HIGHLY QUALIFIED TEACHERS AND

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

MONITORING REPORT

**Delaware Department of Education**

**January 29-31, 2008**

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

Julie Coplin

Carol Manitaras

Stacey Spivey-Blackford

Elizabeth Dabney (Westat)

**Delaware Department of Education (DDOE):**

Amelia E. Hodges, Program Manager for Title II, Part A and Professional
Development and SAHE Coordinator

Wayne A. Barton, Director, Professional Accountability

Patricia Bigelow, Education Associate, Professional Accountability

Martha Brooks, Associate Secretary, Curriculum & Instructional
Improvement Branch

John H. Hulse, Education Associate, School Improvement

Tammy Korosec, Program Manager for Business and Finance---Federal

Mary Ellen Kotz, Education Associate, Professional Accountability

Adrian L. Peoples, DDOE Technology

LEAs participating in the monitoring visit

1.  Red Clay Consolidated School District (on-site visit)

2.  Colonial School District (telephone interview)

3.  Thomas A. Edison Charter School of Wilmington (telephone interview)

**Overview:**

Number of LEAs: 19

Number of Schools: 200

Number of Teachers: 7,938

Funding:

  ----------------------- -------------------------------- -- ----------------------- --------------------------------
  **State Allocation (FY  **[\$13,895,209]{.underline}**      **State Allocation (FY  **[\$13,751,559]{.underline}**
  2005**[^1]**)**                                             2006**[^2]**)**         

  LEA Allocation (FY      [\$13,068,445]{.underline}          LEA Allocation (FY      [\$12,933,342]{.underline}
  2005)                                                       2006)                   

  "State Activities" (FY  [\$343,906]{.underline}             "State Activities" (FY  [\$340,351]{.underline}
  2005)                                                       2006)                   

  SAHE Allocation (FY     [\$361,297]{.underline}             SAHE Allocation (FY     [\$340,351]{.underline}
  2005)                                                       2006)                   

  SEA Administration (FY  [\$121,561]{.underline}             SEA Administration (FY  [\$120,124]{.underline}
  2005)                                                       2006)                   

  SAHE Administration (FY [\$17,391]{.underline}              SAHE Administration (FY [\$17,391]{.underline}
  2005)                                                       2006)                   
  ----------------------- -------------------------------- -- ----------------------- --------------------------------

