Revised June 15, 2005

HIGHLY QUALIFIED TEACHERS AND

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

MONITORING REPORT

Illinois State Board of Education

**March 2-5, 2005**

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

Robert Stonehill Tamara Morse Azar (Westat)

Elizabeth Witt

**Illinois State Board of Education**

Gail Lieberman, Special Assistant for NCLB

Ginger Reynolds, Assistant Superintendent for Teaching and Learning
Services

Connie Wise, Data Analysis and Performance Reporting Division
Administrator

Dennis Williams, Certification Division Administrator

Bob Bigham, Certification Division

Candy Taylor, Programmer for Certification

Myron Mason, Federal Grants and Programs Division Administrator

Marla Wiemer, Budget Office

Bonnie Robinson, Budget Office

Robert Wolfe, External Assurance Division Administrator

Paul Williams, External Assurance

Patrick Murphy, ROE/Chicago Services

**Chicago Public Schools**

Walter Thiel

Kathleen Irizarry

Pedro Martinez

Nancy Slavin

Ascension Juarez

Crystal Sykes

**Pleasant Hill CUSD** (phone interview)

Mike Dempsey, Superintendent

**Divernon CUSD** (phone interview)

Mark Spaid, Superintendent

**Illinois Board of Higher Education \[State Agency for Higher Education
(SAHE)\]**

Terry Nunn, Senior Associate Director, Illinois Board of Higher
Education

Rich Jachino, Illinois Board of Higher Education

Diane Gardner, Illinois State University

Ross Hodel, Illinois State University

  ------------------------------ --------------------- -------------------
  **[Overview of                                       
  Illinois:]{.underline}**                             

  **Number of Districts**        881                   []{.mark}

  **Number of Schools**          4,273                 []{.mark}

  **Number of Teachers**         134,608, both full-   []{.mark}
                                 and part-time         

  []{.mark}                                            

                                 **FY2003**            **FY2004**

  **State Allocation**           \$117,358,738         \$118,016,892

  **LEA Allocation**             \$110,375,893         \$110,994,888

  **State Activities**           \$2,904,629           \$2,920,918

  **SAHE Allocation**            \$2,904,629           \$2,920,918

  **SEA Administration**         \$1,028,356           \$1,034,122

  **SAHE Administration**        \$145,231             \$146,046
  ------------------------------ --------------------- -------------------

**Scope of Review:**

Like all State educational agencies (SEAs), the Illinois State Board of
Education (ISBE), 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 (ED) 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 purpose of the ED monitoring team visit to Illinois was twofold:
first, to review the progress of the State in meeting the Highly
Qualified Teacher (HQT) requirements of NCLB, including the
identification of areas needing corrective action as well as promising
practices; and second, to review the use of ESEA Title II, Part A funds
by the State, 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 a high standard.

The monitoring review was conducted at the Illinois State Board of
Education office and on-site at the Chicago Public Schools. In addition
to meeting with State representatives from ISBE, the team met with LEA
representatives from Chicago Public Schools and conducted phone
interviews with Pleasant Hill and Divernon School Districts. The ED
monitoring team conducted the SAHE interview with Terry Nunn and other
representatives of the Illinois Board of Higher Education.

