United States Government Accountability Office

GAO Report to Congressional Requesters

READING FIRST

States Report 

Improvements in 

Reading Instruction, 

but Additional 

Procedures Would 

Clarify Education's 

Role in Ensuring 

Proper 

Implementation by 

States 

February 2007 

 

GAO-07-161 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2007

READING FIRST

States Report Improvements in Reading 

Instruction, but Additional Procedures 

Would Clarify Education's Role in 

Ensuring Proper Implementation by 

States 

Highlights of GAO-07-161, a report to 

congressional requesters 

The Reading First program was

designed to help students in

kindergarten through third grade 

develop stronger reading skills. 

This report examines the

implementation of the Reading

First program, including (1)

changes that have occurred to

reading instruction; (2) criteria 

states have used to award subgrants to districts, and the 

difficulties, if any, states faced 

during implementation; and (3) the 

guidance, assistance, and oversight 

the Department of Education 

(Education) provides states. 

GAO’s study is designed to

complement several studies by 

Education’s Inspector General (IG)

in order to provide a national 

perspective on some of the specific

issues being studied by the IG. For 

this report, GAO administered a

Web-based survey to 50 states and

the District of Columbia, and 

conducted site visits and interviews

with federal, state, and local 

education officials and providers of 

reading programs and assessments. 

What GAO Recommends

GAO recommends that Education 

establish control procedures to

guide departmental officials and 

contractors in their interactions 

with states, districts, and schools 

to ensure compliance with 

statutory provisions. GAO also

recommends that Education 

establish and disseminate clear

procedures governing its

monitoring process. Education, in 

its response to a draft of this 

report, agreed with GAO’s 

recommendations. 

States reported that there have been a number of changes to, as well as 

improvements in, reading instruction since the implementation of Reading 

First. These included an increased emphasis on the five key components of 

reading (awareness of individual sounds, phonics, vocabulary development, 

reading fluency, and reading comprehension), assessments, and professional 

development with more classroom time being devoted to reading activities. 

However, according to publishers we interviewed, there have been limited 

changes to instructional material. Similarly, states report that few changes 

occurred with regard to their approved reading lists. 

States awarded Reading First sub-grants using a variety of different 

eligibility and award criteria, and some states reported difficulties with 

implementing key aspects of the program. After applying federal and state 

eligibility and award criteria, Education reported that over 3,400 districts 

were eligible to apply for sub-grants in the states’ first school year of 

funding. Of these districts, nearly 2,100 applied for and nearly 1,200 districts 

received Reading First funding. (See figure for percentages.) 

Education officials made a variety of resources available to states during the

application and implementation processes, and states were generally

satisfied with the guidance and assistance they received. However, 

Education developed no written policies and procedures to guide Education 

officials and contractors in their interactions with state officials and guard 

against officials mandating or directing states’ decisions about reading 

programs or assessments, which is prohibited by NCLBA and other laws. 

Based on survey results, some state officials reported receiving suggestions 

from Education officials or contractors to adopt or eliminate certain reading 

programs or assessments. Similarly, the IG reported in September 2006 that 

the Department intervened to influence a state’s and several school districts’ 

selection of reading programs. In addition, while Education officials laid out 

an ambitious plan for annual monitoring of every state’s implementation, 

they did not develop written procedures guiding monitoring visits and, as a 

result, states did not always understand monitoring procedures, timelines, 

and expectations for taking corrective actions. 

Percentages of Eligible, Applicant and Awarded Districts Nationwide During States’ First 

School Year of Funding

Eligible Reading First Districts (20% of 

all districts nationwide)

Eligible that applied for Reading First sub-grants

(12% of all districts nationwide)

Eligible Districts awarded Reading First sub-grants

(7% of all districts nationwide)

 

Source: GAO analysis based on U.S. Department of Education data.

34%

62%

100%

www.gao.gov/cgi-bin/getrpt?GAO-07-161.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia Ashby 

at (202) 512-8403 or ashbyc@gao.gov. 
Contents 

Letter 1

Results in Brief 5 

Background 7

States Reported Changes as Well as Improvements in Reading 

Instruction Since the Inception of Reading First 13 

States Awarded Reading First Sub-Grants to School Districts Using 

a Variety of Different Criteria, and Some States Reported 

Difficulties with Implementation 20 

Education Provided a Wide Range of Guidance, Assistance, and 

Oversight, Generally Satisfying State Officials, but Education 

Lacked Controls to Guard against Mandating or Endorsing 

Curricula and Did Not Provide Written Monitoring Procedures 24 

Conclusions 35

Recommendations 36

Agency Comments 36 

Appendix I Objectives, Scope, and Methodology 38 

Appendix II Descriptions of Assessment Types 41 

Appendix III Comments from the Department of Education 42 

Appendix IV GAO Contacts and Staff Acknowledgments 53 

Tables 

Table 1: Reading Program Publishers Most Frequently Represented 

on States’ Approved Lists 18 

Table 2: Approaches States Used to Develop Their Approved Lists 19 

Table 3: Guidance and Assistance Provided to States during 

Application and Implementation Processes 27 

Table 4: States’ Reported Sources of Guidance for Key Reading 

First Implementation Components 31 

Page i GAO-07-161 Reading First
Figures 

Figure 1: The Process for Awarding State Sub-grants to School 

Districts 11

Figure 2: Improvements in Professional Development for Reading 

First Teachers 16 

Figure 3: All School Districts Nationwide That Were Eligible for, 

That Applied for, and Were Awarded Reading First Subgrants in the First School Year of Funding 22 

Figure 4: States Level of Ease or Difficulty Implementing Key

Reading First Program Aspects 23 

Figure 5: Issues Education Raised About States’ Reading First 

Applications 25

Figure 6: Geographic Regions for Reading First Regional Technical 

Assistance Centers 26 

Figure 7: States’ Assessment of Whether Written Guidance 

Provided Information Needed to Adequately Address 

Application Components 30 

Page ii GAO-07-161 Reading First
Abbreviations 

AIR American Institutes for Research 

CRRFTAC Central Regional Reading First Technical Assistance 

 Center

DEOA Department of Education Organizing Act 

DIBELS Dynamic Indicators of Basic Early Literacy Skills 

Education Department of Education 

ERRFTAC Eastern Regional Reading First Technical 

 Assistance Center 

IG Inspector General 

Interim Report Education’s Reading First Implementation 

 Evaluation: Interim Report 

K-3rd kindergarten through third grade 

NCLBA No Child Left Behind Act

NIFL National Institute for Literacy 

RMC RMC Research Corporation 

SEA state education agency 

SBRR scientifically-based reading research

TAC Technical Assistance Center 

WRRFTAC Western Regional Reading First Technical 

 Assistance Center 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page iii GAO-07-161 Reading First
United States Government Accountability Office

Washington, DC 20548 

 

February 28, 2007 

The Honorable Edward M. Kennedy 

Chairman 

The Honorable Michael B. Enzi 

Ranking Minority Member 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Edward M. Kennedy 

Chairman 

The Honorable Michael B. Enzi 

Ranking Minority Member 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable George Miller 

Chairman 

Committee on Education and Labor

House of Representatives 

The Honorable George Miller 

Chairman 

Committee on Education and Labor

House of Representatives 

The Honorable Jeff Bingaman 

United States Senate 

The Honorable Richard G. Lugar 

United States Senate 

The Reading First program, signed into law in 2002 as part of the No Child 

Left Behind Act (NCLBA), was designed based on reading research to help 

children in kindergarten through third grade develop stronger reading 

skills. Since 2002, Congress has appropriated about $1 billion a year for 

Reading First, more than for any other federal reading program, to fund 6-

year grants to states. States, in turn, have awarded sub-grants to school 

districts to establish reading programs. These sub-grants are targeted to

districts and schools with the highest percentage or numbers of students 

in kindergarten through third (K-3rd) grade reading below grade level and 

to districts and schools with large numbers of low-income students. 

However, in awarding sub-grants, states do have some discretion to 

establish priorities, such as giving priority to districts that demonstrated 

leadership and commitment to improving reading.

The Reading First program, signed into law in 2002 as part of the No Child 

Left Behind Act (NCLBA), was designed based on reading research to help 

children in kindergarten through third grade develop stronger reading 

skills. Since 2002, Congress has appropriated about $1 billion a year for 

Reading First, more than for any other federal reading program, to fund 6-

year grants to states. States, in turn, have awarded sub-grants to school 

districts to establish reading programs. These sub-grants are targeted to

districts and schools with the highest percentage or numbers of students 

in kindergarten through third (K-3rd) grade reading below grade level and 

to districts and schools with large numbers of low-income students. 

However, in awarding sub-grants, states do have some discretion to 

establish priorities, such as giving priority to districts that demonstrated 

leadership and commitment to improving reading.

The Reading First program places a number of requirements on state and

local grant recipients to ensure they adopt reading programs and methods 

that are effective, while, at the same time, NCLBA provisions restrict the 

ability of Department of Education (Education) officials to mandate or 

direct state and local decisions on reading curriculum. In particular, 

Reading First requires states and participating school districts to adopt 

scientifically-based reading programs containing key instructional 

components identified in the law. In some instances, state officials have 

The Reading First program places a number of requirements on state and

local grant recipients to ensure they adopt reading programs and methods 

that are effective, while, at the same time, NCLBA provisions restrict the 

ability of Department of Education (Education) officials to mandate or 

direct state and local decisions on reading curriculum. In particular, 

Reading First requires states and participating school districts to adopt 

scientifically-based reading programs containing key instructional 

components identified in the law. In some instances, state officials have 

Page 1 GAO-07-161 Reading First
required prospective Reading First districts to choose their reading 

program from a state-approved list. In contrast, other states have opted to

vest district applicants with responsibility for researching and selecting 

the reading programs to be used in their Reading First schools. States and

participating school districts are also required to provide professional 

development in reading that is based on scientific research and to track 

students’ progress in reading using valid and reliable assessments. 

However, NCLBA and various other statutory provisions place limits on 

what Education officials can require states, districts, and schools to do. 

For example, under NCLBA, Education officials are not authorized to 

mandate, direct, or control state, school district or school curriculum or 

program of instruction.1

 In other words, these provisions are intended to 

preserve state and local control over key aspects of the public school 

system. 

