HIGHLY QUALIFIED TEACHERS AND

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

MONITORING REPORT

**Montana Office of Public Instruction (OPI)**

**April 8-9, 2008**

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

Jessica Clark

Allison Henderson (Westat)

Carrie Murthy (Westat)

**Montana Office of Public Instruction (OPI):**

Linda McCulloch, Superintendent of Public Instruction

Nancy Coopersmith, Assistant Superintendent

Bob Runkel, Assistant Superintendent

Bud Williams, Deputy Superintendent

Pat Johnson, *ESEA* Title II Specialist (LEA Grants Administration)

BJ Granbery, Educational Opportunity and Equity (EOE) Division
Administrator, ESEA Title I Director

Al McMilin, Educator Quality Program Specialist (State-Level Activities)

Linda Peterson, Accreditation Division Administrator

Tim Harris, Special Education Division Administrator

Kim Warrick, Middle School/At Risk Specialist

Julia Dilly, Centralized Services Division Administrator

Linda Gardner, Computer Systems Analyst

Elizabeth Keller, Education Licensure Manager

**State Agency for Higher Education:**

Jan Clinard, Academic Initiatives Director, Office of the Commissioner
of Higher Education

**LEAs participating in the monitoring visit**

1.  Great Falls Public Schools (on-site visit)

2.  Wolf Point Public Schools (telephone interview)

3.  Billings Public Schools (telephone interview)

Overview:

Number of LEAs 432

Number of Schools 831

Number of Teachers 10,472

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

  LEA Allocation (FY      \$13,068,445       LEA Allocation (FY 2006) \$12,933,342
  2005)                                                               

  "State Activities" (FY  \$343,906          "State Activities (FY    \$340,351
  2005)                                      2006)                    

  SAHE Allocation (FY     \$343,906          SAHE Allocation (FY      \$340,351
  2005)                                      2006)                    

  SEA Administration (FY  \$121,561          SEA Administration (FY   \$120,124
  2005)                                      2006)                    

  SAHE Administration (FY \$17,391           SAHE Administration (FY  \$17,391
  2005)                                      2006)                    
  ----------------------- ------------------ ------------------------ ------------------

**Scope of Review:**

Like all State educational agencies (SEAs), the Montana Office of Public
Instruction, 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 Montana had two purposes. One was
to review the progress of the State in meeting the *ESEA's* HQT
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**

  ------------- ------------------------------- -------------------- -------------- ----------
  State                                                                             
  Educational                                                                       
  Agency                                                                            

  **Critical    **Requirement**                 **Citation**         **Status**     **Page**
  Element**                                                                         

  I.1.          The State has established       §9101(23)            Finding        4
                appropriate HQT requirements                                        
                for all teachers who teach core                                     
                subjects.                                                           

  I.2.          The State has established       §602(10) of the IDEA Finding        5
                appropriate HQT requirements                                        
                for *special* *education*                                           
                *teachers who teach core                                            
                academic subjects.*                                                 

  I.3.          Teachers who are enrolled in    (34 CFR              Finding        5
                approved alternative            200.56(a)(2)(ii))                   
                certification programs AND who                                      
                have already earned a                                               
                bachelor's degree AND                                               
                successfully demonstrated                                           
                subject matter competence may                                       
                be counted as highly qualified                                      
                for a period of three years.                                        

  I.4.          The SEA ensures that all        §1119(a)(1)          Finding        6
                teachers hired after the first                                      
                day of the 2002-2003 school                                         
                year to teach in Title I                                            
                programs were highly qualified                                      
                at the time of hire.                                                

  I.5.          The SEA ensures that all        §2123(a)(2)(B)       Met            NA
                teachers paid with Title II,                         Requirements   
                Part A funds for class size                                         
                reduction are highly qualified.                                     