#### Summary of Monitoring Indicators

+-----------+------------------------------------+--------------+-----+
| # M       |                                    |              |     |
| onitoring |                                    |              |     |
|  Area 1:  |                                    |              |     |
| Highly Qu |                                    |              |     |
| alified T |                                    |              |     |
| eacher Sy |                                    |              |     |
| stems & P |                                    |              |     |
| rocedures |                                    |              |     |
+-----------+------------------------------------+--------------+-----+
| **Element | **Description**                    | # Status     | # P |
| Number**  |                                    |              | age |
+-----------+------------------------------------+--------------+-----+
| Critical  | Has the State developed and        | Finding      | 7   |
| Element   | implemented procedures, consistent |              |     |
| 1.1       | with the statutory definition of   | Commendation |     |
|           | highly qualified, to determine     |              |     |
|           | whether *all* teachers of core     |              |     |
|           | academic subjects are highly       |              |     |
|           | qualified (§9101(23))?             |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | Are all new elementary school      | Finding      | 8   |
| Element   | teachers (including special        |              |     |
| 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 secondary   | Finding      | 8   |
| Element   | school teachers (including special |              |     |
| 1.3       | education teachers, as             |              |     |
|           | appropriate) required to           |              |     |
|           | demonstrate subject-matter         |              |     |
|           | competency in each core academic   |              |     |
|           | subject they teach, consistent     |              |     |
|           | with §9101(23)(B)(II)(ii)?         |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | Are all veteran (i.e., those who   | Findings     | 9   |
| Element   | are not new to the profession)     |              |     |
| 1.4       | elementary school teachers         |              |     |
|           | (including special education       |              |     |
|           | teachers, as appropriate) required |              |     |
|           | to demonstrate subject-matter      |              |     |
|           | competency by passing a rigorous   |              |     |
|           | State test or by completing the    |              |     |
|           | State's "High Objective Uniform    |              |     |
|           | State Standard of Evaluation"      |              |     |
|           | (HOUSSE) procedures                |              |     |
|           | (§9101(23)(C))?                    |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | Are all veteran middle and         | Finding      | 9   |
| Element   | secondary teachers (including      |              |     |
| 1.5       | special education teachers, as     |              |     |
|           | appropriate) required to           |              |     |
|           | demonstrate subject-matter         |              |     |
|           | competency in each core academic   |              |     |
|           | subject they teach, consistent     |              |     |
|           | with §9101(23)(B)(II)(ii)?         |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | If the State has developed HOUSSE  | Finding      | 10  |
| Element   | procedures, please provide a copy  |              |     |
| 1.6       | of the most current version(s).    |              |     |
|           | For each set of HOUSSE procedures  |              |     |
|           | the State has developed, please    |              |     |
|           | describe how it meets each of the  |              |     |
|           | following statutory requirements   |              |     |
|           | of §9101(23)(C)(ii).               |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | How does the SEA ensure that,      | Met          | NA  |
| Element   | since the beginning of the 2002-03 | requirement  |     |
| 1.7       | school year, districts only hire   |              |     |
|           | highly qualified teachers          |              |     |
|           | (including special education       |              |     |
|           | teachers, as appropriate) to teach |              |     |
|           | in Title I programs?               |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | How has the SEA ensured, since the | Finding      | 10  |
| Element   | beginning of the 2002-03 school    |              |     |
| 1.8       | 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 for   | requirement  |     |
| 1.9       | 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 with | Finding      | 10  |
| Element   | specific steps to ensure that poor |              |     |
| 1.10      | 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      | Finding      | 11  |
| Element   | Secretary in the CSPR the number   |              |     |
| 1.11      | and percentage of core academic    | Commendation |     |
|           | classes taught by highly qualified |              |     |
|           | teachers, in the aggregate and in  |              |     |
|           | high-poverty schools, consistent   |              |     |
|           | with the statutory definition of   |              |     |
|           | highly qualified (§1111(h)(4)(G);  |              |     |
|           | §9101(23))?                        |              |     |
+-----------+------------------------------------+--------------+-----+
| Critical  | Does the State prepare and         | Finding      | 12  |
| Element   | disseminate to the public an       |              |     |
| 1.12      | Annual State Report Card           |              |     |
|           | (§1111(h)(1)(C)(viii))? If so, how |              |     |
|           | is it disseminated?                |              |     |
+-----------+------------------------------------+--------------+-----+