During the implementation of the Reading First program some concerns 

were raised by publishers of reading programs to Congress and others 

about Education’s interactions with state and local grantees regarding 

reading programs and assessments. Specifically, several groups 

representing reading programs filed complaints with Education’s 

Inspector General alleging that Education officials, contractors, and 

consultants pressured state and local applicants to choose specific reading 

programs and assessments—actions that are expressly prohibited by 

NCLBA. 

In response to these allegations, Education’s Inspector General (IG) 

undertook several separate investigations and audits of various aspects of 

the program’s administration. For the first of these reports, issued in 

September 2006, the IG reviewed various aspects of the application 

process for awarding Reading First grants to states, including the selection 

and composition of the expert panel that reviewed state applications, 

application review and feedback procedures, and interactions between 

Education and state-level officials.2

 During its review, the IG, among other 

things, interviewed federal and selected state officials and reviewed 

departmental guidance, internal e-mail correspondence, and state 

applications from 11 states and 1 territory. Among its findings, the IG 

reported that the Department intervened to influence a state’s and several 

 1

 20 U.S.C. § 7907. 

2

 U.S. Department of Education Inspector General, The Reading First Program’s Grant 

Application Process: Final Inspection Report (Washington D.C.: September 2006).

Page 2 GAO-07-161 Reading First
school districts’ selection of reading programs, actions that call into 

question whether program officials violated statutory prohibitions against 

directing or controlling state and local curricular decisions. 3 The IG made 

a number of related recommendations, including that the Department 

should (1) develop internal management policies and procedures to ensure 

that programs are managed in compliance with applicable laws and 

regulations, (2) review the management and staff structure of the Reading

First program office, and (3) develop guidance for program officials on 

statutory prohibitions on intervening in state and local curricular 

decisions. The Secretary of Education concurred with all of the report’s 

recommendations. 4 In their written comments to the IG report, Education 

officials detailed numerous action steps they planned to undertake in 

response to the report’s findings and recommendations, including the 

appointment of new internal leadership for the Reading First program,5

 

the development of annual training on internal controls, and the drafting 

of a memorandum for all program managers regarding the importance of 

impartial job performance. 

GAO’s study is designed to complement the IG’s work by providing a 

national perspective on some of the specific issues being studied by the 

IG, as well as providing some information on how the program has been 

implemented at the state level, primarily. To obtain a better understanding 

of how the Reading First program is being implemented at the state level 

and to determine how Education conducts its interactions with states and 

the kind of guidance and oversight it provides, GAO agreed to answer the 

following questions: 

1. What changes have occurred to reading instruction since the inception 

of Reading First? 

 3

 Section 103(b) of the Department of Education Organizing Act (DEOA) states that “No 

provision of a program administered by the Secretary or by any other officer of the

Department shall be construed to authorize the Secretary or any such officer to exercise

any direction, supervision, or control over the curriculum, program of instruction, 

administration, or personnel of any educational institution, school or school system....over 

the selection or content of...textbooks, or other instructional materials by any educational 

institution or school system, except to the extent authorized by law.” 20 U.S.C. § 3403(b).

4

 The Office of Management and Budget, in its Circular A-50, requires federal agencies to 

establish audit follow-up systems that ensure that audit findings and recommendations are

addressed. Under Circular A-50, audit follow-up is a shared responsibility of agency 

management and the auditors. 

5

 The Reading First Program Director resigned following publication of the Final Inspection 

Report. 

Page 3 GAO-07-161 Reading First
2. What criteria have states used to award Reading First sub-grants to 

districts, and what, if any, difficulty did states face in implementing the 

program? 

3. What guidance, assistance, and oversight did Education provide states 

related to the Reading First program? 

To answer these questions, we collected information about the Reading 

First program from a variety of sources. We conducted a Web-based 

survey of the Reading First Directors in all 50 states and the District of 

Columbia, and 100 percent responded. We also obtained and analyzed data

from the Department of Education for each state on Reading First 

districts’ eligibility, applications, and awards for states’ first school year of 

funding. To assess the reliability of this data, we talked to agency officials 

about data quality control procedures and reviewed relevant 

documentation. We also conducted semi-structured follow-up interviews 

with Reading First Directors in 12 states and conducted site visits to 4 of 

the 12 states. During the site visits, we met with state and district officials,

as well as school officials, including teachers, principals, and Reading First 

coaches. We selected these 12 states to represent diversity in terms of 

geographic distribution, grant size, poverty rates, and student reading 

achievement, as well as the presence or absence of a statewide list of 

approved reading programs. In our selection of the 12 states, we also took 

into consideration whether or not state officials reported that they had

received guidance from Education officials advocating for or against 

particular reading programs or assessments. For both the survey and 

follow-up interviews, we agreed to protect the respondents’ confidentiality 

to encourage candid responses: therefore; we will not identify states by 

name in this report. We also interviewed administrators from each of the 

three regional Reading First Technical Assistance Centers (TAC), officials 

from RMC Research—which provided technical assistance to states during 

the application process and oversaw the TACs, and the American 

Institutes for Research (AIR)—the contractor responsible for conducting 

monitoring visits in each state. In addition, we interviewed several 

publishers and other providers of reading curricula and assessments, as 

well as Reading First officials and attorneys at Education. We also 

reviewed state grant files, monitoring reports, and related correspondence 

for the 12 states where we conducted follow-up interviews, as well as 

legislation and guidance related to Reading First. We also interviewed 

Education officials about the implementation of the Reading First 

program. Finally, we reviewed Education’s study “Reading First 

Implementation Evaluation: Interim Report” to identify information 

collected at the district and school level that related to the findings from 

Page 4 GAO-07-161 Reading First
our state survey and also the two relevant reports that had been issued by 

Education’s Inspector General at the time our audit work was completed. 

See appendix I for additional information on the survey, as well as our 

other data collection methods. We conducted our work from December 

2005 through January 2007 in accordance with generally accepted 

government auditing standards. 

Since the inception of Reading First, states reported changes as well as 

improvements in reading instruction due to increased emphasis on reading 

instruction, assessments, and professional development, despite limited 

changes to instructional material. In our survey, 69 percent of all states 

reported great or very great improvement in reading instruction. One 

specific area in which states reported an improvement is the degree to 

which classroom instruction explicitly incorporates the key instructional 

components of the program. In addition, state and local officials we 

interviewed reported that the use of assessments changed after Reading 

First, especially in the way that teachers use data from these assessments 

to better inform reading instruction. All states reported improvement in 

professional development with more than 80 percent of states reporting 

that professional development for reading teachers improved greatly or 

very greatly. Further, over 75 percent of states reported great or very great

increases in the frequency of and resources devoted to teacher 

professional development. At the same time, the publishers we 

interviewed reported making few significant changes to instructional 

materials as a result of Reading First. While three of the four major 

publishers reported that they had not made significant changes, some of 

these publishers stated that they had made minor changes to their reading 

materials to highlight the key instructional components of Reading First. 

Results in Brief 

States awarded Reading First sub-grants to districts using a variety of 

different eligibility and award criteria, and some states reported 

difficulties with implementing key aspects of the program. States varied in

how they defined and established eligibility and award criteria as 

permitted under Reading First. After applying eligibility criteria, Education 

reported that over 3,400 school districts—or about 20 percent of all 

districts nationwide—were eligible to apply for Reading First sub-grants in 

the states’ first school year of funding. After applying award criteria to the 

nearly 2,100 eligible districts that applied, Education reported that nearly 

1,200 school districts—or about 34 percent of all eligible districts and 

nearly 7 percent of all districts nationwide—received Reading First funds. 

With respect to implementation difficulties, 22 states reported that it was 

Page 5 GAO-07-161 Reading First
difficult or very difficult to help districts with reading scores that had not 

improved sufficiently. Furthermore, 17 states reported that it was either 

difficult or very difficult to assess how districts applied scientifically-based 

reading research in choosing their reading program. 

Education officials made a variety of resources available to states during 

the application and implementation process, including written guidance 

and criteria, workshops, conferences, dedicated contractors and regional 

technical assistance centers, as well as written feedback from both the 

application review panel and annual monitoring visits. States were 

generally satisfied with the various forms of Reading First guidance and 

assistance they received, but Education failed to establish controls to 

guard against mandating or directing curricula and clear monitoring 

procedures. For example, state officials were generally positive in 

characterizing the assistance they received from Education officials and 

contractors, with officials from 48 states reporting in our survey that 

Education staff were helpful or very helpful in addressing states’ 

implementation-related questions and officials from 41 states reporting the 

same for the TACs. However, Education developed no written or other 

formal guidance outlining policies and procedures to guide the behavior of

Education officials or contractors in providing Reading First guidance and 

assistance to states. Responses from several state officials suggest that 

Education officials may have violated the statutory prohibition against 

mandating or directing local curricular decisions by effectively endorsing 

or directing the selection of particular Reading First programs. According

to responses to our survey, Reading First officials or contractors made 

specific recommendations about reading programs and assessments to 

officials in several states. Specifically, officials from 10 states reported 

receiving suggestions that they eliminate specific programs or 

assessments, and officials from 4 states reported receiving suggestions to 

adopt specific programs or assessments. Five states also reported 

receiving recommendations from Reading First officials to change some of

their proposed professional development providers. In addition, while 

Education officials laid out an ambitious plan for annually monitoring 

every state’s implementation, Education did not develop transparent 

procedures to guide its monitoring visits and, as a result, states did not 

always understand monitoring procedures, timelines, and expectations. 

For example, officials from one state said they were unaware of 

Education’s expectation that states respond to monitoring findings, and 

officials from another state told us that Education officials never 

responded to the justification they submitted in response to specific 

monitoring findings. 

Page 6 GAO-07-161 Reading First
We are making two recommendations to Education. First, in addition to 

addressing the IG’s recommendations to develop internal (1) policies and 

procedures to guide program managers on when to solicit advice from 

General Counsel and (2) guidance on the prohibitions imposed by section 

103(b) of the Department of Education Organizing Act (DEOA), we 

recommend that Education also establish control procedures to guide 

departmental officials and contractors in their interactions with states, 

districts, and schools. We also recommend that Education develop and 

distribute guidelines regarding its monitoring procedures so that states 

and districts are aware of their roles, responsibilities, and timelines. In its 

comments on a draft of this report, Education agreed with our 

recommendations and indicated that it will take actions to address them. 