  I.6.          The SEA ensures that all LEAs   §1111(h)(6)(A)       Met            NA
                that receive Title I funds                           Requirements   
                notify parents of their right                                       
                to request and receive                                              
                information on the                                                  
                qualifications of their                                             
                children's teachers.                                                

  I.7.          The SEA ensures that all        §1111(h)(6)(B)(ii)   Finding        6
                schools that receive Title I                                        
                funds notify parents when their                                     
                children are taught by teachers                                     
                who are not highly qualified.                                       
  ------------- ------------------------------- -------------------- -------------- ----------

+-----+------------------------------+-------------+------------+-----+
| I   | The SEA reports annually to  | §11         | Finding    | 6   |
| I.A | the Secretary in the         | 11(h)(4)(G) |            |     |
| .1. | Consolidated Performance     |             |            |     |
|     | Report (CSPR) the number and |             |            |     |
|     | percentage of classes taught |             |            |     |
|     | by highly qualified          |             |            |     |
|     | teachers, in the aggregate   |             |            |     |
|     | and in high- and low-poverty |             |            |     |
|     | schools.                     |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has published an     | §1111(h)(   | Finding    | 7   |
| I.B | annual report card with the  | 1)(C)(viii) |            |     |
| .1. | required teacher             |             |            |     |
|     | information.                 |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has ensured that     | §11         | Met        | NA  |
| I.B | LEAs have published annual   | 11(h)(2)(B) | Re         |     |
| .2. | report cards with the        |             | quirements |     |
|     | required teacher information |             |            |     |
|     | for both the LEA and the     |             |            |     |
|     | schools it serves.           |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA ensures that each    | §2141(a)    | Finding    | 7   |
| I.A | LEA that has not met annual  | and         |            |     |
| .1. | measurable objectives for    | §2141(b)    |            |     |
|     | highly qualified teachers    |             |            |     |
|     | for two consecutive years    |             |            |     |
|     | has an improvement plan in   |             |            |     |
|     | place and that the SEA has   |             |            |     |
|     | provided technical           |             |            |     |
|     | assistance to the LEA in     |             |            |     |
|     | formulating the plan.        |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA enters into an       | §2141(c)    | Finding    | 7   |
| I.A | agreement on the use of      |             |            |     |
| .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 place  | §11         | Recom      | 8   |
| I.B | to ensure that poor and      | 11(b)(8)(C) | mendations |     |
| .1. | minority students are not    |             |            |     |
|     | taught at higher rates than  |             |            |     |
|     | other students by            |             |            |     |
|     | inexperience, unqualified,   |             |            |     |
|     | or out-of-field teachers.    |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| II  | The SEA ensures that LEA     | §11         | Met        | NA  |
| I.B | plans include an assurance   | 12(c)(1)(L) | Re         |     |
| .2. | that through the             |             | quirements |     |
|     | implementation of various    |             |            |     |
|     | strategies, poor and         |             |            |     |
|     | minority students are not    |             |            |     |
|     | taught at higher rates than  |             |            |     |
|     | other students by            |             |            |     |
|     | inexperienced, unqualified,  |             |            |     |
|     | or out-of-field teachers.    |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | Once hold harmless           | §2121(a)    | Met        | NA  |
| V.A | provisions are taken into    |             | Re         |     |
| .1. | consideration, the SEA       |             | quirements |     |
|     | allocated additional funds   |             |            |     |
|     | to LEAs using the most       |             |            |     |
|     | recent Census Bureau data    |             |            |     |
|     | found at                     |             |            |     |
|     | <http://www.census.gov/hh    |             |            |     |
|     | es/www/saipe/district.html>. |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has ensured that     | §2122(c)    | Met        | NA  |
| V.A | LEAs have completed          |             | Re         |     |
| .2. | assessments of local needs   |             | quirements |     |
|     | for professional             |             |            |     |
|     | development.                 |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | To be eligible for Title II, | §2122(b)    | Met        | NA  |
| V.A | Part A funds, LEAs must      |             | Re         |     |
| .3. | "submit an application to    |             | quirements |     |
|     | the State educational agency |             |            |     |
|     | at such time, in such        |             |            |     |
|     | manner, and containing such  |             |            |     |
|     | information as the State     |             |            |     |
|     | educational agency may       |             |            |     |
|     | reasonably require."         |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA has ensured that     | §9521       | Met        | NA  |
| V.B | LEAs maintain effort.        |             | Re         |     |
