a

GAO

United States General Accounting Office

Report to Congressional Committees

April 2003 TITLE I

Although Definitions 

of Administrative 

Expenditures Vary, 

Almost All School 

Districts Studied 

Spent Less Than 10 

Percent on 

Administration

GAO-03-386
In defining local administrative expenditures, all studies reviewed always 

included the school district Title I coordinator’s salary and benefits but, 

beyond this, their definitions varied. District spending classified as 

administrative in these studies varied, from 4 percent to 10 percent. In the 

six school districts we studied, definitions of administrative expenditures 

varied, in part because of differing state and local requirements or practices.

Because there is no common agreement on what constitutes administrative 

expenditures, GAO identified a set of categories as “administrative 

expenditures” for the purposes of this study and found that, in the six school 

districts, Title I expenditures for administrative activities ranged from 13 

percent of total Title I expenditures to no Title I funds spent on 

administration. Most Title I funding—at least 84 percent in every district—

was spent on activities related to instruction. In addition, most school 

districts spent a relatively small percentage of their Title I funds on other 

non-instructional expenditures, such as transportation. Title I expenditures 

represent allocation decisions made by the six school districts during a 

particular year and, because some administrative costs may have been 

covered by funds from sources other than Title I, do not necessarily reflect 

the total amount districts spent on Title I administration in that year. 

Percentage of Title I Funds Spent in Six School Districts on Instructional, Administration, 

and Other Noninstructional Expenditures, School Year 2000-01 

TITLE I

Although Definitions of Administrative 

Expenditures Vary, Almost All School 

Districts Studied Spent Less Than 10 

Percent on Administration 

www.gao.gov/cgi-bin/getrpt?GAO-03-386.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact Marnie Shaul at 

(202) 512-7215 or shaulm@gao.gov. 

Highlights of GAO-03-386, a report to the 

Committee on Health, Education, Labor 

and Pensions, United States Senate and 

the Committee on Education and 

Workforce, House of Representatives 

April 2003 

Because of concern about school 

district spending on administration,

Congress directed GAO in two 

separate mandates in the No Child 

Left Behind Act of 2001 to (1) 

examine how school districts 

defined and spent Title I funds on 

administrative activities and (2) 

review Title I expenditures in at 

least six school districts. In 

response to these mandates, we are 

reporting on (1) how five studies 

define Title I administrative 

expenditures and what they found 

about the percentage of funds 

spent on these activities and (2) 

what proportion of Title I funds 

was spent on administrative 

activities compared with 

instructional and other activities in 

six school districts. 
Page i GAO-03-386 Title I Administrative Expenditures 

Letter 1

Results in Brief 2

Background 3

Select Studies Used Varying Definitions of Administrative 

Expenditures 5

The Proportion of Title I Funding Spent on Administrative 

Activities Varied, but Most School Districts Spent Less Than 

10 Percent 10

Concluding Observations 14

Agency Comments 14

Appendix I Scope and Methodology 15 

Objectives 15

Scope and Methodology 15

Appendix II Comments from the U.S. Department of Education 23 

Appendix III GAO Contacts and Staff Acknowledgments 24 

Contacts 24

Acknowledgments 24

Tables 

Table 1: Expenditure Categories Considered to be Title I 

Administrative Expenditures in Five Selected Studies 6

Table 2: Summary of Studies Reviewed 7

Table 3: Proportion of Title I Spending by Type of Expenditure, 

School Year 2000-01, by Size of Title I Expenditures 12

Table 4: Number of Full-Time Equivalent Staff Funded by Title I 

and the Total Staff in the School Districts, School Year 

2000-01 13

Table 5: Characteristics of School Districts Selected, School Year 

2000-01 17

Table 6: Six School Districts’ Views of Whether Three Categories of 

Expenditures Are Title I Administrative Expenditures 18

Table 7: Description of Instructional, Administrative, and Other 

Noninstructional Expenditures Used in This Study 19

Contents 
Page ii GAO-03-386 Title I Administrative Expenditures 

Table 8: GAO Categories of Administrative Expenditures 

Compared with In$ite Administration-Related 

Expenditure Categories 20

Figure 

Figure 1: Percents of Total Title I and Total School District 

Expenditures Spent on Administration, School Year 

2000-01 11

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Page 1 GAO-03-386 Title I Administrative Expenditures 