+-----------+-----------------------------------+--------------+---+-----+---+
| # Moni    |                                   |              |   |     |   |
| toring Ar |                                   |              |   |     |   |
| ea 2: Adm |                                   |              |   |     |   |
| inistrati |                                   |              |   |     |   |
| on of ESE |                                   |              |   |     |   |
| A Title I |                                   |              |   |     |   |
| I, Part A |                                   |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| **Element | # Description                     | ### Status   | # |     |   |
| Number**  |                                   |              | # |     |   |
|           |                                   |              |   |     |   |
|           |                                   |              | P |     |   |
|           |                                   |              | a |     |   |
|           |                                   |              | g |     |   |
|           |                                   |              | e |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Does the SEA allocate funds       | Met          |   | NA  |   |
| Element   | according to the statute, using   | requirement  |   |     |   |
| 2.1       | the most recent Census Bureau     |              |   |     |   |
|           | data as described in the          |              |   |     |   |
|           | Non-Regulatory Guidance           |              |   |     |   |
|           | (§2121(a))?                       |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Does the SEA require an           | Met          |   | NA  |   |
| Element   | application from each LEA before  | requirement  |   |     |   |
| 2.2       | providing Title II, Part A        |              |   |     |   |
|           | funding? If yes, what information |              |   |     |   |
|           | does the SEA require in the LEA   |              |   |     |   |
|           | application (§2122(b))?           |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | In particular, does the SEA       | Met          |   | NA  |   |
| Element   | require each LEA to describe how  | requirement  |   |     |   |
| 2.3       | the activities to be carried out  |              |   |     |   |
|           | are based on the required local   |              |   |     |   |
|           | needs assessment (§2122(b))?      |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Does the SEA have a procedure to  | Met          |   | NA  |   |
| Element   | determine the amount of funds     | requirement  |   |     |   |
| 2.4       | each LEA expended during the      |              |   |     |   |
|           | period of availability?           |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Does the SEA have a procedure to  | Met          |   | NA  |   |
| Element   | regularly review the drawdowns of | requirement  |   |     |   |
| 2.5.      | the LEAs?                         |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Does the SEA have a written       | Met          |   | NA  |   |
| Element   | policy on allowable carryover     | requirement  |   |     |   |
| 2.6       | funds?                            |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | If an LEA cannot obligate funds   | > Met        |   | NA  |   |
| Element   | within the 27 months of           | >            |   |     |   |
| 2.7       | availability (which includes the  |  requirement |   |     |   |
|           | 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 show | Met          |   | NA  |   |
| Element   | that each LEA meets the           | requirement  |   |     |   |
| 2.8       | maintenance of effort             |              |   |     |   |
|           | requirements?                     |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Does the SEA ensure that it and   | Met          |   | NA  |   |
| Element   | its component LEAs are audited    | requirement  |   |     |   |
| 2.9       | annually, if required, and that   |              |   |     |   |
|           | all corrective actions required   |              |   |     |   |
|           | through this process are fully    |              |   |     |   |
|           | implemented?                      |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+
| Critical  | Has the SEA identified and        | Met          |   | 12  |   |
| Element   | provided technical assistance to  | requirement  |   |     |   |
| 2.10      | LEAs that are not making progress | Re           |   |     |   |
|           | toward meeting their annual       | commendation |   |     |   |
|           | measurable objectives in meeting  |              |   |     |   |
|           | the highly qualified teacher      | Commendation |   |     |   |
|           | challenge?                        |              |   |     |   |
+-----------+-----------------------------------+--------------+---+-----+---+

+----------+------------------------------------+--------------+-----+
| # Mon    |                                    |              |     |
| itoring  |                                    |              |     |
| Area 3:  |                                    |              |     |
| State Ac |                                    |              |     |
| tivities |                                    |              |     |
+----------+------------------------------------+--------------+-----+
| *        | # Description                      | ### Status   | #   |
| *Element |                                    |              | # P |
| Number** |                                    |              | age |
+----------+------------------------------------+--------------+-----+
| Critical | Does the State use its State       | Met          | 12  |
| Element  | Activities funds to promote the    | requirement  |     |
| 3.1      | recruitment, hiring, training, and |              |     |
|          | retention of highly qualified      | Re           |     |
|          | teachers and principals?           | commendation |     |
+----------+------------------------------------+--------------+-----+
| Critical | Does the State support activities  | Met          | 13  |
| Element  | that focus on increasing the       | requirement  |     |
| 3.2      | subject-matter knowledge of        |              |     |
|          | teachers and that assist teachers  | Commendation |     |
|          | to become highly qualified?        |              |     |
+----------+------------------------------------+--------------+-----+