Reading First, which was enacted as part of NCLBA, aims to assist states 

and local school districts in establishing reading programs for students in 

kindergarten through third grade by providing funding through 6-year 

formula grants. The goal of the program is to ensure that every student can 

read at grade level or above by the end of third grade. To that end, Reading 

First provides funds and technical assistance to states and school districts 

to implement programs supported by scientifically-based reading research 

(SBRR), increase teacher professional development based on this 

research, and select and administer reading assessments to screen, 

diagnose, and monitor the progress of all students. NCLBA defines SBRR 

as research that (1) uses systematic, empirical methods that draw on 

observation or experiment; (2) involves rigorous data analyses that test 

stated hypotheses and justify general conclusions; (3) relies on

measurements or observational methods that are valid; and (4) has been

accepted by a peer-reviewed journal or approved by a panel of

independent experts. Further, NCLBA requires states to adopt reading 

programs that contain the five essential components of reading-- (1) 

phonemic awareness; (2) phonics; (3) vocabulary development; 

Background 

Page 7 GAO-07-161 Reading First
(4) reading fluency, including oral reading skills; and (5) reading 

comprehension strategies.6

While Education has responsibility for overseeing the Reading First 

program and states’ implementation and compliance with statutory and 

program requirements, NCLBA places restrictions on what Education 

officials can require states to do. Specifically, Education is not authorized 

to mandate, direct, control, or endorse any curriculum designed to be used 

in elementary or secondary schools.7

 Further, when Education was formed

in 1979, Congress was concerned about protecting state and local 

responsibility for education and, therefore, placed limits in Education’s 

authorizing statute on the ability of Education officials to exercise any 

direction, supervision, or control over the curriculum or program of 

instruction, the selection of textbooks or personnel, of any school or 

school system.8

Every state could apply for Reading First funds, and states were required 

to submit a state plan for approval that demonstrates how they will ensure 

that statutory requirements will be met by districts. Education, working in 

consultation with the National Institute for Literacy (NIFL), as required in

NCLBA, established an expert review panel composed of a variety of 

reading experts to evaluate state plans and recommend which plans 

should be approved. In these plans, states were required to describe how 

they would assist districts in selecting reading curricula supported by 

SBRR, valid and reliable9

 reading assessments, and professional 

development programs for K-3rd grade teachers based on SBRR. The law 

does not call for Education to approve or disapprove particular reading 

 6

 These components were identified as integral parts of effective reading programs by the 

National Reading Panel, or NRP. Phonemic awareness refers to the ability to hear, identify, 

and manipulate the individual sounds—phonemes—in spoken words. Phonics refers to the

relationship between the letters of written language and the sounds of spoken words. 

Vocabulary development refers to the development of stored information about the 

meanings and pronunciations of words necessary for communication. Reading fluency

refers to the ability to read text accurately and quickly. It provides a bridge between word 

recognition and comprehension. Reading comprehension refers to the understanding, 

remembering, and communicating with others about what has been read. 

7

 20 U.S.C. § 7907. 

8

 20 U.S.C. § 3403. 

9

 Data collected must be valid and reliable to be considered accurate. Valid refers to the 

degree that it actually measures what it claims to measure. Reliable refers to the degree to

which it consistently measures what it claims to measure. 

Page 8 GAO-07-161 Reading First
programs or curricula identified in state plans. When appropriate, the peer

review panel was to also recommend clarifications or identify changes it 

deemed necessary to improve the likelihood of a state plan’s success. 

NCLBA requires that Education approve each state’s application only if it 

meets the requirements set forth in the law. 

Reading First allows states to reserve up to 20 percent of their funds for 

professional development; technical assistance; and planning, 

administrative, and reporting activities.10 For example, states can use their 

funds to develop and implement a professional development program to 

prepare K-3rd teachers in all essential components of reading instruction. 

One model for supporting teachers’ reading instruction involves hiring a 

Reading Coach who works with teachers to implement reading activities 

aligned with SBRR. Almost all states require Reading First schools to have 

a Reading Coach tasked with supporting teachers and principals with 

instruction, administering assessments, and interpreting assessment data. 

States that receive Reading First grants are required to conduct a 

competitive sub-grant process for eligible school districts and must 

distribute at least 80 percent of the federal Reading First grants they 

receive to districts. NCLBA and Education guidance provides states with 

flexibility to set eligibility criteria for school districts so that eligible 

districts are among those in the state that have the highest number or 

percentage of K-3rd grade students reading below grade level and (1) have

jurisdiction over an empowerment zone or enterprise community,11 (2) 

have a significant number or percentage of schools identified as in need of

improvement,12 or (3) are among the districts in the state that have the 

highest number or percentages of children counted as poor and school-

 10 From this 20 percent, states may spend up to 65 percent on professional development, up 

to 25 percent for technical assistance for districts and schools, and up to 10 percent for 

planning, administration, and reporting activities. 

11 Empowerment zones and enterprise zones are defined in 26 U.S.C. § 1392. Both are local 

areas of high poverty that meet certain eligibility requirements to receive specified forms of 

aid or regulatory flexibility. 

12 Under NCLBA, each state creates its own content standards, academic achievement 

tests, and proficiency levels. States are required to test all children for reading and 

mathematics achievement annually in grades 3-8 to determine whether schools are making 

adequate yearly progress (AYP). Districts must identify as a school in need of improvement 

any school that has not made AYP for 2 consecutive years.

Page 9 GAO-07-161 Reading First
aged for the purposes of Title I.13 NCLBA establishes priorities that states 

must consider when awarding a Reading First sub-grant, while also 

allowing states to establish other priority areas. For instance, NCLBA 

requires that the state sub-grant process give priority to districts with at 

least 15 percent of students or 6,500 children from families with incomes 

below the poverty line, but states also have some flexibility to establish 

additional priorities, such as a demonstrated commitment to improving 

reading achievement. The sub-grant process along with the criteria at each

stage is summarized in figure 1. 

 13 Title I of Elementary and Secondary Education Act, as amended and reauthorized by 

NCLBA, authorizes federal funds to help elementary and secondary schools establish and

maintain programs that will improve the educational opportunities of economically 

disadvantaged children. Title I is the largest federal program supporting education in 

kindergarten through 12th grade. 

Page 10 GAO-07-161 Reading First
Figure 1: The Process for Awarding State Sub-grants to School Districts

Award Criteria for RF: 

States required to give priority to eligible districts

that have at least 15% or 6,500 of their students

from families below the poverty line

State flexibility to: 

set additional priorities

to give competitive 

edge to certain districts

States receive Reading First grant from Education 

States submit application to Education to receive Reading First (RF) Funding

States determine what districts are eligible to apply to the state for Reading

First sub-grants

Eligibility criteria for RF based on: 

low reading performance of K-3rd grade students 

and

• an empowerment zone or enterprise community

or

• significant number or percentage of schools in need 

of improvement

or

• highest number or percentage of children who are 

counted under Title I, Part A

State flexibility to:

define and set eligibility 

definition within federal 

guidelines

State review competitive sub-grants applications

States notify eligible 

districts of sub-grant

competition

States award sub-grants

to eligible districts for 

established period of 

time set by state 

States approve or renew 

award to districts 

Districts submit applications

to state sub-grant 

competition

States deny award 

or discontinue award 

and drop districts

from the program 

Districts opt out

of the program 

Legend: 

States assess the progress

of participating districts in 

improving reading achievement 

and implementing program as

outlined in sub-grant 

application 

Source: GAO analysis based on U.S. Department of Education guidance.

When states renew districts’ sub-grants, states continue to monitor 

the districts’ progress in improving reading achievement. 

Districts are required to use their sub-grant funds to carry out certain 

activities identified in NCLBA. For example, districts must use these funds 

to select and implement reading programs based on SBRR that include the 

essential components of reading instruction, to select and implement 

diagnostic reading assessment tools, and to provide professional 

development opportunities for teachers. Additionally, districts are 

Page 11 GAO-07-161 Reading First
permitted to use Reading First funds in support of other activities, such as 

training parents and tutors in the essential components of reading 

instruction. 

States are required to report to Education annually on the implementation

of Reading First, including their progress in reducing the number of 

students who are reading below grade level. Additionally, states are 

required to submit a mid-point progress report to Education at the end of 

the third year of the grant period. These mid-point progress reports are 

subject to review by the same expert peer review panel that evaluated

state applications. If Education determines, after submission and panel 

review of a state’s mid-point progress report and on the basis of ongoing 

Education monitoring, that a state is not making significant progress, 

Education has the discretion to withhold further Reading First grant 

payments from that state. While these state reports to Education are 

intended to provide information on the effectiveness of Reading First, 

Education is also required to contract with an independent organization 

outside Education for a rigorous and scientifically-valid, 5-year, national 

evaluation of the program, with a final report scheduled to be issued in 

2007. 

The Reading First program has relied on several key contractors to 

perform a number of program functions. For example, Education officials 

hired RMC Research Corporation, a company that provides research, 

evaluation, and related services to educational and human services clients, 

to provide technical assistance to states and districts that have received 

Reading First funding. According to Education officials, RMC contractors 

were tasked initially with providing specific, individualized guidance on 

the application process to state officials who requested it. RMC later 

became the national coordinator for the contract overseeing the National 

Center for Reading First Technical Assistance and its three regional 

subsidiaries: the Eastern Regional Reading First Technical Assistance 

Center (ERRFTAC) in Tallahassee, Florida; the Central Regional Reading 

First Technical Assistance Center (CRRFTAC) in Austin, Texas; and the 

Western Regional Reading First Technical Assistance Center (WRRFTAC) 

in Eugene, Oregon. In this role, RMC staff provides support to the TACs 

and their employees, as well as weekly coordination among the TACs, and 

regular training seminars. Operated out of universities recognized by 

Education officials for their expertise in SBRR and related areas, the 

centers began operations in 2003 and are responsible for providing an 

array of technical assistance activities to states, including national and 

regional conferences, training and professional development, products and 

materials, and liaisons to national reading experts. Education officials also

Page 12 GAO-07-161 Reading First
contracted with Learning Point Associates to provide technical assistance

to states as they launched their sub-grant competitions. 