April 7, 2003 

The Honorable Judd Gregg, Chairman 

The Honorable Edward M. Kennedy 

Ranking Minority Member 

Committee on Health, Education, Labor and Pensions 

United States Senate 

The Honorable John A. Boehner, Chairman 

The Honorable George Miller 

Ranking Minority Member 

Committee on Education and the Workforce 

House of Representatives 

In 2001, the Congress passed the No Child Left Behind Act (NCLB) in part 

to improve the academic achievement of disadvantaged children. The act 

also provided additional funding to school districts with students from 

low-income families. For fiscal year 2002, $10 billion was available through 

Title I of the act,1

 the largest source of federal funding for elementary and 

secondary education. To ensure that most of these funds were spent on 

instructional activities that improve student learning, in the conference 

report accompanying NCLB, the Congress indicated that only the 

necessary and appropriate amount of funds be used for administrative 

activities. However, the law does not specifically define administrative 

activities or set specific limits on administrative spending by school 

districts. 

We were directed in two separate mandates by the Congress to (1) 

examine how school districts defined and spent Title I funds on 

administrative activities and (2) review Title I expenditures in at least six 

school districts. In response to these mandates, we are reporting on (1) 

how five studies define Title I administrative expenditures and what they 

found about the percentage of funds spent on these activities and (2) what 

proportion of Title I funds was spent on administrative activities compared 

with instructional and other activities in six school districts. 

 1

Throughout this report, we refer to Title I, Part A of the No Child Left Behind Act as “Title 

I.” Part A of Title I in the act is directed at improving basic programs operated by local 

education agencies, which we refer to as “school districts” in this report. 

United States General Accounting Office

Washington, DC 20548 
Page 2 GAO-03-386 Title I Administrative Expenditures 

In response to the first mandate, we examined five studies related to Title I 

that we found in our literature review which defined school district 

administrative expenditures and the percentage of funds school districts 

spent on administration. In response to the second mandate, we 

conducted site visits in six school districts and gathered information about 

Title I expenditures to assess what proportion of Title I funding was spent 

on administrative activities compared with instructional and other 

activities. We selected six school districts in the following locations to 

ensure variation in enrollment size, ethnic composition, economic 

condition, and geographic location: Portsmouth, Rhode Island; Douglas 

County, Nevada; Jefferson Parish, Louisiana; Indianapolis, Indiana; St. 

Louis, Missouri; and San Diego, California. Because there is no agreement 

on a definition of administrative expenditures, in order to compare the six 

districts, we identified expenditure categories as “administrative” from our 

analysis of the five studies and consultations with school finance experts. 

The administrative expense categories include (1) the salaries and fringe 

benefits of Title I coordinators, managers, and administrative support 

staff; (2) support expenditures, such as equipment, for staff in category 

one, and (3) the salaries, fringe benefits and related expenditures for 

district- and school-level administrative leadership, such as principals. We 

then broke the districts’ total Title I spending into three subcategories: 

instruction and instructional support, administration, and other 

noninstructional activities, such as transportation. Because of the limited 

number of districts and other factors outlined in appendix I, our findings 

cannot be generalized to school districts nationwide. (Appendix I explains 

our methodology in more detail.) We conducted our work between April 

2002 and January 2003 in accordance with generally accepted government 

auditing standards. 

All studies reviewed included the school district Title I coordinator’s 

salary and benefits in their definition of local administrative expenditures, 

but, beyond this, their definitions varied. For example, professional 

development activities were included in one definition but not in others. 

District spending classified as administration in these studies varied, from 

4 percent to 10 percent. 