+----------+------------------------------------+--------------+-----+
| # Monito |                                    |              |     |
| ring Are |                                    |              |     |
| a 4: Sta |                                    |              |     |
| te Agenc |                                    |              |     |
| y for Hi |                                    |              |     |
| gher Edu |                                    |              |     |
| cation ( |                                    |              |     |
| SAHE) Ac |                                    |              |     |
| tivities |                                    |              |     |
+----------+------------------------------------+--------------+-----+
| *        | # Description                      | ### Status   | #   |
| *Element |                                    |              | # P |
| Number** |                                    |              | age |
+----------+------------------------------------+--------------+-----+
| Critical | Did the SAHE manage a competition  | Met          | 13  |
| Element  | for eligible partnerships?         | requirement  |     |
| 4.1      |                                    |              |     |
|          |                                    | C            |     |
|          |                                    | ommendations |     |
+----------+------------------------------------+--------------+-----+
| Critical | Does the SAHE have procedures to   | Met          | NA  |
| Element  | ensure that eligible partnerships  | requirement  |     |
| 4.2      | 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? |              |     |
+----------+------------------------------------+--------------+-----+

**[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))?**

**[Finding:]{.underline}** ISBE's procedure for determining the highly
qualified teacher (HQT) status of special education teachers of core
academic subjects is not consistent with the definition of a "highly
qualified" teacher in §9101(23) of the ESEA.

ISBE has not determined the highly qualified status of special education
teachers instructing in the core content areas. The State currently
requires that special education teachers pass a test of basic skills
that includes reading, writing, and mathematics. They must also pass the
Assessment of Professional Teaching for the appropriate grade level,
which evaluates the teachers' knowledge of the Illinois Professional
Teaching Standards, the language arts standards, and the technology
standards. ISBE has indicated that in Fall 2006 all special education
teachers will also be required to take a Special Education General
Curriculum assessment that will test their understanding of mathematics,
social science, and science based on the Illinois Learning Standards.

For veteran special educators, technical assistance was provided for
ISBE to (1) determine which teachers directly deliver content to
students, (2) identify those teachers with dual certification in
elementary or a content area, and (3) develop and implement HOUSSE
procedures for veteran teachers to determine their highly qualified
status.

**[Citation:]{.underline}** The ESEA provisions governing teacher
quality include basic requirements (§1119(a) and (b)) that all teachers
of core academic subjects who teach in Title I programs and who were
hired after the first day of the 2002-03 school year first demonstrate
that they are highly qualified, and that all other teachers of core
academic subjects in all public schools be highly qualified by the end
of the 2005-06 school year. §9101(23) of the ESEA expressly defines a
"highly qualified" teacher as one who has at least a bachelor's degree,
has full State certification, and has demonstrated competency in each
subject he or she teaches in certain statutorily prescribed ways.

**[Further Action Required:]{.underline}** ISBE must submit a written
plan with specific procedures to ensure that all special education
teachers of core academic subjects are highly qualified in conformity
with the definition in §9101(23) and the timeline in §1119(a)(1) and
(2).

**[Commendation:]{.underline}** Through the development of the On-Line
Teacher Information System (OTIS), the State is attempting to streamline
the process of determining the highly qualified status for teachers
throughout the state. While the system is still in the pilot stage and
will require modifications to ensure that all provisions of NCLB's
highly qualified teacher requirements are met before determining that a
teacher has met the standards, OTIS will work in conjunction with
existing state personnel databases to relieve some burden for teachers
and LEAs in determining and reporting highly qualified teacher
information.

**[Critical Element 1.2.]{.underline} Are all new elementary school
teachers (including special 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))?**

**[Finding:]{.underline}** The Illinois definition and procedures for
determining the highly qualified status of new special education
teachers are not in compliance with statute. Special education teachers
hold categorical licenses based on grade level, and are not assessed in
the same manner as regular education teachers. See Critical Element 1.1
for a more detailed discussion of this issue.

**[Citation:]{.underline}** §9101(23)(B)(II) of the ESEA requires that
all new elementary teachers demonstrate subject-matter competency in
each of the core academic subjects they teach by passing a rigorous
State assessment in reading, writing, mathematics, and the other areas
of the elementary school curriculum

**[Further Action Required:]{.underline}** ISBE must ensure that all new
elementary teachers, including special education teachers who provide
direct instruction in core academic subjects, demonstrate subject-matter
competency no later than the end of the 2005-06 school year.

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

**[Finding:]{.underline}** New middle and secondary teachers who hold
the Illinois 6-12 license are required to pass a content exam or have a
major (or its credit equivalent) in the content area to earn a
content-specific endorsement. However, middle and secondary school
special educators are not required to pass an assessment of their
content knowledge. Middle and secondary school special education
teachers are required to take the same battery of assessments as
elementary teachers (as described in Critical Element 1.1).