**Scope of Review:**

Like all State educational agencies (SEAs), the Delaware Department of
Education (DDOE), 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 Delaware had two purposes. One was
to review the progress of the State in meeting *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 |                            |                |            |    |
| Ag  |                            |                |            |    |
| enc |                            |                |            |    |
| y** |                            |                |            |    |
+=====+============================+================+============+====+
| *   | **Requirement**            | **Citation**   | **Status** | ** |
| *Cr |                            |                |            | Pa |
| iti |                            |                |            | ge |
| cal |                            |                |            | ** |
| Ele |                            |                |            |    |
| men |                            |                |            |    |
| t** |                            |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The State has established  | §9101(23)      | Co         | 6  |
| .1. | appropriate HQT            |                | mmendation |    |
|     | requirements for all       |                |            |    |
|     | teachers who teach core    |                | Recom      |    |
|     | subjects.                  |                | mendations |    |
+-----+----------------------------+----------------+------------+----+
| I   | The State has established  | §602(10) of    | Met        | NA |
| .2. | appropriate HQT            | the *IDEA*     | R          |    |
|     | requirements for *special* |                | equirement |    |
|     | *education* *teachers who  |                |            |    |
|     | teach core academic        |                |            |    |
|     | subjects.*                 |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | Teachers who are enrolled  | (34 CFR        | Met        | NA |
| .3. | in approved alternative    | 200            | R          |    |
|     | certification programs AND | .56(a)(2)(ii)) | equirement |    |
|     | who have already earned a  |                |            |    |
|     | bachelor's degree AND      |                |            |    |
|     | successfully demonstrated  |                |            |    |
|     | subject matter competence  |                |            |    |
|     | may be counted as highly   |                |            |    |
|     | qualified for a period of  |                |            |    |
|     | 3 years.                   |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA ensures that all   | §1119(a)(1)    | Finding    | 6  |
| .4. | teachers hired after the   |                |            |    |
|     | first day of the 2002-03   |                |            |    |
|     | school year to teach in    |                |            |    |
|     | Title I programs were      |                |            |    |
|     | highly qualified at the    |                |            |    |
|     | time of hire.              |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA ensures that all   | §2123(a)(2)(B) | Finding    | 7  |
| .5. | teachers paid with Title   |                |            |    |
|     | II, Part A funds for class |                |            |    |
|     | size reduction are highly  |                |            |    |
|     | qualified.                 |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA ensures that all   | §1111(h)(6)(A) | Met        | NA |
| .6. | LEAs that receive Title I  |                | R          |    |
|     | funds notify parents of    |                | equirement |    |
|     | their right to request and |                |            |    |
|     | receive information on the |                |            |    |
|     | qualifications of their    |                |            |    |
|     | children's teachers.       |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA ensures that all   | §111           | Met        | NA |
| .7. | schools that receive Title | 1(h)(6)(B)(ii) | R          |    |
|     | I funds notify parents     |                | equirement |    |
|     | when their children are    |                |            |    |
|     | taught by teachers who are |                |            |    |
|     | not highly qualified.      |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA reports annually   | §1111(h)(4)(G) | Met        | NA |
| I.A | to the Secretary in the    |                | R          |    |
| .1. | Consolidated State         |                | equirement |    |
|     | 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(         | Finding    | 7  |
| I.B | annual report card with    | h)(1)(C)(viii) |            |    |
| .1. | the required teacher       |                |            |    |
|     | information.               |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA has ensured that   | §1111(h)(2)(B) | Met        | NA |
| I.B | LEAs have published annual |                | R          |    |
| .2. | report cards with the      |                | equirement |    |
|     | required teacher           |                |            |    |
|     | information for both the   |                |            |    |
|     | LEA and the schools it     |                |            |    |
|     | serves.                    |                |            |    |
+-----+----------------------------+----------------+------------+----+
| II  | The SEA ensures that each  | §2141(a) and   | Met        | NA |
| I.A | LEA that has not met       | §2141(b)       | R          |    |
| .1. | annual measurable          |                | equirement |    |
|     | 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.      |                |            |    |
+-----+----------------------------+----------------+------------+----+
| II  | The SEA enters into an     | §2141(c)       | Reco       | 7  |
| I.A | agreement on the use of    |                | mmendation |    |
| .2. | 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.           |                |            |    |
+-----+----------------------------+----------------+------------+----+
| II  | The SEA has a plan in      | §1111(b)(8)(C) | Met        | NA |
| I.B | place to ensure that poor  |                | R          |    |
| .1. | and minority students are  |                | equirement |    |
|     | not taught at higher rates |                |            |    |
|     | than other students by     |                |            |    |
|     | inexperienced, unqualified |                |            |    |
|     | or out-of-field teachers.  |                |            |    |
+-----+----------------------------+----------------+------------+----+
| II  | The SEA ensures that LEA   | §1112(c)(1)(L) | Met        | NA |
| I.B | plans include an assurance |                | R          |    |
| .2. | that through the           |                | equirement |    |
|     | 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  |                | R          |    |
| .1. | consideration, the SEA     |                | equirement |    |
|     | allocated additional funds |                |            |    |
|     | to LEAs using the most     |                |            |    |
|     | recent Census Bureau data  |                |            |    |
|     | found at [http**:**        |                |            |    |
|     | //www.c                    |                |            |    |
|     | ensus.gov/hhes/www/saipe/\ |                |            |    |
|     | district.html](            |                |            |    |
|     | http://www.census.gov/hhes |                |            |    |
|     | /www/saipe/district.html). |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA has ensured that   | §2122(c)       | Met        | NA |
| V.A | LEAs have completed        |                | R          |    |
| .2. | assessments of local needs |                | equirement |    |
|     | for professional           |                |            |    |
|     | development.               |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | To be eligible for Title   | §2122(b)       | Met        | NA |
| V.A | II, Part A funds, LEAs     |                | R          |    |
| .3. | must "submit an            |                | equirement |    |
|     | application to 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.      |                | R          |    |
| .1. |                            |                | equirement |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA ensures that LEA   | §2123(b)       | Finding    | 8  |
| V.B | funds do not supplant      |                |            |    |
| .2. | other, non-Federal funds.  |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA and LEAs are       | EDGAR §80.26   | Met        | NA |
| V.B | audited, as required by    |                | R          |    |
| .3. | EDGAR §80.26.              |                | equirement |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA regularly and      | EDGAR §76.770  | Co         | 8  |
| V.B | systematically monitors    | and §80.40(a)  | mmendation |    |
| .4. | 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).     |                |            |    |
+-----+----------------------------+----------------+------------+----+
| I   | The SEA ensures that LEAs  | §9501          | Met        | NA |
| V.B | comply with requirements   |                | R          |    |
| .5. | with regards to services   |                | equirement |    |
|     | to eligible nonpublic      |                |            |    |
|     | schools.                   |                |            |    |
+-----+----------------------------+----------------+------------+----+
| V   | The SEA ensures that       | §2113(c)       | Finding    | 8  |
| .1. | State-level activity funds |                |            |    |
|     | are expended on allowable  |                |            |    |
|     | activities.                |                |            |    |
+-----+----------------------------+----------------+------------+----+
| V   | The SEA ensures that       | §2113(f)       | Met        | NA |
| .2. | State-level activity funds |                | R          |    |
|     | do not supplant other,     |                | equirement |    |
|     | non-Federal funds.         |                |            |    |
+-----+----------------------------+----------------+------------+----+