Once Reading First sub-grants had been awarded to local districts, 

Education contracted with the American Institutes for Research (AIR), a 

behavioral and social science research organization, to conduct annual

monitoring visits to each state. These visits incorporate sessions with state 

officials, as well as visits to a few districts in each state and are designed 

to assess states’ and districts’ compliance with their approved plans. After 

each monitoring visit, AIR representatives submit a report, including any 

findings of non-compliance, to Reading First officials. Reading First 

officials are to forward these reports to the cognizant state officials. 

States reported that there have been a number of changes and

improvements14 in reading instruction since the implementation of Reading

First. There has been an increased emphasis on the five key components 

of reading,15 assessments, and professional development with more 

classroom time being devoted to reading activities. However, according to

publishers we interviewed, there have been limited changes to 

instructional material. Similarly, many states that approved reading 

programs for districts to choose from report few changes to their lists of 

approved programs. 

States Reported 

Changes as Well as 

Improvements in 

Reading Instruction 

Since the Inception of 

Reading First 

 14 Education has contracted with an independent research firm to conduct a 5-year, 

quantitative evaluation of the Reading First program, evaluating the effect of Reading First 

activities on improving reading instruction. In addition, in their annual reports and midpoint evaluations, states must include their progress in reducing the number of students in 

grades K-3 reading below grade level. 

15 The five key components of reading include (1) phonemic awareness; (2) phonics; (3)

vocabulary development; (4) reading fluency, including oral reading skills; and (5) reading

comprehension strategies.

Page 13 GAO-07-161 Reading First
In responding to our survey, 69 percent of all states reported great or very 

great improvement in reading instruction since inception of Reading First. 

One area in which states16 reported a change that may have contributed to 

improvement of reading was the degree to which classroom instruction 

explicitly incorporated the five key components. In our survey, at least 39 

states reported that Reading First schools had incorporated each of the 

five required components of reading into curriculum to a great or very 

great degree as a result of Reading First. State and local officials we talked

to during some of our site visits reinforced this opinion and in particular 

noted that Reading First teachers had awareness of and were more 

focused on the five components. In addition, the increased time devoted to 

reading activities under Reading First may have contributed to 

improvement. Several district officials we met with told us they were 

including a protected, uninterrupted block of time for reading instruction 

of 90 minutes or more per day—which the department’s Guidance for the 

Reading First Program lists as a key element of an effective reading 

program. Education’s Reading First Implementation Evaluation: Interim 

Report (The Interim Report)17 also found that Reading First teachers 

reported allocating over 90 minutes per day, on average, for a designated

reading block. 

States Reported That 

Reading Instruction 

Changed or Improved 

Following the 

Implementation of 

Changes under Reading 

First 

States officials reported improvement in reading instruction resulting from 

the use of assessments.18 In responding to our survey, one state official 

said, “One of the strengths of the Reading First program has been its 

strong adherence to SBRR and to the use of valid and reliable assessments 

in guiding instruction and program evaluation.” A number of state and 

local officials we interviewed reported that the use of assessments 

changed after Reading First, especially in the way that teachers use data 

from these assessments to better inform reading instruction. Specifically, 

district officials we talked to during our site visits reported that teachers 

review students’ assessment results to determine the areas in which they

need more targeted instruction. One official also reported that assessment 

data can sometimes be used to identify successful teachers from whom 

other teachers can learn teaching techniques, with one official asserting 

that “Reading First has and is making a great impact on teachers’ 

 16 For the purposes of this report, the term “states” also includes the District of Columbia. 

17 Education’s “Reading First Implementation Evaluation: Interim Report.” 

18 The types of assessments are screening, diagnostic, and progress monitoring. See 

appendix II for more complete descriptions of each. 

Page 14 GAO-07-161 Reading First
instructional practices, techniques, and strategies.” Also, according to 

Education’s Interim Report, researchers estimated that 83 percent of 

Reading First teachers cited assessment results essential to organizing 

instructional groups, 85 percent cited the results essential to determining 

progress on skills, and 75 percent cited the results essential to identifying 

students who need reading intervention. 

According to our survey, most states also reported that the assessments 

they used differed greatly or very greatly from the ones they used prior to 

Reading First. States reported a wide variety of reading assessments on 

their state-approved lists, with over 40 different assessments listed. By far, 

the most frequently approved assessment was Dynamic Indicators of Basic 

Early Literacy Skills (DIBELS), approved by 45 states. Also, a few states 

reported to us that they were moving toward a more uniform systematic 

assessment system for the first time, whereas previously each school 

could choose which assessment it would use. Some state and district 

officials told us that having a more uniform and systematic assessment 

was beneficial, because, for instance, it allowed the officials to track and 

compare reading scores more easily. 

Professional development is another area in which state officials noted 

improvement. All states reported improvement in professional 

development as a result of Reading First, with at least 41 states reporting 

that professional development for reading teachers improved greatly or 

very greatly in each of five key instructional areas. Further, a considerable 

majority of states reported great or very great increases in the frequency of

professional development and the resources devoted to it, 45 and 39, 

respectively. One state reported, “The provision of funding to be used to 

support statewide professional development efforts for K-3 reading has 

been an important aspect of the program.” The Interim Report on the 

Reading First program highlights that a vast majority of Reading First 

teachers had received training on the five key components of reading. In

our site-visits, district officials confirmed that, for the most part, teachers 

in their Reading First classrooms had received training. However, in 

responding to our survey, 19 states did report some challenges in training

of 100 percent of Reading First teachers, with teacher turnover cited by 12

states as the reason some Reading First teachers might not have taken any

type of Reading First training. Figure 2 summarizes reported 

improvements in professional development for teachers. 

Page 15 GAO-07-161 Reading First
Figure 2: Improvements in Professional Development for Reading First Teachers 

0

10

20

30

40

50

Use of assessment 

data to inform instruction

Administration 

of assessments

Administration of core 

programs

Instruction in the

 5 components

Understanding

SBRR

Number of states

Instructional area

Very great improvement

Great improvement

Source: GAO analysis.

24

23

24

26

15

27

21

27

19

22

Professional development was provided by a variety of federal, state, and

private sources. Staff from the TACs and officials from at least one state 

reported providing professional development to districts customized to 

the individual district’s needs and perceived future needs. Education’s 

Interim Report on Reading First implementation noted that state Reading 

First coordinators in 33 states reported that state staff chose and 

organized all statewide professional development efforts and played a key

role in selecting professional development topics for districts and schools. 

In addition, publishers we spoke with told us they often provide training to 

acclimate teachers to their products. Certain publishers of major 

commercial reading programs and assessments told us that since the 

implementation of Reading First, districts demand much more training. 

Specifically, according to some of the publishers and TAC staff we spoke 

with, districts have been interested in more in-depth workshops on 

particular topics such as teaching techniques and using and interpreting 

assessments.

Page 16 GAO-07-161 Reading First
Finally, another aspect of professional development pertinent to Reading 

First is the presence of a Reading Coach. State and district officials 

reported that Reading Coaches receive training that better enables them to 

assist schools. Education’s Interim Report found that each Reading Coach

worked with an average of 1.2 schools and with 21 teachers to help 

implement activities aligned with SBRR. 

Publishers Reported 

Making Few Changes to 

Reading Programs, and 

States Reported Adopting 

a Variety of Approaches to 

Select Reading Programs 

Three of the four major publishers of reading programs we spoke with 

reported that they had not made significant changes to the content of their 

reading programs as a result of Reading First. Two publishers stated that 

they made minor changes to their reading materials to make more explicit 

how the content of the existing programs align with the five components 

emphasized in Reading First. Two of them reported that they made 

changes to their programs based on the National Reading Panel’s findings, 

which was prior to the enactment of Reading First. For example, 

representatives of one company stated that they launched a new reading 

program based on the findings of the National Reading Panel that takes 

into account the requirements of Reading First. Despite limited changes to

the actual instructional material, all the publishers noted a greater 

emphasis on assessing the efficacy of their reading programs as a result of

Reading First. In an effort to measure the effectiveness of their programs, 

the publishers reported devoting more effort to research and to evaluate 

how effective their reading programs were at raising reading assessment 

scores. 

States followed two main approaches in selecting reading programs for 

districts —22 identified a state-approved list of programs for districts to 

select, while the other 29 did not have a state-approved list, thereby 

requiring districts in those states to self-select reading programs and 

determine, with some state oversight and subject to state approval, 

whether they satisfy the requirements of SBRR. Of the 22 states with 

approved lists, reading program publishers most frequently represented on 

the lists were Houghton Mifflin, McGraw-Hill, and Harcourt (see table 1). 

At the school level, Education found in its Interim Report that these three 

reading program publishers were also the most frequently used, estimating 

that between 11 and 23 percent of schools used programs from one of 

them. 

Page 17 GAO-07-161 Reading First
Table 1: Reading Program Publishers Most Frequently Represented on States’ 

Approved Lists 

Publisher name Number of states 

Houghton Mifflina 21 

McGraw-Hill-Educationb 21 

Harcourtc 19 

Pearsond 15 

Success for All Foundation “Success for All” 11 

Source: GAO analysis.

a

Because some states listed publisher (parent company) names instead of reading program names, 

our analysis will only reflect overall totals based on publisher names. “The Nation’s Choice,” a 

program published by Houghton Mifflin, would be included in this category. 

b

McGraw-Hill Education includes SRA-”Open Court,” SRA-”Reading Mastery,” and “MacMillan 

McGraw-Hill Reading.” 

c

Harcourt, Inc. publishing includes “Trophies.” 

d

Pearson Scott Foresman includes “Scott Foresman Reading,” “Longman ESL,” and “Scott Foresman 

Reading Street.” 

Additionally, of the 22 states that identified a list of approved core reading

programs19 for Reading First, 8 already had a list of approved core reading 

programs for adoption by all schools in their state prior to Reading First. 