**[Citation:]{.underline}** §9101(23)(B)(II)(ii) of the ESEA requires
middle and secondary school teachers new to the profession to
demonstrate subject-matter competency in each of the core academic
subjects they teach by passing a rigorous State academic subject test or
by successfully completing an academic major, coursework equivalent to
an academic major, a graduate degree, or advanced certification or
credentialing.

**[Further Action Required:]{.underline}** ISBE must ensure that all
middle and secondary school teachers who teach multiple subjects,
including special education teachers who provide direct instruction in
core academic subjects, demonstrate subject-matter competency in each
core academic subject they teach, in accordance with the options
available in §9101(23)(B)(ii) and §9101(23)(C)(ii) of the ESEA, no later
than the end of the 2005-06 school year.

**[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 1:]{.underline}** The current HOUSSE procedures allow
teachers who are not new to the profession to demonstrate subject-matter
competency in ways that are not in compliance with the statute, as
described in §9101(23)(C). The Illinois HOUSSE allows for credit to be
given for experience outside of the content area and allows experience
to count for more than 50 percent of the total points needed.

**[Finding 2:]{.underline}** As discussed in Critical Element 1.1,
Illinois has not yet determined which special education teachers who are
not new to the profession directly deliver content to students, and meet
the highly qualified teacher provisions of NCLB.

**[Citation:]{.underline}** §1119(a)(2) of the ESEA requires all
teachers of core academic subjects to be highly qualified by the end of
the 2005-06 school year. Recent amendments to the IDEA, which the
President signed into law on December 3, 2004, affirm that these
requirements apply to special education teachers (while providing some
flexibility for special education teachers of multiple subjects and who
teach to alternate achievement standards for students with significant
cognitive disabilities).

**[Further Action Required]{.underline}:** ISBE must ensure that all
teachers who are not new to the profession, including special education
teachers who provide direct instruction in core academic subjects, are
highly qualified in each of the core academic subjects they teach by the
end of the 2005-06 school year. (Please also refer to the discussion in
Critical Element 1.1-1.3 above.)

**[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, in one or more of the following
ways?**

**[Finding:]{.underline}** For middle and secondary school teachers with
grades 6-12 licensure who teach multiple core academic subjects,
Illinois requires 18 credit hours to add an additional content-area
endorsement to the license. Eighteen hours is not a major equivalent
and, as such, is insufficient to demonstrate subject-area competence.

**[Citation:]{.underline}** §9101(23)(C)(ii) of the ESEA requires middle
or secondary school teachers not new to the profession, including
special education teachers who instruct in the core academic subjects,
to demonstrate subject-matter competency in each of the core academic
subjects they teach.

**[Further Action Required:]{.underline}** ISBE must ensure that, no
later than the end of the 2005-06 school year, experienced teachers pass
the required State subject test or meet one of the other criteria for
demonstrating the required subject-matter knowledge that §9101(23)
(B)(ii) or §9101(23) (C)(ii) of the ESEA requires in order to be highly
qualified. See Critical Elements 1.1 through 1.4 for more discussion.

**[Critical Element 1.6.]{.underline} Does each set of HOUSSE procedures
the State has developed meet each of the statutory requirements of
§9101(23)?**

**[Finding:]{.underline}** ISBE HOUSSE procedures allowed an elementary
education degree and the completion of an elementary preparation program
as sufficiency measures for meeting the highly qualified requirements.
Also, the HOUSSE awarded points for general teaching experience (not
limited to in the content area), and awarded additional points for
teaching in the content area. The two areas combined could satisfy 85 of
100 points in the HOUSSE. The Department team provided technical
assistance to ISBE to bring this component into compliance with the
statute.

**[Citation:]{.underline}** §9101(23)(C)(ii) permits a State to
establish HOUSSE procedures to determine the subject-matter knowledge of
an "elementary, middle, or secondary school teacher who is not new to
the profession." §9101(23)(C)(ii)(V) states that the HOUSSE may take
"into consideration, but not be based primarily on, the time the teacher
has been teaching in the academic subject."

**[Further Action Required:]{.underline}** ISBE must provide a written
plan for ensuring HOUSSE procedures are developed in alignment with the
statutory criteria, which includes considering teaching experience in
the content area, but which does not allow previous experience to count
for more that 50 percent.

