August 10, 2005

HIGHLY QUALIFIED TEACHERS AND

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

MONITORING REPORT

**Tennessee Department of Education**

**May 10-12, 2005**

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

Elizabeth Witt

Miriam Lund

Allison Henderson (Westat)

**Tennessee Department of Education**

John Scott, Assistant Commissioner, Center for Teaching and Learning

Angelia Cannon, Executive Director, Teacher Quality

Christie Lentz, Director, Field Services

Julie McCargar, Executive Director, Federal Programs

Karen Moody, Director, Teacher Quality and Recruitment

Vance Rugaard, Director, Licensure

Sharon Yates, Consultant

**Tennessee Higher Education Commission**

William Arnold, SAHE Coordinator

**Overview of Tennessee:**

Number of Districts: 136

Number of Teachers: 58,577

Total State Allocation (FY 2004): \$50,061,830

Allocation for local educational agencies (LEAs): \$47,083,152

State Educational Agency (SEA) State Activities Allocation: \$1,239,030

State Agency for Higher Education (SAHE) Allocation: \$1,239,030

**Scope of Review:**

Like all State educational agencies (SEAs), the Tennessee Department of
Education (TDOE), 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" 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 Tennessee had two purposes. One was
to review the progress of the State in meeting the ESEA's highly
qualified teacher (HQT) requirements. The second was to review the use
of ESEA Title II, Part A funds by the SEA, selected districts, 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 high academic
achievement standards and to their full potential.

The monitoring review was conducted May 10-12, 2005 at the offices of
the TDOE. As part of the review, the Department's monitoring team met
with Angelia Cannon and Julie McCargar who administer the ESEA Title II,
Part A funds and William Arnold, the SAHE coordinator. The review team
visited the Davidson County School District and conducted telephone
interviews with the Bradley and Wayne Public School Districts.