  ----------------------------------------------------------------------------------
  **State                                                                     
  Agency for                                                                  
  Higher                                                                      
  Education**                                                                 
  ------------- -------------------------------- -------------- ------------- ------
  **Critical    **Requirement**                  **Citation**   Status        Page
  Element**                                                                   

  1\.           The SAHE manages a competition   §2132 and      Met           NA
                to award grants to carry out     §2133          Requirement   
                appropriate professional                                      
                development activities.                                       

  2\.           The SAHE works in conjunction    §2132(a)       Met           NA
                with the SEA (if the two are                    Requirement   
                separate agencies) in awarding                                
                the grants.                                                   

  3\.           The SAHE awards grants only to   §2131          Met           NA
                eligible partnerships that                      Requirement   
                include at least 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.                                 

  4\.           The SAHE ensures that each       §2134          Met           NA
                partnership awarded a grant                     Requirement   
                engages in eligible activities.                               

  5\.           The SAHE has procedures in place §2132(c)       Met           NA
                to ensure that no partner uses                  Requirement   
                more than 50 percent of the                                   
                funds in the grant.                                           

  6\.           The SAHE regularly and           EDGAR §76.770  Met           NA
                systematically monitors grantees and §80.40(a)  Requirement   
                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)                                                     
  ----------------------------------------------------------------------------------

**[State Educational Agency]{.smallcaps}**

> **Area I: HQT Definitions and Procedures**

**[Critical Element I.1]{.underline}: The State has established
appropriate HQT requirements for all teachers who teach core subjects.**

**[Citation]{.underline}:** §9101(23)

**[Commendation]{.underline}:** The State is commended for the
development and implementation of the Delaware Educator Data System
(DEEDS). This comprehensive, user-friendly online system has allowed the
state to link its various data sources to facilitate its ability to meet
the HQT challenge. Teachers use DEEDS to complete their HOUSSE process
(called the Teacher Quality Survey). As the teachers complete their
survey, the system tailors the survey to the certification status and
experience level of the teacher. DEEDS contains internal quality-control
processes; the system provides regular data-quality reports to the
districts as the teachers complete their survey. Teachers can also
provide updated information to the state on their professional
development activities and credentials through DEEDS, and the system is
continuously updated with new information. State, district and school
staff can use DEEDS to track the HQT status of their teachers. DEEDS is
also available to the public to find the qualifications of teachers in
the state.

**[Recommendation 1]{.underline}:** While DEEDS is available to the
public, interviews with state and district officials indicate that the
system is not widely used by parents or the public. It is recommended
that the state and districts make the availability of DEEDS more widely
known and encourage parents and the public to use DEEDS.

**[Recommendation 2]{.underline}:** The DDOE issues an Emergency
Certificate to address teacher shortages. This nonrenewable three-year
certificate is issued to individuals participating in alternative routes
to certification as well as out-of-field teachers and teachers who have
not yet passed the Praxis II content test(s), which are now required for
full state certification. The State should consider eliminating this
Emergency Certificate, especially in the core academic content areas,
because ensuring that all teachers have full state certification is an
essential element in getting all teachers of core academic content areas
to highly qualified status.