| .1. |                              |             | quirements |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that LEA     | §2123(b)    | Met        | NA  |
| V.B | funds do not supplant other, |             | Re         |     |
| .2. | non-Federal funds.           |             | quirements |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA and LEAs are         | EDGAR       | Met        | NA  |
| V.B | audited, as required by      | §80.26      | Re         |     |
| .3. | EDGAR §80.26.                |             | quirements |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA regularly and        | EDGAR       | Reco       | 8   |
| V.B | systematically monitors LEAs | §76.770 and | mmendation |     |
| .4. | for compliance with Federal  | §80.40(a)   |            |     |
|     | statutes and regulations,    |             | Co         |     |
|     | applicable State rules and   |             | mmendation |     |
|     | policies, and the approved   |             |            |     |
|     | sub grantee application, as  |             |            |     |
|     | required by EDGAR §76.770    |             |            |     |
|     | and §80.40(a).               |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| I   | The SEA ensures that LEAs    | §9501       | Met        | NA  |
| V.B | comply with requirements     |             | Re         |     |
| .5. | with regards to services to  |             | quirements |     |
|     | eligible nonpublic schools.  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| V   | The SEA ensures that state   | §2113(c)    | Met        | NA  |
| .1. | level activity funds are     |             | Re         |     |
|     | expended on allowable        |             | quirements |     |
|     | activities.                  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| V   | The SEA ensures that state   | §2113(f)    | Met        | NA  |
| .2. | level activity funds do not  |             | Re         |     |
|     | supplant other, non-Federal  |             | quirements |     |
|     | funds.                       |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| *   |                              |             |            |     |
| *St |                              |             |            |     |
| ate |                              |             |            |     |
| Age |                              |             |            |     |
| ncy |                              |             |            |     |
| for |                              |             |            |     |
| Hig |                              |             |            |     |
| her |                              |             |            |     |
| Ed  |                              |             |            |     |
| uca |                              |             |            |     |
| tio |                              |             |            |     |
| n** |                              |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| *   | **Requirement**              | *           | **Status** | **  |
| *Cr |                              | *Citation** |            | Pag |
| iti |                              |             |            | e** |
| cal |                              |             |            |     |
| Ele |                              |             |            |     |
| men |                              |             |            |     |
| t** |                              |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 1\. | The SAHE manages a           | §2132 and   | Met        | NA  |
|     | competition to award grants  | §2133       | Re         |     |
|     | to carry out appropriate     |             | quirements |     |
|     | professional development     |             |            |     |
|     | activities.                  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 2\. | The SAHE works in            | §2132(a)    | Met        | NA  |
|     | conjunction with the SEA (if |             | Re         |     |
|     | the two are separate         |             | quirements |     |
|     | agencies) in awarding the    |             |            |     |
|     | grants.                      |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 3\. | The SAHE awards grants only  | §2131       | Met        | NA  |
|     | to eligible partnerships     |             | Re         |     |
|     | that include at least an     |             | quirements |     |
|     | institution of higher        |             |            |     |
|     | education and the division   |             |            |     |
|     | of the institution that      |             |            |     |
|     | prepares teachers and        |             |            |     |
|     | principals; a school of arts |             |            |     |
|     | and sciences; and a          |             |            |     |
|     | high-need LEA.               |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 4\. | The SAHE ensures that each   | §2134       | Met        | NA  |
|     | partnership awarded a grant  |             | Re         |     |
|     | engages in eligible          |             | quirements |     |
|     | activities.                  |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 5\. | The SAHE has procedures in   | §2132(c)    | Met        | NA  |
|     | place to ensure that no      |             | Re         |     |
|     | partner uses more than 50    |             | quirements |     |
|     | percent of the funds in the  |             |            |     |
|     | grant.                       |             |            |     |
+-----+------------------------------+-------------+------------+-----+
| 6\. | The SAHE regularly and       | EDGAR       | Met        | NA  |
|     | systematically monitors      | §76.770 and | Re         |     |
|     | grantees for compliance with | §80.40(a)   | quirements |     |
|     | Federal statutes and         |             |            |     |
|     | regulations, applicable      |             |            |     |
|     | State rules and policies,    |             |            |     |
|     | and the approved sub grantee |             |            |     |
|     | application, as required by  |             |            |     |
|     | EDGAR §76.770 and §80.40(a)  |             |            |     |
+-----+------------------------------+-------------+------------+-----+