Only two of these states reported removing reading programs—a total of 

six—from their lists because they did not meet Reading First 

requirements. According to Education’s Interim Report, an estimated 39 

percent of Reading First schools reported adopting a new core reading 

program at the beginning of the 2004-2005 school year in which they 

received their Reading First grant, in contrast with an estimated 16 percent 

of non-Reading First Title I schools. 

States used a variety of sources to help them identify and select reading

programs that met Reading First’s criteria. For example, 15 of the 22 states 

with state-approved lists reported using the Consumer’s Guide to 

 19 The Consumer’s Guide to Evaluating A Core Reading Program Grades K-3: A Critical 

Elements Analysis, or Consumer’s Guide, describes the core reading program concept in

the following way: “A core reading program is the primary instructional tool that teachers

use to teach children to learn to read and ensure they reach reading levels that meet or 

exceed grade-level standards. The core program. . . should serve as the primary reading 

program for the school and the expectation is that all teachers within and between the

primary grades will use the core reading program as the base of reading instruction. Such 

programs may or may not be commercial reading series.” 

Page 18 GAO-07-161 Reading First
Evaluating A Core Reading Program Grades K-3: A Critical Elements 

Analysis to make this decision.20 Other frequently used resources include

criteria in the state’s application for Reading First, information obtained at

Reading First Leadership Academies21 provided by Education, and other 

states’ approved lists. Based on responses to our survey, the table below 

summarizes approaches states used to develop their approved lists (see 

table 2). 

Table 2: Approaches States Used to Develop Their Approved Lists 

Approaches Number of states

Conducted review of reading programs using A Consumer’s 

Guide to Evaluating a Core Reading Program (Kame’enui & 

Simmons) 15

Conducted review of reading programs using criteria outlined in 

your state’s Reading First application 12

Based on information obtained during Reading First Leadership 

Academies 8

Adopted reading programs from another state’s approved list(s) 7

Used existing textbook adoption list 6

Requested a Reading First Technical Assistance Center review 

of reading programs 3

Based on recommendation from U.S. Department of Education 

officials 2

Source: GAO analysis.

Based on our survey results, 25 of the 29 states reporting that they did not 

have a list of approved core reading programs said they provided guidance

for districts and schools to identify core reading programs. Fifteen of these 

states reported directing districts and schools to conduct a review of 

reading programs using A Consumer’s Guide to Evaluating a Core Reading 

Program. Other states reported providing a variety of guidance to districts 

to help them select reading programs supported by SBRR, including 

 20 Deborah C. Simmons and Edward Kame’enui. A Consumer’s Guide to Evaluating A Core

Reading Program Grades K-3: A Critical Elements Analysis (University of Oregon: March

2003). http://reading.uoregon.edu/curricula/con_guide.php 

21 Education officials sponsored three Reading Leadership Academies in the early part of

2002. The Academies were forums for state education officials to obtain information and 

build their capacity to implement key aspects of the Reading First program, including 

reliance on SBRR and professional development. 

Page 19 GAO-07-161 Reading First
referring them to the approved lists of other states and reviews conducted 

by academic experts. 

States varied in how they exercised their flexibility to set additional 

eligibility and award criteria as allowed by the Reading First program, and 

some states reported difficulty with implementing key aspects of the 

Reading First program while other states did not. In the areas in which 

they were given flexibility, states used a variety of criteria for determining 

eligibility and in awarding sub-grants to eligible districts, such as awarding 

grants to districts that had previously received federal reading dollars. 

Education reported that over 3,400 school districts were eligible to apply 

for Reading First sub-grants in the states’ first school year of funding.22,23 

Of these districts, nearly 2,100 applied for and nearly 1,200 received

Reading First sub-grants in the states’ first school year of funding. In 

addition, 22 states reported that it was difficult or very difficult to help 

districts with reading scores that had not improved sufficiently. On the 

other hand, 28 states reported that it was easy or very easy to determine 

whether districts’ applications met criteria for awarding sub-grants. 

States varied in how they exercised their flexibility to set school district 

eligibility criteria for sub-grants. The Reading First program provides 

states with some flexibility to define eligibility criteria within the statutory 

guidelines. For instance, while Reading First requires that states target 

districts with students in kindergarten through third grade reading below 

grade level, states have flexibility to set eligibility criteria based on the 

percentage and/or number of these students within districts. While 34 

states reported electing to base eligibility on a percentage of schools with 

students reading below grade level, 18 states reported electing to base 

eligibility on a number of students reading below grade level.24 After 

applying eligibility criteria, Education reported that states determined that 

over 3,400 school districts were eligible to apply for Reading First subStates Awarded 

Reading First SubGrants to School 

Districts Using a 

Variety of Different 

Criteria, and Some 

States Reported 

Difficulties with 

Implementation 

States Varied in How they 

Exercised Their Flexibility 

to Set Additional School 

District Sub-grant 

Eligibility and Award 

Criteria 

 22 The first school year of funding varied across states. Twenty-five states received their 

first year of funding in the 2002-2003 school year. Twenty-five states received their first 

year of funding in the 2003-2004 school year. 

23 Two states were excluded from our analysis because of data inconsistencies. See 

appendix I for additional information about methodology.

24 The total number of states does not add to 51 because 1 state reported that its district 

eligibility included both a percentage figure as well as the number of schools. 

Page 20 GAO-07-161 Reading First
grants for states’ first school year of funding, or about 20 percent of all 

school districts nationwide. However, the percentage of eligible districts 

varied greatly across the states, ranging from about 3 to 93 percent. 

Of those districts eligible to apply, 62 percent, or nearly 2,100 districts, did 

so, as summarized in figure 3 below. States reported a variety of reasons 

why eligible school districts did not apply such as the prescriptive nature 

of the program, differences in educational philosophy, and inadequate 

resources for the application process. For example, officials from a few 

states reported that some districts did not have the capacity to write the 

grant application. An official from one state reported that some districts 

did not have the time and the staff to complete the sub-grant process. 

Furthermore, an official from another state reported that the application 

process was too lengthy and time-consuming to complete. 

Nineteen states reported in our survey that they exercised flexibility in 

establishing priorities when awarding Reading First sub-grants. States set 

a variety of additional priorities for awarding grants to school districts. 

For instance, six states reported that they gave priority to districts that 

already had other grants, such as Early Reading First grants,25 or indicated 

that they could somehow use their Reading First funds in combination 

with other resources to maximize the number of students reading at grade 

level. In contrast, two states gave priority to districts that had not received 

other grant funding. In addition, two states gave priority to districts based 

on the population of Native Americans or students with limited English 

proficiency. After applying selection criteria, states awarded Reading First 

sub-grants to about 34 percent or nearly 1,200 school districts for states’ 

first school year of funding. This represented about 56 percent of the 2,100 

eligible districts that applied and nearly 7 percent of all school districts 

nationwide for states’ first school year of funding (see fig. 3).

 25 The No Child Left Behind Act of 2001 added two new reading programs to the 

Elementary and Secondary Education Act, Reading First and Early Reading First. Early 

Reading First provides support to local efforts to enhance the early language, literacy, and 

pre-reading development of preschool-age children, particularly those from low-income 

families, through strategies and professional development that are based on scientifically 

based reading research. 

Page 21 GAO-07-161 Reading First
Figure 3: All School Districts Nationwide That Were Eligible for, That Applied for, 

and Were Awarded Reading First Sub-grants in the First School Year of Funding 

Eligible Reading First Districts

(20% of all districts nationwide)

Eligible that applied for Reading First sub-grants

(12% of all districts nationwide)

Eligible Districts awarded Reading First sub-grants

(7% of all districts nationwide)

 

Source: GAO analysis based on U.S. Department of Education data.

34%

62%

100%

Some States Reported 

Difficulty Implementing 

Key Aspects of the 

Program 

Some states reported difficulty in implementing key aspects of the Reading 

First program. Twenty-two states reported that it was either difficult or 

very difficult to help districts with reading scores that had not improved 

sufficiently.26 Officials from one state said that this was difficult because it

requires close examination of students reading deficiencies and the 

commitment of school leadership. Officials from another state reported 

some difficulty in improving selected reading skills of students with 

limited English proficiency, which are concentrated in pockets around the 

state. Seventeen states reported that it was either difficult or very difficult 

to assess how districts applied SBRR in choosing their reading program. 

Finally, seven states reported difficulty implementing four or more of six 

key program aspects listed in our survey and shown in figure 4. Officials 

from one of these states told us that the difficulty with implementation 

was due to the newness of the program for which everything had to be

developed from scratch. 

 26 States develop their own performance thresholds for districts to meet and develop 

policies for how to handle those districts with results that are below these thresholds. 

When monitoring participating districts, states must determine whether funding should

continue or whether districts should be dropped from the program. Sixteen states reported

dropping at least one district that was initially awarded a sub-grant. There were a variety of 

reasons that a state dropped a district, including districts not showing progress, noncompliance with state requirements, or a shift in reading philosophy. 

Page 22 GAO-07-161 Reading First
On the other hand, states reported ease implementing other key aspects. 

In particular, 28 states reported that it was easy or very easy to determine 

whether districts’ applications met criteria for awarding sub-grants. For 

example, states are required to determine whether districts will adhere to

the key components of the program, such as developing a professional 

development program or using reading assessments to gauge performance. 

Several states we interviewed suggested that it was easy to make this 

determination because some of the Reading First requirements were 

already in place in their states before Reading First was implemented. For 

example, some state officials we interviewed mentioned using reading

assessments prior to Reading First. In addition, officials in one state told 

us that they already had a professional development program in place to 

train teachers on the state’s reading program. Twenty-four states reported 

that it was easy or very easy to identify reading programs based on SBRR. 

Figure 4: States Level of Ease or Difficulty Implementing Key Reading First Program Aspects 

0

10

20

30

40

50

Helping districts

with reading scores

that have not 

improved 

sufficiently

Assessing how 

districts applied 

principles of 

scientifically-based 

reading research

Using

reading

assessment

Creating

professional 

development 

curricula

Identifying

reading programs

based on 

scientificallybased reading

research

Determining

whether districts’ 

applications

met the agreed 

upon criteria to 

receive funding

Number of states

Program aspects

Source: GAO analysis.

