c)

**[Finding]{.underline}:** Because the State is not collecting verified
classroom-level HQT data, it cannot accurately determine whether each
LEA has met annual measurable goals for highly qualified teachers for
three consecutive years. Therefore, the State cannot meet the
requirements for §2141(c). The unverified data that are currently
available indicate that there are LEAs that have not met their annual
measurable objectives for HQT for three consecutive years and that have
also failed to make AYP for three years. The State has not entered into
agreements with these LEAs.

**[Further Action Required]{.underline}:** Within 30 days, the State
must provide a written plan and a timeline for correctly identifying any
LEAs that currently have not met their HQT annual measurable objectives
for three consecutive years and have also failed to make AYP for three
years. In addition to providing a list of identified LEAs, the State
must also provide a plan and a timeline for ensuring that the SEA enters
into the required agreements on the use of funds with all of the
identified LEAs.

**[Recommendation]{.underline}:** The State should create written policy
concerning the requirements of §2141, including what the agreements
cover, the tracking of data and the notification of LEAs. In addition,
the State should provide technical assistance to all LEAs in
understanding both the requirements and the consequences associated with
the statute. The State should provide written guidance and technical
assistance as soon as possible.

**[Critical Element III.B.1]{.underline}: The SEA has a plan in place to
ensure that poor and minority students are not taught at higher rates
than other students by inexperienced, unqualified or out-of-field
teachers.**

**[Citation]{.underline}:** §1111(b)(8)(C)

**[Finding]{.underline}:** Though the State has a plan in place to
ensure that poor and minority students are not taught at higher rates
than other students by inexperienced, unqualified or out-of-field
teachers, the State is not measuring progress on the plan or reporting
on the plan.

**[Further Action Required]{.underline}:** Within 30 business days, the
State must provide the Department with a plan with specific procedures
and a timeline that the State will implement to ensure that it will
monitor and publicly report on its progress in carrying out its 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. The State must also provide the Department with evidence that
it is taking this corrective action.

**[Recommendation]{.underline}:** The State should continue to update
officially, on a regular basis, its plan to ensure that poor and
minority students are not taught at higher rates than other students by
inexperienced, unqualified or out-of-field teachers on a regular basis.
The State should ensure that it updates both its data and its strategies
to reflect needs evidenced by the data. This will ensure that LEAs and
the public have access to the most current information.

**[Critical Element III.B.2]{.underline}: The SEA ensures that LEA plans
include an assurance that through the implementation of various
strategies, poor and minority students are not taught at higher rates
than other students by inexperienced, unqualified, or out-of-field
teachers.**

**[Citation]{.underline}:** §1112(c)(1)(L)

**[Recommendation]{.underline}:** The State should urge LEAs to revisit
and update their plans to ensure that poor and minority students are not
taught at higher rates than other students by inexperienced, unqualified
or out-of-field teachers on a regular basis. The State should urge LEAs
to update both their data and their strategies to reflect needs
evidenced by the data, especially in LEAS that are large enough where
alternative distribution of teachers is a possibility.

**Area IV: Administration of Title II, Part A**

**[Critical Element IV.B.4]{.underline}: The SEA regularly and
systematically monitors LEAs for compliance with Federal statutes and
regulations, applicable State rules and policies and the approved
sub-grantee application, as required by *EDGAR* §76.770 and §80.40(a).**

**[Citation]{.underline}:** *EDGAR* §76.770 and §80.40(a)

**[Recommendation]{.underline}:** The State currently monitors LEAs
through several different departments, but the various monitoring
efforts and departments do not cohere and monitoring efforts are not
unified. The State's program offices should work together to develop a
comprehensive, coherent monitoring system that includes a plan for
collaborative site visits and desk monitoring. The plan should include
random monitoring of a certain number of LEAs and regular monitoring of
all LEAs, especially those that receive large amounts of Title II, Part
A funding and/or have persistent issues with hiring highly qualified
teachers.

**State Agency for Higher Education**

**[Critical Element 4]{.underline}: The SAHE ensures that each
partnership awarded a grant engages in eligible activities.**

**[Citation]{.underline}:** §2134

**[Finding]{.underline}:** The SAHE has awarded grants to partnerships
that provided services to pre-service teachers. Pre-service teachers are
not eligible to use Title II, Part A funds.

**[Further Action Required]{.underline}:** On June 24, 2008, subsequent
to the monitoring visit, the SAHE director sent to the Department
information indicating which grantees had served pre-service teachers,
as well as assurances from those grantees that no further services to
pre-service teachers would be provided with program funds. The SAHE has
also provided assurances that grants awarded in the future will not
serve pre-service teachers. No further action is required.

**[Critical Element 6]{.underline}: The SAHE regularly and
systematically monitors grantees for compliance with Federal statutes
and regulations, applicable State rules and policies, and the approved
sub grantee application, as required by EDGAR §76.770 and §80.40(a).**

**[Citation]{.underline}:** *EDGAR* §76.770 and §80.40(a)

**[Commendation 1]{.underline}:** The SAHE is commended for its
structured monitoring efforts that focus on reviewing outcomes rather
than outputs.

**[Commendation 2]{.underline}:** The SAHE is commended for its
sophisticated program evaluation plan. The SAHE is focused on improving
effectiveness, not just on compliance.

[^1]: FY 2005 funds are those that became available to the State on July
    1, 2005.

[^2]: FY 2006 funds are those that became available to the State on July
    1, 2006.