#### Summary of Monitoring Indicators

+----------+-------------------------------+----------------+--------+
| #        |                               |                |        |
| Monitori |                               |                |        |
| ng Area  |                               |                |        |
| 1: Highl |                               |                |        |
| y Qualif |                               |                |        |
| ied Teac |                               |                |        |
| her Syst |                               |                |        |
| ems & Pr |                               |                |        |
| ocedures |                               |                |        |
+----------+-------------------------------+----------------+--------+
| *        | **Description**               | # Status       | # Page |
| *Element |                               |                |        |
| Number** |                               |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Has the State developed and   | Commendations  | 7      |
| Element  | implemented procedures,       |                |        |
| 1.1.     | consistent with the statutory | Recommendation |        |
|          | 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   | requirement    |        |
| 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        | Met            | NA     |
| Element  | secondary school teachers     | requirement    |        |
| 1.3.     | (including special education  |                |        |
|          | teachers, as appropriate)     |                |        |
|          | required to demonstrate       |                |        |
|          | subject-matter competency, in |                |        |
|          | each core academic subject    |                |        |
|          | they teach, in one or more of |                |        |
|          | the following ways            |                |        |
|          | (§9101(23)(B)(II)(ii))?       |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Are all veteran (i.e., those  | > Finding      | 7      |
| Element  | who are not new to the        | >              |        |
| 1.4.     | profession) elementary school | > Commendation |        |
|          | 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    | > Met          | 8      |
| Element  | secondary teachers (including | > requirement  |        |
| 1.5.     | special education teachers,   | >              |        |
|          | as appropriate) required to   | > Commendation |        |
|          | demonstrate subject-matter    |                |        |
|          | competency in each core       |                |        |
|          | academic subject they teach?  |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | For each set of HOUSSE        | Met            | NA     |
| Element  | procedures the State has      | requirement    |        |
| 1.6.     | developed, can the State      |                |        |
|          | describe how it meets each of |                |        |
|          | the statutory requirements in |                |        |
|          | §9101(23)(C)(ii)?             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Does the SEA ensure that,     | Finding        | 8      |
| Element  | since the beginning of the    |                |        |
| 1.7.     | 2002-03 school year,          |                |        |
|          | districts only hire highly    |                |        |
|          | qualified teachers (including |                |        |
|          | special education teachers,   |                |        |
|          | as appropriate) to teach in   |                |        |
|          | Title I programs?             |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Has the SEA ensured, since    | Finding        | 8      |
| Element  | the beginning of the 2002-03  |                |        |
| 1.8.     | 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  | requirement    |        |
| 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 such teachers   |                |        |
|          |     to become highly          |                |        |
|          |     qualified and successful  |                |        |
|          |     classroom teachers        |                |        |
|          |     (§1119(a)(2)(A))?         |                |        |
+----------+-------------------------------+----------------+--------+
| Critical | Does the SEA also have a plan | Finding        | 9      |
| 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 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 | Met            | 9      |
| Element  | Secretary in its Consolidated | requirement    |        |
| 1.11.    | State Performance Report      |                |        |
|          | (CSPR) the number and         | Recommendation |        |
|          | 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 requirement | 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 requirement | 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 | Does the SEA require each    | Met requirement | NA     |
| Element  | LEA to describe how the      |                 |        |
| 2.3.     | activities to be carried out |                 |        |
|          | are based on the required    |                 |        |
|          | local needs assessment       |                 |        |
|          | (§2122(b))?                  |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have a          | Met requirement | NA     |
| Element  | procedure to determine the   |                 |        |
| 2.4.     | amount of funds each LEA     |                 |        |
|          | expended during the period   |                 |        |
|          | of availability?             |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have a          | Met requirement | NA     |
| Element  | procedure to regularly       |                 |        |
| 2.5.     | review the drawdowns of the  |                 |        |
|          | LEAs?                        |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have a written  | Met requirement | NA     |
| Element  | policy on allowable          |                 |        |
| 2.6.     | carryover funds?             |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | If an LEA cannot obligate    | Met requirement | NA     |
| Element  | funds within the 27 months   |                 |        |
| 2.7.     | of availability (which       |                 |        |
|          | includes the extra year of   |                 |        |
|          | availability permitted under |                 |        |
|          | the Tydings amendment), does |                 |        |
|          | the SEA have a procedure for |                 |        |
|          | reallocating these funds to  |                 |        |
|          | other LEAs?                  |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA have records to | Met requirement | NA     |
| Element  | show that each LEA meets the |                 |        |
| 2.8.     | maintenance of effort        |                 |        |
|          | requirements?                |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Does the SEA ensure that it  | Met requirement | NA     |
| Element  | and its component LEAs are   |                 |        |
| 2.9.     | audited annually, if         |                 |        |
|          | required, and that all       |                 |        |
|          | corrective actions required  |                 |        |
|          | through this process are     |                 |        |
|          | fully implemented?           |                 |        |
+----------+------------------------------+-----------------+--------+
| Critical | Has the SEA identified and   | Met requirement | NA     |
| Element  | provided technical           |                 |        |
| 2.10.    | assistance to LEAs that are  |                 |        |
|          | not making progress toward   |                 |        |
|          | meeting their annual         |                 |        |
|          | measurable objectives in     |                 |        |
|          | meeting the highly qualified |                 |        |
|          | teacher challenge (§2141)?   |                 |        |
+----------+------------------------------+-----------------+--------+

+---------+---------------------------------+------------------+------+
| #       |                                 |                  |      |
| Monitor |                                 |                  |      |
| ing Are |                                 |                  |      |
| a 3: St |                                 |                  |      |
| ate Act |                                 |                  |      |
| ivities |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| **      | # Description                   | ### Status       | ##   |
| Element |                                 |                  | Page |
| N       |                                 |                  |      |
| umber** |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the State use its State    | Met requirement  | NA   |
| ritical | Activities funds to promote the |                  |      |
| Element | recruitment, hiring, training,  |                  |      |
| 3.1.    | and retention of highly         |                  |      |
|         | qualified teachers and          |                  |      |
|         | principals?                     |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the State support          | Met requirement  | 10   |
| ritical | activities that focus on        |                  |      |
| Element | increasing the subject-matter   | Commendation     |      |
| 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           | Met requirement  | NA   |
| ritical | competition for eligible        |                  |      |
| Element | partnerships?                   |                  |      |
|         |                                 |                  |      |
| 4\. 1.  |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | Does the SAHE have procedures   | Finding          | 10   |
| ritical | to ensure that eligible         |                  |      |
| Element | partnerships include the        | Recommendation   | 11   |
| 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: State Procedures to Identify Highly Qualified
Teachers]{.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))?**

[]{.mark}

**[Commendation:]{.underline}** The State is commended for its highly
qualified teacher (HQT) plan. The plan provides comprehensive
information on the HQT process in a user-friendly manner and has been
very well received by LEAs.