Easy/very easy

Neither easy nor difficult

Difficult/very difficult

28

17

6

24

18

22

18

11

19 20

12

7

20

22

12

21

17

7

Page 23 GAO-07-161 Reading First
Education officials provided states a wide variety of guidance, assistance, 

and oversight, but Education lacked written procedures to guide its 

interactions with the states and provided limited information on its 

monitoring procedures. Education’s guidance and assistance included 

written guidance, preparatory workshops, feedback during the application 

process, and feedback from monitoring visits. Additionally, guidance and 

assistance were provided by Education’s contractors, including the 

regional technical assistance centers. For the most part, state officials 

characterized the guidance and assistance they received from Education 

officials and contractors, especially the regional technical assistance 

centers, as being helpful or very helpful, and many also reported relying on

the expertise of Reading First officials in other states. However, Education 

lacked controls to ensure that its officials did not endorse or otherwise 

mandate or direct states to adopt particular reading curricula. For 

example, according to state officials, Education officials and contractors 

made suggestions to some states to adopt or eliminate certain reading 

programs, assessments, or professional development providers. In 

addition, some state officials reported a lack of clarity about key aspects 

of the annual monitoring process, including time frames and expectations 

of states in responding to monitoring findings. 

Education provided a variety of written and informal guidance and 

assistance to states to help them prepare their applications. For example, 

three months after the enactment of NCLBA in January 2002, Education 

issued two key pieces of written guidance to states pertaining to the 

Reading First program and grant application process: the Guidance for the 

Reading First Program and Criteria for Review of State Applications. 

Education officials also sponsored three Reading Leadership Academies in 

the early part of 2002. The Academies were forums for state education 

officials to obtain information and build their capacity to implement key 

aspects of the Reading First program, including professional development 

and the application of SBRR. Education contracted with RMC Research 

Corporation to provide technical assistance to states related to the grant 

application process. States reported seeking guidance from RMC on 

various aspects of the Reading First application, in particular the use of 

instructional assessments (17 states) and instructional strategies and 

programs (14 states). Throughout the application process, both Education 

and RMC officials were available to address states’ questions. In particular, 

Education officials provided feedback to states on the results of expert 

review panel evaluations of their applications. Consequently, a large 

number of states reported that Education required them to address issues 

in their applications, most commonly related to the use of instructional 

Education Provided a 

Wide Range of 

Guidance, Assistance, 

and Oversight, 

Generally Satisfying 

State Officials, but 

Education Lacked 

Controls to Guard 

against Mandating or 

Endorsing Curricula 

and Did Not Provide 

Written Monitoring 

Procedures 

Education Provided a Wide 

Range of Guidance and 

Assistance 

Page 24 GAO-07-161 Reading First
assessments (33 states) and instructional strategies and programs (25 

states). See figure 5 for issues raised about state applications. Forty-eight

states reported that they needed to modify their application at least once,

and 27 reported modifying them three or more times. 

Figure 5: Issues Education Raised About States’ Reading First Applications

0

5

10

15

20

25

30

35

40

Outline and rationale 

for using

SBRR

Selection criteria for 

awarding

subgrants

Definition of 

subgrant eligibility

Reporting and evaluation

Professional 

development plan

Instructional strategies

 and programs

Use of instructional

 assessment

Number of states

Source: GAO analysis.

Issues

Once grants were awarded, Education continued to provide assistance and 

contracted with RMC Research to oversee three regional TACs to help 

states implement Reading First. RMC established three TACs affiliated 

with state university centers in Florida, Texas, and Oregon, which RMC 

and TAC officials told us were selected based on their expertise in one or 

more areas central to the success of the Reading First program, such as 

professional development or reading assessment. Each technical 

assistance center was responsible for providing comprehensive support to

each of the states in its geographic region (see fig. 6). States reported that

they looked to these centers for guidance on a variety of issues, especially

creating professional development criteria, using reading assessments, and 

helping districts with reading scores that had not improved sufficiently. 

Page 25 GAO-07-161 Reading First
According to TAC staff, some of the most common requests they receive 

pertain to the use and interpretation of assessment data and use of 

Reading Coaches. TAC staff also told us that they catalog recurring issues 

or problems. 

Figure 6: Geographic Regions for Reading First Regional Technical Assistance Centers 

Sources: U.S. Department of Education.

PA

OR

NV

ID

MT

WY

UT

AZ NM

CO

ND

SD

NE

TX

KS

OK

MN

IA

MO

AR

LA

IL

MS

IN

KY

TN

AL

FL

GA

SC

NC

VA

OH

NH

MA

RI MI

CA

WA

WI NY

ME

VT

WV

HI

CT

NJ

DE

MD

DC

AK

Eastern region

Central region

Western region

Location of regional technical assistant center

Page 26 GAO-07-161 Reading First
In addition, according to one RMC official and some state officials, the 

TACs provided support to states during implementation to help them 

supplement their capacity and expertise in evaluating whether or not 

reading programs proposed by districts were based on SBRR. For 

instance, staff from the TAC in Florida explained that some states in their 

region had asked for assistance in evaluating reading programs that had 

been in use prior to Reading First to gauge their compliance with the 

requirements of Reading First. Staff from the TAC emphasized that in 

reviewing these reading programs, they used the criteria in each state’s 

approved state plan as the criteria for determining compliance with 

Reading First requirements. Officials in one state explained that while the 

staff at their state educational agency (SEA) possessed the knowledge 

necessary to conduct reviews of reading programs, scarce state staff 

resources would have made it difficult to conclude the reviews in the short 

time frame available. Though Education officials were aware of and 

initially condoned the TAC review process, Education officials advised all 

TACs to discontinue reviews of programs—to avoid the appearance of 

impropriety—after allegations were raised about Reading First officials 

expressing preference for specific reading programs. (Table 3 provides a 

summary of the types of guidance and assistance provided by Education 

and its contractors.) 

Table 3: Guidance and Assistance Provided to States during Application and Implementation Processes 

Source Type Purpose Time frame

Final Guidance for the 

Reading First Program and 

Criteria for Review of State 

Applications 

Written guidance Interpreting the provisions of NCLBA authorizing 

the Reading First program and providing guidance 

on the criteria review panel members would be 

using in evaluating states’ applications. 

Application process 

Reading Leadership 

Academies 

Workshops Helping states master key features of the Reading 

First program, in particular the application of SBRR 

in classroom and professional development 

activities. 

Application process 

RMC Research technical 

assistance providers 

Technical assistance Providing technical assistance to states including 

training in SBRR. 

Application process 

Regional Reading First 

Technical Assistance Centers

Technical assistance Providing guidance to states about conducting their 

district sub-grant competitions, delivering training, 

assistance, and related materials in response to 

requests from state-level Reading First officials, 

and training including annual workshops for states. 

Implementation process 

Source: GAO analysis.

Page 27 GAO-07-161 Reading First
During the application and implementation phases of the Reading First 

program, many states came to rely on other unofficial sources of guidance, 

including other states’ Reading First officials, in addition to the written 

guidance provided by Education. For example, as noted earlier, among the 

22 states that had an approved list of reading programs for Reading First 

districts, 15 reported using A Consumer’s Guide to Evaluating a Core 

Reading Program to assist them in reviewing potential reading programs. 

In addition, officials from 21 states reported that other states’ Reading

First Coordinators provided great or very great help during the Reading

First state grant application process. Further, a number of state officials 

reported using the information from other states’ websites, such as 

approved reading programs, to help inform their own decisions pertaining 

to the selection of reading programs. One state official explained, “With 

our limited infrastructure and dollars, we were never able to muster the 

resources needed to run an in-house programs review,” and further that, 

“It worked well for us to use the programs and materials review results 

from larger states that ran rigorous review processes.” Another state 

official reported that the state did not feel equipped to apply the principles

of SBRR in evaluating reading programs and responded by comparing one 

state’s review and subsequent list of reading programs to those of a few 

other states to make judgments about allowable programs. 

Page 28 GAO-07-161 Reading First
Most states reported making use of and being satisfied with the primary 

sources of guidance available to them over the course of the Reading First 

application and implementation processes. For example, 46 states 

reported making use of the two key pieces of Education’s written guidance 

in preparing their Reading First applications. A majority of states also 

reported that these pieces of guidance provided them with the information 

needed to adequately address each of the key application components. For 

example, over 40 states reported that the guidance related to the definition

of sub-grant eligibility and selection criteria for awarding sub-grants 

helped them adequately address these areas in their application. However, 

officials in eight states reported that the guidance on the use of 

instructional assessments did not provide them with the information 

needed to adequately address this area. (See fig. 7.) 

States Were Generally 

Satisfied with the 

Guidance and Assistance 

Available to Them 

Page 29 GAO-07-161 Reading First
Figure 7: States’ Assessment of Whether Written Guidance Provided Information

Needed to Adequately Address Application Components 

0

5

10

15

20

25

30

35

40

45

Reporting and evaluation

Instructional strategies

and programs

Use of instructional

assessment

Professional

development plan

Selection criteria for

awarding

sub-grants

Definition of

sub-grant eligibility

Outline and rationale

for using

SBRR

Number of states

Source: GAO analysis.

Application or implementation component

Number of states reporting guidance was adequate to address application component

Number of states reporting guidance was not adequate to address application component

Overall, most state officials were also satisfied with the level of assistance 

they received from Education staff and their contractors in addressing 

issues related to the Reading First application and implementation 

processes. For example, state officials in 39 states reported that Education 

staff were of great or very great help during the application or

implementation process. Additionally, officials from 48 states reported 

that Education officials were helpful or very helpful in addressing states’ 

implementation-related questions, which frequently dealt with using 

reading assessments and helping districts with reading scores that had not

improved sufficiently. A number of state officials reported to us that they 

appreciated the guidance and attention they received from Reading First 

officials at Education. For example, one state Reading First Coordinator 

Page 30 GAO-07-161 Reading First
reported, “the U.S. Department of Education personnel have been 

wonderful through the process of implementing Reading First. I can’t say 

enough about how accessible and supportive their assistance has been.” 