**[Critical Element 1.8.]{.underline} How 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}** ISBE noted to the monitoring team that they
believed that teachers who were hired to reduce class size before the
implementation of NCLB would be exempt from meeting the highly qualified
teacher requirements.

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

**[Further Action Required]{.underline}:** The State must submit a
written plan with specific procedures to ensure that districts pay only
highly qualified teachers with ESEA Title II, Part A funds that are used
to reduce class size.

**[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}** ISBE 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 the CSPR the number and percentage of core academic classes
taught by highly qualified teachers, in the aggregate and in
high-poverty schools, consistent with the statutory definition of highly
qualified (§1111(h)(4)(G); §9101(23))?**

**[Finding:]{.underline}** The State did not report data in the CSPR on
the number and percentage of classes in core academic subjects that are
taught by highly qualified teachers in a manner that is consistent with
the statutory definition of highly qualified.

LEAs are working to implement the HOUSSE procedures, and the State does
not yet have data on the status of its veteran teachers that have not
passed State assessments. Also, ISBE is developing a plan to determine
the highly qualified status of special education teachers who instruct
in the core academic subjects. As a result, the State is reporting
estimates of the number and percentage of classes in core academic
subjects that are taught by highly qualified teachers.

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

**[Further Action Required:]{.underline}** ISBE must submit a written
plan with specific procedures and a timeline for reporting to the public
and to the Department, as required by §1111(h), the percentage of
classes taught by highly qualified teachers at all grade levels (and
disaggregated by high-and low-poverty schools), as required for the
CSPR.

**[Commendation]{.underline}:** ISBE developed the OTIS system, an
online teacher information database, for teachers to use to determine
their highly qualified status. The State is populating the database with
certification and service records already housed in other database
systems. OTIS has been piloted in two school districts, and ISBE expects
to release it statewide this fall. OTIS also includes online HOUSSE
procedures for veteran teachers.

**[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}** Illinois publishes data on the qualifications
of its teachers in an Annual State Report Card and other publications.
However, the State used incomplete data to report the percentage of core
academic classes taught by highly qualified teachers; special education
teachers and not-new teachers who need to demonstrate subject matter
mastery and have not yet gone through HOUSSE procedures.

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

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

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

**[Critical Element 2.10.]{.underline} Has the SEA identified and
provided technical assistance to LEAs that are not making progress
toward meeting their annual measurable objectives in meeting the highly
qualified teacher challenge?**

**[Recommendation:]{.underline}** ISBE requires LEAs, as part of the
consolidated application for funding, to include a professional
development component. ISBE should use this indicator and highly
qualified teacher data to target those LEAs who are not making progress
toward the statewide annual measurable objectives in meeting the highly
qualified teacher requirements for technical assistance.

**[Commendation:]{.underline}** In 2004, Illinois passed a state law
that requires LEAs with a shortage of highly qualified teachers, as
defined by NCLB, to use at least 40 percent of Title II, Part A funding
to address that shortage.

**[Area 3: State Activities]{.underline}**

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

**[Recommendation:]{.underline}** ISBE experiences routine carryover and
an under-use of State activities funds. The State is encouraged to
improve strategic planning and align State Activities funds more closely
with the statewide needs assessment.

**[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 Illinois Community College Board
(ICCB) is commended for their work with paraprofessionals in the State.
ICCB is collaborating between the community college system and ISBE to
work with paraprofessionals, offering test preparation and coursework
toward degree programs.

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

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

**[Commendation:]{.underline}** The Illinois Board of Higher Education
(IBHE) is commended for the quality of the peer review process they used
to evaluate grant applications. IBHE selected a group of assessors from
across the State that had significant professional development
experience in both content areas and professional knowledge. The
assessors were trained on the review instrument, then reviewed grant
applications and made their recommendations to BHE.

**[Commendation:]{.underline}** The SAHE offers annual symposiums for
grantees to learn and share best practices, and to gather information on
the grant process.

**[Commendation]{.underline}:** The SAHE works in collaboration with
ISBE to fund projects that address statewide need areas and to avoid
duplicate funding to the same grantees. The SAHE works to fund programs
that support professional development, curriculum, and delivery
structures that can support State goals.

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