**[Commendation]{.underline}:** The TDOE is commended for its public
"Teacher Certification Information" database. Members of the public can
view the specific licenses that teachers hold as well as their HQT
status.

**[Recommendation]{.underline}:** Tennessee issues two temporary
licenses -- the Interim B and Permit. Interim B candidates have
completed all requirements for full certification except passing all
required Praxis II assessments. Teachers with these licenses are not
highly qualified. Permits are granted to a local school system to employ
individuals who do not hold a valid license when that school system is
unable to obtain the services of a qualified teacher for the type of
position in which the vacancy exists. The monitoring team recommended
that the SEA begin phasing out these licenses before the end of the
2005-06 school year, as well as analyzing how many teachers on these
licenses would be eligible to participate in alternative route programs.

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

**[Finding:]{.underline}** The TDOE allows veteran elementary school
teachers to demonstrate subject-matter competency in ways that are not
in compliance with the statute as described in §9101(23)(C). The TDOE
considers elementary school teachers who have National Board for
Professional Teaching Standards (NBPTS) Certification to be highly
qualified.

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

**[Further Action Required]{.underline}:** The TDOE must revise its
procedures so that veteran elementary teachers may demonstrate
subject-matter competency only through passing a test or HOUSSE. The
TDOE may revise its HOUSSE procedures for veteran elementary school
teachers to include a factor pertaining to holding NBPTS Certification.
As part of a State's HOUSSE procedures, this qualification could be
sufficient to determine subject-matter competency.

**[Commendation]{.underline}:** The State is commended for providing
teachers a range of HOUSSE options. Veteran teachers may elect to use
the Professional Matrix, Teacher Effect Data, or the Framework for
Evaluation and Professional Growth.

**[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?**

**[Commendation]{.underline}:** The State is commended for providing
teachers a range of HOUSSE options. Veteran teachers may elect to use
the Professional Matrix, Teacher Effect Data, or the Framework for
Evaluation and Professional Growth.

**[Critical Element 1.7:]{.underline} Does the SEA ensure that, since
the beginning of the 2002-03 school year, districts only hire highly
qualified teachers (including special education teachers, as
appropriate) to teach in Title I programs?**

**[Finding:]{.underline}** The State cannot ensure that LEAs are hiring
only highly qualified teachers to provide direct instruction in core
academic subjects for their Title I schoolwide programs.

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

**[Further Action Required:]{.underline}** The TDOE must submit a
written plan with specific procedures and a timeline for requiring LEAs
in the State to ensure that all teachers hired to teach in Title I
programs after the first day of the 2002-03 school year, including
special education teachers providing direct instruction in core academic
subjects, demonstrate that they are highly qualified in each core
academic subject they teach, either by passing the State's test for
demonstrating subject-matter knowledge or by satisfying HOUSSE
procedures established by the State.

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

**[Finding:]{.underline}** The TDOE does not have procedures to ensure
that districts using ESEA funds to reduce class size hire only highly
qualified teachers.

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

[**Further Action Required**:]{.underline} The TDOE must submit a
written plan with specific procedures and a timeline for requiring LEAs
in the State to ensure that all teachers hired after the first day of
the 2002-03 school year, including special education teachers providing
direct instruction in core academic subjects, demonstrate that they are
highly qualified in each core academic subject they teach, either by
passing the State's test for demonstrating subject-matter knowledge or
by satisfying HOUSSE procedures established by the State.

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

**[Finding:]{.underline}** The TDOE has not developed a plan to ensure
that poor and minority children are not taught at higher rates than
other children by teachers who are inexperienced or unqualified.