Using a set of administrative expenditure categories developed for this 

study we found that, in the six school districts we studied, Title I 

expenditures for administrative activities ranged from 13 percent of total 

Title I expenditures to no Title I funds spent on administration. However, 

only in one district did Title I administrative expenditures exceed 10 

percent. Most Title I funding—at least 84 percent in every district—was 

Results in Brief 
Page 3 GAO-03-386 Title I Administrative Expenditures 

spent on activities related to instruction. However, the amount of Title I 

funds spent on administration reflects school district decisions about how 

expenses for administrative activities are allocated among various 

programs. For example, Portsmouth, Rhode Island, spent no Title I funds 

on administration but conducts Title I administrative activities. The 

district pays for them with local funds, according to district officials. Four 

of the school districts spent a relatively small percentage of their Title I 

funds on other noninstructional expenditures, including student 

transportation, building maintenance, and capital projects. The Title I 

expenditures on administration represent allocation decisions made by the 

six school districts for a particular year and do not represent school 

district spending in other years. Such decisions may change from one 

school year to the next. 

States and localities provide most of the funding for public schools. In the 

1998-99 school year, funds from state and local governments accounted for 

93 percent of elementary and secondary school funding. Overall, states 

and localities contribute roughly an equal amount to educational 

programs, although individual state shares vary considerably. For 

example, in 1997, the state share in New Hampshire was 9 percent while in 

New Mexico it was 72 percent. The federal government also provides 

funding for elementary and secondary education, largely through the 

Elementary and Secondary Education Act (ESEA) of 1965. 

The NCLB Act of 2001 reauthorized ESEA. Title I of NCLB is intended to 

help elementary and secondary schools establish and maintain programs 

that will improve the educational opportunities of low-income and 

disadvantaged children. Title I funds are intended to provide instruction 

and instructional support for these disadvantaged children so that they 

can master challenging curricula and meet state standards in core 

academic subjects. Although NCLB incorporated new or expanded 

requirements for the Title I program that related to such issues as 

strengthening accountability for results, it does not stipulate exactly how 

these funds are to be spent. Instead, the Title I program is an example of 

flexible funding for state educational agencies and school districts. 

The Congress intended for most Title I funds to be spent on instruction 

and instructional activities, while limiting other costs, such as those on 

administrative activities. However, Title I does not contain a general 

definition of administrative expenses that school districts must use. Before 

the enactment of NCLB, ESEA required the U.S. Department of Education 

(Education) to conduct a study and report on the use of the funds for 

Background 
Page 4 GAO-03-386 Title I Administrative Expenditures 

administration under the act and, based on the results of that study 

develop a definition of what types of activities constitute administration. 

Within 1 year of the study, which was required to have been completed by 

July 1, 1997, Education was required to promulgate final regulations or 

guidance regarding the use of funds for administration under ESEA, 

including limitations on the amount of funds that may be used for 

administration where no limit had been specified in law.2

 Education did 

not develop a definition of administrative activities or issue regulations or 

guidance. However, these requirements were repealed by NCLB. 

While Education has not developed a specific definition of administrative 

activities for Title I, the agency’s general administrative regulations and 

guidance address the issue of how grantees should identify administrative 

costs. Education’s general administrative regulations contain a statement 

that “administrative requirements mean those matters common to grants 

in general, such as financial management, kinds and frequency of reports, 

and retention of records. These are distinguished from programmatic

requirements, which concern matters that can be treated only on a 

program-by-program or grant-by-grant basis, such as kinds of activities 

that can be supported by grants under a particular program.”3

 (Emphasis 

in original.) 

In response to the requirement in the ESEA that Education report on the 

results of its study, in 1998 the agency issued The Use of Federal 

Education Funds for Administrative Costs, which included a section 

entitled “Definitions of Administrative Spending.” The report includes a 

discussion of various definitions of administrative costs and activities 

described in law and guidance, definitions used by researchers, and 

“issues that should be considered in developing a definition of 

administrative costs for federal education programs.” The report refers to 

prior guidance issued by Education on what constitutes administrative 

costs where the term is not otherwise defined in statute or regulation.4

This guidance states that “[t]he costs of administration are those portions 

of reasonable, necessary and allowable costs associated with the overall 

project management and administration and which are not directly related 

 2

P.L. 103-382, title I,§101 (Oct. 20, 1994), amending ESEA. These requirements were 

repealed by NCLB. 