Another state official remarked that the state’s efforts to make reading

improvements “would have been impossible without their [Education 

officials and contractors] guidance and support.” Even officials from one 

state who had a disagreement with Education over its suggestion to 

eliminate a certain reading program characterized most of the guidance 

they received from Reading First officials as “excellent.” However, one 

state official reported feeling that the technical assistance workshops have 

served as conduits for Education officials to send messages about the 

specific reading programs and assessments they prefer. Another state 

official reported that, “core programs and significant progress have not 

been defined” and that “SBRR programs are not clearly designated.” 

According to responses obtained to our survey, the three TACs also 

provided a resource for states seeking advice on issues pertaining to the 

implementation of their Reading First programs. Specifically, 41 states 

cited the Centers as helpful or very helpful in addressing states’ inquiries 

related to the implementation of Reading First. In addition, on a variety of 

key implementation components, more state officials reported seeking 

information from their regional TACs than they did from Education 

officials (see table 4). 

Table 4: States’ Reported Sources of Guidance for Key Reading First 

Implementation Components

Number of states seeking

guidance or assistance from

Education and the TACs

Implementation component Education TACs

Creating professional development criteria 6 41

Identifying reading programs based on SBRR 9 24

Assessing how districts applied principles of SBRR 10 29

Using reading assessments 20 40

Helping districts with reading scores that have not 

improved sufficiently 12 36

Other implementation issues related to approving 

district applications 18 20

Source: GAO analysis.

Page 31 GAO-07-161 Reading First
We found that Education developed no written guidance, policies, or 

procedures to direct or train Education officials or contractors regarding 

their interactions with the states. Federal agencies are required under the 

Federal Managers’ Financial Integrity Act of 198227 to establish and 

maintain internal controls to provide a reasonable assurance that agencies 

achieve objectives of effective and efficient operations, reliable financial 

reporting, and compliance with applicable laws and regulations.28 When 

executed effectively, internal controls work to ensure compliance with 

applicable laws and regulations by putting in place an effective set of 

policies, procedures, and related training. We found that Education had

not developed written guidance or training to guide managers on how to 

implement and comply with statutory provisions prohibiting Education 

officials from directing or endorsing state and local curricular decisions. 

Department officials told us that it was their practice that program 

managers should consult the Office of General Counsel if they had 

questions regarding interactions with grantees. Reading First officials told

us that it was their approach to approve each state’s method and rationale 

for reviewing or selecting reading programs as outlined in each state’s plan 

and that state compliance with program requirements, including 

adherence to the principles of SBRR, would then be assessed using the 

provisions of these plans as the criteria. Similarly, officials from 

Education’s contractors responsible for conducting monitoring visits told 

us that they were instructed by Education to use state plans as the criteria

for gauging states’ compliance with Reading First reading program 

requirements, but that they were provided no formal written guidance or 

training. A senior Education attorney who is currently working with 

Reading First program officials told us that he was not aware that they had 

used this approach and that he felt that the statutory requirements should 

also play an important role in the monitoring process. Following the 

publication of the IG’s report in September, Education’s Office of General 

Counsel has provided training to senior management on internal control 

requirements and has begun working with the Reading First office to 

develop procedures to guide the department’s activities. 

Education Lacked Written 

Procedures to Guide Its 

Interactions with States 

Despite the statutory prohibition against mandating or endorsing curricula 

and the department’s stated approach to rely on state plans, and the 

 27 31 U.S.C. § 3512 (c) and (d). 

28 For more information, see GAO’s Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999), P.L. 97-255 and 31

USC 1105, 1113, and 3512. 

Page 32 GAO-07-161 Reading First
processes articulated in them, to assess compliance, states reported to us 

several instances in which Reading First officials or contractors appeared 

to intervene to influence their selection of reading programs and 

assessments. For example, officials from four states reported receiving

suggestions from Education or its contractors to adopt specific reading 

programs or assessments. Specifically, two states reported that it was 

suggested that they adopt a particular reading assessment. Similarly, 

Education’s first IG report also documented one instance in which 

Reading First officials at Education worked in concert with state 

consultants to ensure that a particular reading program was included on

that state’s list of approved reading programs.29

In addition, states reported that Education officials or contractors 

suggested that they eliminate specific reading programs or assessments 

related to Reading First. Specifically, according to our survey results, 

officials from 10 states reported receiving suggestions that they eliminate 

specific programs or assessments. In some cases, the same program was 

cited by officials from more than one state. In one instance, state officials 

reported that Education officials alerted them that expert reviewers 

objected to a reading program that was under consideration but not 

named explicitly in the state’s application. An official from a different state 

reported receiving suggestions from Education officials to eliminate a 

certain reading program, adding that Education’s justification was that it 

was not aligned with SBRR. In another instance, state officials pointed out 

that they had adopted a program that was approved by other states, 

according to the procedures in their approved state plan, but were told by

Education officials that it should be removed from their list and that 

Education would subsequently take a similar course of action with regard 

to those other states as well. Also, Education officials did not always rely

on the criteria found in state plans as the basis for assessing compliance. 

We found, for example, one summary letter of findings from a monitoring 

report in which Education officials wrote that “Two of the monitored 

districts were implementing reading programs that did not appear to be 

aligned with scientifically based reading research.” Officials we spoke to in

that state told us that they did not feel that they had been assessed on the 

basis of the procedures outlined in the state’s plan, but rather that the 

reading program itself was being called into question. The IG also found 

that Reading First officials communicated to several states against the use 

 29 Department of Education, Office of the Inspector General, The Reading First Program’s

Grant Application Process: Final Inspection Report (Washington, D.C.: September 2006).

Page 33 GAO-07-161 Reading First
of certain reading programs or assessments, including Rigby and Reading 

Recovery. 

Officials from a few states also reported being contacted by Education 

regarding district Reading First applications or reading programs. For 

example, officials from four states reported being contacted by an 

Education official about a district application under consideration and one 

of those states also reported being approached by staff from one of the 

regional technical assistance centers or another contractor for the same 

reason. Officials from each of these states indicated that the reason they 

were contacted stemmed from the reading programs being used by the 

districts in question. In a few cases, state officials reported being 

contacted by Education officials regarding the state’s acceptance of a 

reading program or assessment that was not in compliance with Reading 

First. In one instance, state officials reported that Education contacted 

them outside of the normal monitoring process after they had obtained 

information from a national Reading First database maintained by a nonprofit research organization that districts in the state were using a specific

reading program. 

Five states also reported receiving recommendations from Reading First 

officials or contractors to change some of the professional development 

providers proposed in their original grant applications. When asked about 

the specific providers identified for elimination, three of the states 

indicated that the providers identified for elimination were in-state 

experts. In one case, a state was told that the review panel cited a lack of 

detail about the qualifications of the state’s proposed professional 

development consultants. 

We also found that while Education officials laid out an ambitious plan to

annually monitor every state, they failed to develop written procedures 

guiding its monitoring visits. For example, Education did not establish 

timelines for submitting final reports to states following monitoring visits, 

specifically how and when state officials were expected to follow up with 

Education officials regarding findings from the monitoring visits. As a 

result, states did not always understand monitoring response procedures, 

timelines, and expectations. While we found that most state officials we 

spoke with understood that they were to be monitored with the use of 

their state plans as the criteria, they did not always understand what was 

required of them when responding to monitoring findings. For example, 

one state official reported being unaware that the state was supposed to 

respond to Education officials about findings from its monitoring report. 

An official from another state maintained that he/she was unclear about 

Page 34 GAO-07-161 Reading First
the process the state was to follow to respond to findings, and that no 

timeline for responding was provided to him/her. Furthermore, one state 

reported that findings were not delivered in a timely manner, and another 

state reported that Education did not address the state’s responses to the 

monitoring findings. Key aspects of an effective monitoring program 

include communicating to individuals responsible for the function any 

deficiencies found during the monitoring. 

The Reading First program, according to state coordinators, has brought 

about changes and improvements to the way teachers, administrators, and 

other education professionals approach reading instruction for children in

at-risk, low-performing schools during the critical years between 

kindergarten and third grade. To assist states in implementing this large, 

new federal reading initiative, Education has provided a wide range of 

guidance, assistance, and oversight, that, for the most part, states have

found helpful. However, Education failed to develop comprehensive 

written guidance and procedures to ensure that its interactions with states 

complied with statutory provisions. Specifically, Education lacked an

adequate set of controls to ensure that Reading First’s requirements were 

followed, while at the same time ensuring that it did not intervene into

state and local curricular decisions. We concur with the Education IG’s 

recommendations that the Department develop a set of internal 

procedures to ensure that federal statutes and regulations are followed 

and we feel it is important for the Secretary to follow up on these 

recommendations to ensure that they are properly implemented. 

Additionally, we feel it is important for the department to have clear 

procedures in place to guide departmental officials in their dealings with 

state and local officials. While Education’s stated approach was to rely on

state plans as its criteria for enforcing Reading First’s requirements, states 

reported several instances in which it appears that Education officials did 

attempt to direct or endorse state and local curricular decisions. Such 

actions would prevent states from exercising their full authority under the 

law and would violate current statutory restrictions. Balancing Reading 

First’s requirements and the limits placed on the department requires 

Education to have clear, explicit, and well-documented procedures to 

guide its interactions with the states. Failure to do so places the 

department at risk of violating the law and leaves it vulnerable to 

allegations of favoritism. 

Conclusions 

Additionally, while Education’s annual monitoring effort for Reading First 

is ambitious, it did not provide clear guidelines and procedures to states. 

As a result, states were not always aware of their roles and responsibilities 

Page 35 GAO-07-161 Reading First
in responding to findings of non-compliance, and Education was not 

always consistent in its procedures to follow up with states to resolve 

findings and let states know if they had taken proper actions. Key aspects 

of an effective monitoring program include transparency and consistency.

Letting all states know in a timely manner whether or not their plans to 

address deficiencies are adequate is important to ensure that findings are 

dealt with in an appropriate, timely and clear manner. 

In addition to addressing the IG’s recommendations to develop internal 

(1) policies and procedures to guide program managers on when to solicit

advice from General Counsel and (2) guidance on the prohibitions 

imposed by section 103(b) of the DEOA, we recommend that, in order to 

ensure that the department complies with statutory prohibitions against 

directing, mandating, or endorsing state and local curricular decisions, the 

Secretary of Education also establish control procedures to guide 

departmental officials and contractors in their interactions with states, 

districts, and schools. 