**Area I: HQT Definitions and Procedures**

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

**[Citation]{.underline}:** §9101(23)

**[Finding]{.underline}:** To be considered highly qualified, the State
requires all secondary teachers to hold a major in their primary
assignment area. However, secondary teachers may add an additional
endorsement with 20-24 semester credits in an approved minor. By itself,
a minor does not meet the minimum requirements of a subject-area major
or coursework equivalent to a major that the *ESEA* establishes for
secondary teachers.

**[Further Action Required]{.underline}:** Within 30 business days, the
State must submit a plan and timeline to ensure that all secondary
teachers complete a subject-area major or coursework equivalent to a
major in their primary assignment area, as established in the *ESEA*.
The State must also provide the Department with evidence that it is
taking this corrective action.

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

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

**[Finding]{.underline}:** OPI has not determined the highly qualified
status of special education teachers who provide direct instruction to
students in the core academic areas. These teachers currently are
excluded from the counts of classes taught by highly qualified teachers.

**[Further Action Required]{.underline}:** Within 30 business days, the
State must submit a plan and timeline establishing uniform corrective
action procedures to ensure that the highly qualified status of special
education teachers who teach core classes is correctly determined as
quickly as possible in a manner approved by statute and that the status
of these teachers is included in the State's reported HQT data. The
submitted plan and timeline must be written to include the required
reports and deadlines described below.

The State must provide the Department with evidence that it is taking
this corrective action. This evidence will be provided in formal reports
of progress that are due to the Department on October 1, 2008; February
11, 2009; and May 30, 2009. The reports should detail progress the State
has made in the following areas:

-   Notifying LEAs that the HQ status of special education teachers who
    teach core subject classes must be determined;

-   Assessing the HQ status of all special education teachers who teach
    core subject classes;

-   Notifying parents, as required, when special education teachers who
    are not HQ teach their children.

In addition, the report that is due on May 30, 2009, should include
preliminary HQT data for the 2008-09 school year. **By the time the May
report is submitted, the** **State must have completed the process of
determining the highly qualified status of all special education
teachers who teach core subjects**. The State is further expected to
submit, via the December 2009 CSPR*,* final HQT data for the 2008-09
school year. The data submitted in the CSPR must be accurate and
complete and include all special education classes in the core subject
areas.

**[Critical Element I.3]{.underline}: Teachers who are enrolled in
approved alternative certification programs AND who have already earned
a bachelor's degree AND successfully demonstrated subject matter
competence may be counted as highly qualified for a period of three
years.**

**[Citation]{.underline}:** (34 CFR 200.56(a)(2)(ii))

**[Finding]{.underline}:** Elementary teachers employed on a Class 5
Alternative License are not required to demonstrate subject matter
competence prior to being counted as highly qualified for their
classroom assignments.

**[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 ensuring that
elementary teachers employed on a Class 5 Alternative License are
required to demonstrate subject matter competency prior to being counted
as highly qualified for their classroom assignments. The State must
provide the Department with evidence that it is taking this corrective
action.

**[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}:** Because of the definitional issues discussed
above in I.1, I.2, and I.3, 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 were 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.7]{.underline}: The SEA ensures that all schools
that receive Title I funds notify parents when their children are taught
by teachers who are not highly qualified.**

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

**[Finding]{.underline}:** Because of the definitional issues discussed
above in I.1, I.2, and I.3, the State cannot ensure that schools that
receive Title I funds are notifying parents when their children are not
taught by highly qualified teachers.