**[Citation:]{.underline}** §1111(b)(8)(C) of the ESEA requires each
State to have a plan that describes "the specific steps the State
educational agency will take to ensure that both schoolwide programs and
targeted assistance schools provide instruction by highly qualified
instructional staff as required by sections 1114(b)(1)(C) and
1115(c)(1)(E), including steps that the State educational agency will
take to ensure that poor and minority children are not taught at higher
rates than other children by inexperienced, unqualified, or out-of-field
teachers, and the measures that the State educational agency will use to
evaluate and publicly report the progress of the State educational
agency with respect to such steps."

[]{.mark}

**[Further Action Required:]{.underline}** The State must submit a
written plan with specific procedures to ensure that poor and minority
children are not taught at a higher rate than their peers by
inexperienced or unqualified teachers.

**[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))?**

**[Recommendation]{.underline}**: The TDOE currently is collecting
district-level HQT data via emailed Excel spreadsheets. Such
decentralized files are difficult to manage and pose problems with data
confidentiality. The State indicated that it needs assistance to build a
centralized data collection system. ED recommends that the State
consider using Title II, Part A State activity funds to build such a
system.

**[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}** The TDOE has collected and reported HQT data
in an annual report card. However, the data have not been reported in
the required format. The State reported the percentage of classes taught
by highly qualified teachers. Information about teachers on waivers was
reported as a number rather than as a percentage. The Annual State
Report Card did not provide information on the qualification of the
teaching workforce.

[**Citation**:]{.underline} §1111(h)(1)(C)(viii) of the ESEA requires
each SEA to include in its Annual State Report Card data on the
professional qualifications of teachers in the State, the percentage of
such teachers teaching with emergency or provisional credentials, and
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 TDOE must report to the
public, as required by §1111(h)(1)(C)(viii), on the professional
qualifications of teachers in the State, the percentage of such teachers
teaching with emergency or provisional credentials, and 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.

##### Area 3: State Activities

**[Critical Element 3.2:]{.underline} Does the State support activities
that focus on increasing the subject-matter knowledge of teachers and
that assist teachers to become highly qualified?**

[Commendation:]{.underline} The TDOE is commended for using its Title
II, Part A funds to support high-quality professional development,
especially through the Highly Qualified Teacher Academies and the High
Priority Gateway Institutes. The High Priority Gateway Institutes are
designed to train middle and high school teachers in content-related
instructional strategies to help students pass the Tennessee Gateway
exit test. The Highly Qualified Teacher Academies provide instruction
focused on content and pedagogy aligned with the *Blueprint for
Learning's* performance standards. Academy participants may receive 3
semester hours of credit for \$100, which is a very good value for
teachers seeking continuing education.

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

**[Critical Element 4.2:]{.underline} Does the SAHE have procedures to
ensure that eligible partnerships include the 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?**

**[Finding:]{.underline}** The SAHE did not use the required Census data
in its determination of a high-need LEA and cannot assure that each
grant includes an eligible high-need LEA.

[**Citation**:]{.underline} §2131(1)(A)(iii) of ESEA requires the SAHE
to include a high-need LEA in each eligible partnership. §2102(3)
defines the poverty requirements for a high-need LEA as an LEA that:

-   Serves not fewer than 10,000 children from families with incomes
    below the poverty line; or

-   Not less than 20 percent of the children served by the agency are
    from families with incomes below the poverty line **and**

-   For which there is a high percentage of teachers not teaching in the
    academic subjects or grade levels that the teachers were trained to
    teach; **or**

-   For which there is a high percentage of teachers with emergency,
    provisional, or temporary certification or licensing \[Section
    2102(3)\].

Because the statute addresses family income, the Secretary has
determined that the Census Bureau data is the only stable and reliable
measure of family income and poverty.

**[Further Action Required:]{.underline}** In the next competition for
eligible partnerships, the SAHE must use the most recent available
Census data (as determined by the Secretary) to identify high-need LEAs.
Other sources of data, such as free- and reduced-priced lunch data, may
not be factored into the calculations, except for LEAs for which there
is no available Census data (e.g., charter school LEAs). The most recent
data can be found at <http://www.census.gov/hhes/www/saipe/>.

**[Recommendation]{.underline}:** While the SAHE coordinator monitors
grants to ensure that no single participant in an eligible partnership
uses more than 50 percent of the funds made available to the
partnership, he found it difficult to actually track the use of funds.
The coordinator may want to consider using effective tracking models
developed by his colleagues in other states.