**[Critical Element I.4]{.underline}: The SEA ensures that all teachers
hired after the first day of the 2002-03 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.

**[Further Action Required]{.underline}****:** The State must, within 30
business days, submit to the Department a written plan with specific
procedures and a timeline the State will implement to ensure that all
teachers hired after the first day of the 2002-03 school year to teach
in Title I programs are highly qualified at the time of hire. The State
must also provide the Department with evidence that it is taking this
corrective action.

**[Critical Element I.5]{.underline}: The SEA ensures that all teachers
paid with Title II, Part A funds for class size reduction are highly
qualified.**

**[Citation]{.underline}:** §2123(a)(2)(B)

**[Finding]{.underline}:** The State cannot ensure that all teachers
paid with Title II, Part A funds for class size reduction are highly
qualified.

**[Further Action Required]{.underline}:** The State must, within 30
business days, 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 II, Part A funds for class size reduction are
highly qualified. Also, the State must provide the Department with
evidence that it is taking these corrective actions.

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

**[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 must revise its Annual Report Card
to include the required HQT data. The State's Annual Report Card must
include the percentage of teachers on emergency or provisional
credentials.

**[Further Action Required]{.underline}:** Within 30 business days, the
State must submit to the Department a written plan with specific
procedures and a timeline that the State will implement to correct
deficiencies in the HQT data reported in its Annual Report Card.

**Area III: HQT Plans**

**[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)

**[Recommendation]{.underline}:** While the state has had annual
measurable objectives for meeting the HQT challenge in place for its
LEAs since 2003-04, the state did not begin collecting classroom-level
HQT data until 2005-06. It is recommended that the state be prepared at
the end of the 2007-08 school year to enter into an agreement on the use
of funds with any LEAs not meeting their annual measurable objectives
for HQT and failing to make AYP for three years. 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.

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

**[Critical Element IV.B.2]{.underline}: The SEA ensures that LEA funds
do not supplant other, non-Federal funds.**

**[Citation]{.underline}:** §2123(b)

**[Finding]{.underline}:** The State did not demonstrate that the LEAs
using Title II, Part A funds to carry out activities to reduce class
sizes used these funds to supplement, and not supplant, any State and
local funds that would otherwise have been used to meet the State\'s
class-size reduction requirements.

**[Further Action Required]{.underline}:** Within 30 days, the State
must:

\(1\) Identify which LEAs for the 2007-2008 school year have used Title
II, Part A funds to pay the salaries of teachers hired to reduce class
size; and

\(2\) Submit documentary support that demonstrates that each of these
LEAs used Title II, Part A funds only to supplement, and not to
supplant, any State and local funds that would otherwise have been used
to meet the requirements of Title 14, section 1705A(c), of the Delaware
Code.

**[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.**

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

**[Commendation]{.underline}:** The State is commended for its new
cohesive and thorough monitoring and evaluation system. In addition to
traditional desk audits and on-site reviews, the state is moving toward
using risk analysis and needs-based monitoring. Using various data
elements, including HQT, the state is developing quality indicators to
regularly monitor districts. The state is hoping to move to an "every
district, every year" monitoring schedule by examining data and
correcting compliance issues early and using onsite reviews as more of a
technical assistance, rather than a monitoring tool.

**Area V: Title II, Part A State-Level Activities**

**Critical Element V.1: The SEA ensures that State-level activity funds
are expended on allowable activities.**

**[Citation]{.underline}:** §2113(c)

**[Finding]{.underline}:** In both the 2006 and 2007 fiscal years, the
state allocated more than 95 percent of its Title II, Part A funding to
the LEAs. State Activity funds may not be allocated to LEAs, so the
State must correct the allocation error.

**[Further Action Required]{.underline}:** The State must correct the
fiscal year 2006 allocation error with fiscal year 2008 funds and send
the Department the spreadsheet with the corrections. Within 30 business
days, the State must submit to the Department a written plan with
specific procedures and a timeline that the State will implement to
correct this error. The State has indicated that it intends to correct
the fiscal year 2007 allocation error with 2007 funds.

[^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.