In addition, to help the department conduct effective monitoring of the 

Reading First program, we recommend that the Secretary of Education 

establish and disseminate clear procedures governing the Reading First 

monitoring process. In particular, Education should delineate states’ rights 

and responsibilities and establish timelines and procedures for addressing 

findings. 

We provided a draft of this report to the Department of Education and 

received written comments from the agency. In its comments, included as 

appendix III of this report, Education agreed with our recommendations 

and indicated that it will take actions to address them. 

Recommendations 

Agency Comments 

Specifically, Education said it will provide written guidance to all 

departmental staff to remind them of the importance of impartiality in 

carrying out their duties and not construing program statutes to authorize 

the department to mandate, direct, or control curriculum and instruction, 

except to the extent authorized by law. On February 7, 2007, the Secretary 

of Education issued a memorandum to senior officers reminding them that 

it is important to maintain objectivity, fairness, and professionalism when 

carrying out their duties. The Secretary’s memorandum also emphasizes 

the importance of adhering to the statutory prohibitions against 

mandating, directing, and controlling curriculum and instruction, and 

strongly encourages managers to consult with Education’s Office of 

General Counsel early on to identify and resolve potential legal issues. 

Page 36 GAO-07-161 Reading First
Also, according to Education’s written comments on our draft report and 

the Secretary’s February 7, 2007, memorandum to senior officers, annual 

training will be required on internal controls and this training will address 

statutory prohibitions against mandating, directing or controlling local 

curriculum and instruction decisions. 

Regarding its monitoring process for Reading First, in its comments, 

Education said that it will develop and disseminate guidelines to states 

outlining the goals and purposes of its monitoring efforts, revise the 

monitoring protocols, and develop timelines and procedures on states’ 

rights and responsibilities for addressing monitoring findings. Education 

also included in its response a summary of its actions and planned actions 

to address recommendations from the department’s Office of Inspector 

General’s recent report on the implementation of the Reading First 

program. 

As agreed with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its 

issue date. At that time, we will send copies of this report to appropriate 

congressional committees, the Secretary of Education, and other 

interested parties. Copies will also be made available upon request. In 

addition, the report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. If you or your staff have any questions about the 

report, please contact me at (202) 512-7215. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix IV.

Cornelia M. Ashby 

Director, Education, Workforce, and

 Income Security Issues 

Page 37 GAO-07-161 Reading First
Appendix I: Objectives, Scope, and Appendix I: Objectives, Scope, and Methodology 

Methodology 

Our objective was to answer the following questions: (1) What changes 

have occurred to reading instruction since the inception of Reading First?

(2) What criteria have states used to award Reading First sub-grants to 

districts, and what, if any, difficulty did states face in implementing the 

program? (3) What guidance, assistance, and oversight did Education 

provide states related to the Reading First program? To answer these 

questions, we collected both qualitative and quantitative information about 

the Reading First program from a variety of sources. We conducted a Webbased survey of the Reading First Directors in all 50 states and the District 

of Columbia. We also obtained and analyzed data from the Department of 

Education for each state on Reading First districts’ eligibility, applications 

and awards for states’ first school year of funding. The first school year of

funding varied across states. Twenty-five states received their first year of 

funding in the 2002-2003 school year. Twenty-five states received their first 

year of funding in the 2003-2004 school year. To assess the reliability of 

this data, we talked to agency officials about data quality control 

procedures and reviewed relevant documentation. We excluded two states 

because of reporting inconsistencies, but determined that the data for the 

other states were sufficiently reliable for the purposes of this report. We 

also conducted semi-structured follow-up interviews with Reading First 

Directors in 12 states, mostly over the telephone. We conducted site visits 

to 4 of the 12 states. During the site visits, we met with state officials, local

program administrators, and state-level technical assistance providers, as 

well as school officials from individual schools, including teachers, 

principals, and Reading First coaches. In identifying local sub-grant 

recipients to meet with in each state, we sought to incorporate the 

perspectives of urban, rural, and suburban school districts. We selected 

the 12 states to have diversity in a variety of factors, including geographic 

distribution, grant size, poverty rate, percentage of students reading at or 

below grade level, urban and rural distinctions, the presence of a 

statewide list of approved reading programs, and whether states had 

reported that they received guidance from Education officials advocating 

for or against particular reading programs or assessments. For both the 

survey and follow-up interviews, to encourage candid responses, we 

promised to provide confidentiality. As a result, state survey responses 

will be provided primarily in summary form or credited to unnamed states, 

and the states selected for follow-up interviews will not be specifically 

identified. Furthermore, in order to adequately protect state identities, we 

are unable to provide the names of particular reading programs or 

assessments Education officials or contractors suggested a state use or 

not use. We did not attempt to verify allegations made by state or local 

officials in their survey responses or during interviews or otherwise make 

any factual findings about Education’s conduct.

Page 38 GAO-07-161 Reading First
Appendix I: Objectives, Scope, and 

Methodology 

We also visited or talked with administrators from each of the three 

regional Reading First Technical Assistance Centers, located in Florida, 

Texas and Oregon, as well as RMC Research, the federal contractor tasked

with administering the contract with the technical assistance centers. We

also interviewed several publishers and other providers of reading 

curricula and assessments, to obtain their views about changes Reading 

First has prompted in states, districts, and schools. We chose these 

providers to reflect the perspectives of large, commercial reading textbook 

programs that are widely represented nationwide on states’ lists of 

approved programs, as well as some other selected providers of reading 

curricula, including some that have filed complaints related to Reading 

First. We also interviewed Education officials about the implementation of 

the Reading First program. 

To obtain a better understanding of state program structure, as well as the 

nature of interactions between Education officials and state grantees, we 

reviewed state grant files, monitoring reports, and related correspondence 

for the 12 states where we conducted follow-up interviews. In addition, we 

reviewed NCLBA language authorizing Reading First, as well as statements 

of work articulating the responsibilities of the regional technical 

assistance centers and the contractor tasked with providing assistance to 

states in conducting local sub-grant competitions. We conducted our work 

from December 2005 through January 2007 in accordance with generally

accepted government auditing standards. 

To better understand state implementation of the Reading First program, 

we designed and administered a Web-based survey of the Reading First 

Directors in all 50 states and the District of Columbia. The survey was 

conducted between June and July 2006 with 100 percent of state Reading 

First Directors responding. The survey included questions about 

curriculum; professional development; and state Reading First grant 

eligibility, application, award, and implementation processes. The survey 

contained both closed- and open-ended questions. For the open-ended 

questions, we used content analysis to classify and code the responses 

from the states such as the publishers on states’ approved lists. We had 

two people independently code the material, then reconciled any 

differences in coding. Because this was not a sample survey, there are no 

sampling errors. However, the practical difficulties of conducting any 

survey may introduce nonsampling errors, such as variations in how 

respondents interpret questions and their willingness to offer accurate 

responses. We took steps to minimize nonsampling errors, including pretesting draft instruments and using a Web-based administration system. 

Specifically, during survey development, we pre-tested draft instruments 

Survey of States 

Page 39 GAO-07-161 Reading First
Appendix I: Objectives, Scope, and 

Methodology 

with one expert reviewer and Reading First Directors in four states during 

April and May 2006. In the pre-tests, we were generally interested in the 

clarity of the questions and the flow and layout of the survey. For example, 

we wanted to ensure definitions used in the survey were clear and known 

to the respondents, categories provided in closed-ended questions were 

complete and exclusive, and the ordering of survey sections and the 

questions within each section was appropriate. On the basis of the pretests, the Web instrument underwent some slight revisions. A second step 

we took to minimize nonsampling errors was using a Web-based survey.

By allowing respondents to enter their responses directly into an 

electronic instrument, this method automatically created a record for each 

respondent in a data file and eliminated the need for and the errors (and 

costs) associated with a manual data entry process. To further minimize 

errors, programs used to analyze the survey data were independently 

verified to ensure the accuracy of this work. 

Page 40 GAO-07-161 Reading First
Appendix II: Descriptions of Assessment Appendix II: Descriptions of Assessment Types 

Types

Reading First Assessment Requirements and Descriptions

• Reading programs under Reading First must include rigorous assessments with proven validity and reliability. 

• Assessments must measure progress in the five essential components of reading instruction and identify students who may be at 

risk for reading failure or who are already experiencing reading difficulty. 

• Reading programs under Reading First must include screening assessments, diagnostic assessments, and classroom-based 

instructional assessments of progress. 

Assessment type Description

Screening Determine which children are at risk for reading difficulty and need 

additional support 

Diagnostic Provide more in-depth information on students’ skills and 

instructional needs; forms the basis of intervention strategies

Classroom-based instructional assessments of progress Determine whether students are making progress and/or need 

more support to achieve grade-level reading outcomes 

Source: GAO analysis based on Education guidance.

Page 41 GAO-07-161 Reading First
Appendix III: Comments from the Department Appendix III: Comments from the of Education 

Department of Education 

Page 42 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 43 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 44 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 45 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 46 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 47 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 48 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 49 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 50 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 51 GAO-07-161 Reading First
Appendix III: Comments from the Department 

of Education 

Page 52 GAO-07-161 Reading First
Appendix IV: 

A

GAO Contacts and Staff 

cknowledgments 

Page 53 GAO-07-161

Appendix IV: GAO Contacts and Staff 

Acknowledgments 

Cornelia M. Ashby (202) 512-7215 ashbyc@gao.gov

Bryon Gordon, Assistant Director, and Tiffany Boiman, Analyst-in-Charge, 

managed this engagement and made significant contributions to all 

aspects of this report. Sonya Phillips, Sheranda Campbell, Janice Ceperich, 

and Andrew Huddleston also made significant contributions. Jean 

McSween provided methodological expertise and assistance. Sheila 

McCoy and Richard Burkard delivered legal counsel and analysis. 

Susannah Compton, Charlie Willson, and Scott Heacock assisted with 

message and report development. 

Reading First

GAO Contacts 

Acknowledgments 

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