3

34 C.F.R. §80.3. 

4

U.S. Department of Education, Indirect Cost Determination: Guidance for State and 

Local Government Agencies, (Washington, D.C., 1997) pp. 72. 
Page 5 GAO-03-386 Title I Administrative Expenditures 

to the provision of services to participants or otherwise allocable to the 

program cost objectives/categories. These costs can be both personnel and 

nonpersonnel costs and both direct and indirect.

5

 (Emphasis in original.)6

The guidance provides a list of examples of direct administration such as 

the salaries, benefits, and other expenses of staff who perform overall 

program management, program coordination, and office management 

functions. 

All five studies we reviewed included the school district Title I 

coordinator’s salary and benefits in their definition of local administrative 

expenditures but, beyond this, the activities categorized as administration 

varied. District spending on administration in the five studies reviewed 

varied from 4 percent to 10 percent. Several factors may contribute to this 

variation, such as the use of different definitions of administrative 

expenditures or reliance on different data types, such as budget numbers 

or actual expenditures. 

Although they had common elements, the definitions of administrative 

expenditures used in the studies we reviewed varied. In all five of the 

studies, the salaries and benefits of school district Title I coordinators 

were considered to be administrative expenditures.7

 However, four of the 

studies used a definition that encompassed more than this. For example, 

four of the studies also included supplies and equipment to support Title I 

administration in their definition. Table 1 highlights the similarities and 

differences among the various definitions of administrative expenditures 

used in the studies. 

 5

Direct expenditures are those that can be specifically identified with a program, such as 

the salaries and benefits of program administrators. Indirect expenditures are for resources 

that cannot be specifically identified with a program, such as the portion of expenditures 

for data processing or accounting that support the program. 

6

While this document is termed “Guidance,” such guidance issued by the agency authorized 

to administer the program is generally binding in determining the allowability of costs. See 

California v. U.S., 547 F.2d 1388 (9th Cir. 1977). The overallocation of indirect costs, for 

example, would be considered unauthorized and, therefore, unallowable. Principles of 

Federal Appropriations Law, 2nd ed, vol. II, pps. 10-75. 

7

One study we examined did not include a definition of administration in their report. 

However, researchers used definitions developed by the National Center for Education 

Statistics when categorizing district expenditures. See table 2 for the center’s definition. 

This study is: U.S. Department of Education, Planning and Evaluation Service, Study of 

Education Resources and Federal Funding, (Washington, D.C.: 2000).

Select Studies Used 

Varying Definitions of 

Administrative 

Expenditures 

In Five Studies, Definitions 

of Administrative 

Expenditures Varied 
Page 6 GAO-03-386 Title I Administrative Expenditures 

Table 1: Expenditure Categories Considered to be Title I Administrative 

Expenditures in Five Selected Studies 

Expenditure categories Study 1a Study 2b Study 3c Study 4d Study 5e

Salaries and benefits of Title I 

coordinators 9 9 9 9 9

Supplies and equipment to 

support Title I administration

9 9 9 9

Salaries and benefits of Title I 

administrative support staff

9 9 9 9

Professional development for 

Title I coordinators and 

administrative support staff 

9

District administration (salaries 

and benefits for 

superintendents, school 

boards, senior administrators, 

and other central office staff) 

9 9

Researchers and program 

evaluators

9

School administration 

(principals and assistant 

principals) 

9 9

Business services (payroll, 

personnel, purchasing, 

accounting, and data 

processing) 

 9

Furniture, computers and 

supplies for school and district

administrators

9 9

Legal services 9 9

Source: GAO analysis.

a

U.S. Department of Education, Planning and Evaluation Service, Study of Education Resources and

Federal Funding. (Washington, D.C.: 2000). 

b

U.S. Department of Education Inspector General, Following Title I, Part A and Secondary School 