**[Further Action Required]{.underline}:** As outlined in Critical
Element I.2, within 30 business days, the State must submit a written
plan and a timeline that includes provisions for notifying parents, as
required, when their children are taught by teachers who are not highly
qualified. The State's progress in taking this corrective action must be
formally reported as required in Critical Element I.2.

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

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

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

**[Finding]{.underline}:** Because the State is out of compliance on the
definition of highly qualified teachers, including the exclusion of
special education teachers from the HQT process, the HQT data included
in the CSPR are incorrect.

**[Further Action Required]{.underline}:** As outlined in Critical
Element I.2, within 30 business days, the State must submit a written
plan and a timeline for correcting its HQT data. Within 30 business
days, the State must also provide an assurance that it will submit final
HQT data for the 2008-09 school year in the 2009 CSPR, and that the data
will be accurate and complete and include all special education classes
in the core subject areas. The State's progress in taking this
corrective action must be formally reported as required in Critical
Element I.2.

**[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}:** Because the State is out of compliance on the
definition of highly qualified teachers, including the exclusion of
special education teachers from the HQT process, the HQT data included
in the State Report Card are incorrect.

**[Further Action Required]{.underline}:** To correct data errors in the
Annual State Report Card, the State must, within 30 business days,
submit to ED a written plan with specific procedures and a timeline the
State will implement to ensure that HQT data reported in future Annual
State Report Cards are correct. Accurate and complete data must be
collected in accordance with the timeline outlined in Critical Element
I.2 and, when available, must be included in the annual report card.

**Area III: HQT Plans**

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

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

**[Finding]{.underline}:** Because the State is out of compliance on the
definition of highly qualified teachers, including the exclusion of
special education teachers from the HQT process, it cannot accurately
determine whether each LEA has met annual measurable goals for highly
qualified teachers for two consecutive years. Therefore, the State
cannot meet the requirements for §2141(a) and §2141(b).

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

[]{.mark}

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

**[Citation]{.underline}:** §2141(c)

[]{.mark}

**[Finding]{.underline}:** Because the State is out of compliance on the
definition of highly qualified teachers, including the exclusion of
special education teachers from the HQT process, it cannot accurately
determine whether each LEA has met annual measurable goals for highly
qualified teachers for three consecutive years. Therefore, the State
cannot meet the requirements for §2141(c).

**[Further Action Required]{.underline}:** Within 30 days, the State
must provide a written plan and a timeline for determining any LEAs that
currently have not made progress on meeting their HQT annual measurable
objectives for three consecutive years and have also failed to make AYP
for three years. The State must also provide a plan and a timeline for
ensuring that the SEA enters into the required agreements on the use of
funds with any LEAs not meeting these objectives for three consecutive
years

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

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

**[Recommendation 1]{.underline}:** The State should officially update,
on a regular basis, its plan to ensure that poor and minority students
are not taught at higher rates than other students by inexperienced,
unqualified or out-of-field teachers. The State should ensure that it
regularly updates its data on the distribution of teachers and its
strategies to address any inequities that become evident.

**[Recommendation 2]{.underline}:** The State should include in its
monitoring procedures provisions to ensure that the equity plan
assurances and the strategies that the LEAs have described in their
plans are being carried out.

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

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

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

**[Recommendation]{.underline}:** The State is in the process of
developing a new system for monitoring LEAs for compliance with Federal
statutes, including Title II, Part A. It is recommended that the State
continue working with other program offices such as Title I to develop a
comprehensive monitoring system that includes a plan and schedule for
regular site visits and desk monitoring of all LEAs. In addition, the
plan should consider random monitoring of a certain number of LEAs and
regular monitoring of LEAs that receive large amounts of Title II, Part
A funding and/or have persistent issues with hiring highly qualified
teachers.

**[Commendation]{.underline}:** The State is commended for E-Grants, its
online consolidated application and financial management system.
E-Grants supports the grant application process from allocation of funds
and application for funding through payment accountability, reporting to
the grantor and grant closeout for both state and federal grants. The
user-friendly system allows the SEA to monitor LEA expenditures and LEA
progress on hiring qualified personnel.

[^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.