Vocational Education Program Dollars to the Schools in 36 LEAs Visited, (Atlanta, Ga.: 1998). 

c

U.S. Department of Education, Planning and Evaluation Service, Elementary and Secondary 

Education Division, The Use of Federal Education Funds for Administrative Costs, (Washington, D.C.: 

1998). 

d

Abt Associates,Inc. The Chapter 1 Implementation Study, Interim Report, Cambridge, Mass., 1992. 

e

U.S. General Accounting Office, Compensatory Education-Most Chapter 1 Funds in Eight Districts 

Used for Classroom Services, GAO/HRD-92-136FS (Washington, D.C.: Sept. 30, 1992). 

Using different definitions of administrative expenditures, estimates of 

Title I district spending on administration varied among the five studies 

that we reviewed (see table 2). The studies generally found that school 

districts spent between 4 percent and 10 percent of Title I funds on 

administrative activities. These estimates can also differ from school 

District Spending on Title I 

Administration Ranged 

from 4 Percent to 10 

Percent 
Page 7 GAO-03-386 Title I Administrative Expenditures 

district to school district within a single study. For example, Education’s 

1998 study of expenditure data from 41 school districts located in 3 states 

found that a school district in Milwaukee spent 4 percent of Title I funds 

on administrative activities, school districts in South Carolina spent an 

average of 6 percent on administrative activities, and school districts in 

Rhode Island spent an average of 10 percent on such activities. 

Table 2: Summary of Studies Reviewed 

Study 

School 

year of 

data 

reviewed 

Number of 

school 

districts 

sampled Definition of administration 

Estimate of Title I 

spending on 

administration (in 

percent)

U.S. Department of 

Education, Planning and 

Evaluation Service, 

Study of Education 

Resources and Federal 

Funding

1997-98 180 Although the study does not develop its own definition 

of administration, researchers used definitions 

developed for categorized district data in National 

Center for Education Statistics guidance contained in 

Financial Accounting for Local and State School 

Systems.

The National Center for Education Statistics definition 

includes two types of administration categories: general 

administration and school administration. Both 

categories include salaries, fringe benefits, furniture, 

equipment, and supplies associated with administrative 

activities. 

General administration: 

• Superintendent 

• School board 

• Labor relations and negotiations 

• Central office expenditures for administering special 

programs (e.g., Title I) and other central office 

expenditures 

• Legal services 

• Election services 

• Tax assessment and collection 

• Community relations 

• Grant procurement 

School administration: 

Principal’s office (including vice principals and 

administrative support) and full-time department 

chairpersons. 

8
Page 8 GAO-03-386 Title I Administrative Expenditures 

Study 

School 

year of 

data 

reviewed 

Number of 

school 

districts 

sampled Definition of administration 

Estimate of Title I 

spending on 

administration (in 

percent)

U.S. Department of 

Education Inspector 

General, Following Title 

I, Part A and Secondary 

School Vocational 

Education Program 

Dollars to the Schools in 

36 LEAs Visited

1996-97 36 Primarily included salaries, related benefits, and 

professional development for program coordinators and 

their administrative staff, as well as any materials and 

equipment used to support administrative functions. 

6

U.S. Department of 

Education, Planning and 

Evaluation Service, 

Elementary and 

Secondary Education 

Division, The Use of 

Federal Education 

Funds for Administrative 

Costs

1995-96 41 Based on Coopers & Lybrand Financial Analysis Model 

[currently called the In$ite model]. Divided 

administration into three categories: district and school 

administration and business services. Each of these 

three categories includes salaries and fringe benefits 

for administrative staff as well as non-personnel costs 

such as furniture, computers, and supplies. District 

administration includes superintendents, school boards, 

senior administrators, legal services, research and 

program evaluators, and other central office staff. 

School administration includes principals and assistant 

principals. Business services include payroll, 

purchasing, personnel, accounting, and data 

processing. For federal education programs, 

administrative costs will typically include salaries and 

expenses for district and school level federal program 

coordinators. 

4-10

Abt Associates, Inc. The 

Chapter 1 

Implementation Study, 

Interim Report

1990-91 1,600 Salaries and benefits for Title I administrators, including 

district staff. 

4

U.S. General Accounting 

Office, Compensatory 

Education-Most Chapter 

1 Funds in Eight Districts 

Used for Classroom 

Services, GAO/HRD-92-

136FS 

1990-91 8 Primarily salaries and benefits for Title I coordinators 

and administrative staff, as well as supplies and 

equipment used to support the program. 

10

Source: GAO analysis. 

A

The term “Chapter 1” was used until the 1994 reauthorization of ESEA to refer to what is now Title I. 

For clarity, this report will refer to the program as Title I even when discussing data collected prior to 

the 1994 reauthorization. 

Several factors, such as different definitions of administration or data 

types, may have contributed to the variety of findings among the studies 

we reviewed. The study that found that school districts were using the 

smallest percent of Title I funds for administration used the most limited 

definition of administration, only including the salaries and benefits of 

Title I administrators. Also, the scope of the studies differed. Two studies 

produced national estimates by reviewing a large number of school 
Page 9 GAO-03-386 Title I Administrative Expenditures 

districts nationwide, while the other three selected fewer school districts, 

and the findings were not generalizable to school districts nationwide. In 

addition, the studies’ data types for estimating administration spending 

were not the same. For example, two studies based their findings on 

budget estimates provided by school districts while the other three studies 

used expenditure reports from school districts. Finally, the studies 

reviewed expenditure data from different school years. 

The six school districts that we studied used different definitions of 

administrative expenditures, in part because of differing state and local 

requirements or practices. As a result, expenditures may be accounted for 

in different ways across the school districts we studied. Local officials in 

all six school districts agreed that salaries and benefits of Title I 

coordinators, managers, and administrative support staff who are engaged 

in basic program operation and management, such as office administration 

and program coordination, were administrative. However, beyond this, 

what district officials counted as administrative expenditures varied. For 

example, St. Louis school district officials considered staff time dedicated 

to the professional development of teachers as administration, while 

school district officials in Jefferson Parish, La., did not. 

In some cases, states may develop definitions of Title I administrative 

expenditures for school districts to limit the amount charged to the 

program for administration. Varying state accounting requirements and 

use of different state accounting handbooks may influence the 

characteristics of school district expenditure data. Two of the school 

districts we visited described state requirements that affect how school 

districts define and track expenditures in their state. For example, as part 

of the Title I application process, the state of Indiana encouraged school 

districts to reserve a maximum of 4 percent for administration and a 

minimum of 62 percent for instruction.8

 Taking a slightly different 

approach, the state of California education code directs school districts to 

spend at least 85 percent of their Title I allocation at schools for direct 

services to students, thereby limiting the amount that can be spent on 

other activities, including administration.9

 8

Title I Application Review Questions, Indiana Department of Education. 

9

California Education Code sec. 63001 (2000). 

In Six School Districts We 

Studied, Definitions of 

Administrative 

Expenditures Varied 
Page 10 GAO-03-386 Title I Administrative Expenditures 

Because there is no common agreement on what constitutes 

administrative expenditures, we identified a set of expenditure categories 

as “administrative” for the purposes of this study and found that, in the six 

school districts, Title I expenditures for administrative activities ranged 

from 0 percent to 13 percent of total Title I expenditures for the 2000-01 

school year.10 However, only in one district did Title I administrative 

expenditures exceed 10 percent. Most Title I expenditures—at least 84 

percent in every district—were spent on instructional activities. 

Instructional expenditures include spending on instruction and 

instructional support. Spending on instruction included the salaries of 

instructional teachers, paraprofessionals and substitutes. Spending on 

instructional support included classroom materials and pupil and teacher 

support. 

Administration for the purposes of this study include the following 

expenditure categories that we developed: 

• The salaries and fringe benefits of Title I coordinators, managers, and 

administrative support staff who are engaged in basic program 

operation and management, such as office administration and program 

coordination. 

• The related expenditures of coordinators, managers, and 

administrative support staff of Title I, such as equipment, supplies, 

furniture and business services required to support the administrative 

function, and auditing and legal services and data processing. 

• Salaries, fringe benefits, and related indirect expenditures for district 

or school-level administrative leadership (including school board, 

superintendent, superintendent’s cabinet, school principal, and vice 

principal) involved in directing and supervising staff who are providing 

instruction or instruction-related services for Title I programs. 

In the six school districts, the proportion of Title I funding spent on 

administrative activities varied, though most Title I funds were spent on 

instruction and instructional support. Of the six school districts, San Diego 

spent the largest percentage of Title I funds on administration (13 

percent), while Portsmouth, Rhode Island, spent none of its Title I funds 

 10Expenditure data from five of the six districts are from the 2000-01 school year. 

Expenditure data from Indianapolis, however, are from calendar year 2000. Hereafter, we 

will refer to the year of our data collection as school year 2000-01. 

The Proportion of 

Title I Funding Spent 

on Administrative 

Activities Varied, but 

Most School Districts 

Spent Less Than 10 

Percent 

The Proportion of Title I 

Funding Spent on 

Administration Varied 

among Six School Districts 
Page 11 GAO-03-386 Title I Administrative Expenditures 

on administration. Title I expenditures on administration represent 

allocation decisions made by the six school districts for a particular year. 

The amount of Title I funds spent on administration reflects school district 

decisions about what funds to use for administrative activities and not 

necessarily how much total funding was dedicated to the administration of 

Title I. For example, the Portsmouth school district does conduct Title I 

administrative activities, but pays for them with local funds. In all six 

school districts, the share of total Title I spending on administration was 

less than the share of total district spending on administration (see fig. 1). 

Figure 1: Percents of Total Title I and Total School District Expenditures Spent on 

Administration, School Year 2000-01 

Note: Expenditure data from Indianapolis are from calendar year 2000. 
Page 12 GAO-03-386 Title I Administrative Expenditures 

Though they spent different percentages of their Title I funds on 

administration, the types of administrative activities the six school 

districts chose to pay for with Title I funds were similar. In five of the six 

school districts, Title I coordinators were funded by Title I during the 

2000-01 school year. In all but the Portsmouth school district, Title I funds 

supported other district staff with Title I responsibilities, such as staff who 

provided technical assistance to the schools in specific areas such as 

finance, professional development, and technology. None of the school 

districts we visited used Title I funds to pay for activities by principals and 

vice principals. 

In all six school districts, most Title I funding was spent on activities 

related to instruction. Each school district spent at least 84 percent of its 

Title I funds on instruction and instructional support (see table 3). (See 

appendix I for details on what constitutes each type of expenditure.) 

Table 3: Proportion of Title I Spending by Type of Expenditure, School Year 2000-01, by Size of Title I Expenditures 

Instructional Administration Other noninstructional 

School district 

Total Title I 

expenditures Instruction 

Instructional 

support Total Total Operations Other Total 

Portsmouth, R.I. $110,912 100% 0% 100% 0% 0% 0% 0% 

Douglas County, Nev. $377,233 85% 8% 93% 7% 0% 0% 0% 

Jefferson Parish, La. $9,096,895 71% 14% 85% 6% 4% 5% 9% 

Indianapolis, Ind. $15,060,344 57% 27% 84% 3% 0% 12% 12% 

St. Louis, Mo. $18,658,131 81% 8% 90% 8% 0% 2% 2% 

San Diego, Calif. $32,547,153 57% 28% 85% 13% 0% 2% 2% 

Source: GAO’s data analysis of Title I spending. 

Notes: (1) Percentages do not represent total district spending on instructional, administrative, and 

other noninstructional activities. (2) Percentages reflect local Title I allocation decisions and not 

necessarily total expenditures in those spending categories, as state and local funds my be used in 

addition to or in place of Title I funds in any category. (3) The proportions of Title I funding spent on 

various activities reflect the decisions and circumstances of school districts for a particular year and 

do not represent school district spending in other years. (4) The proportion of Title I expenditures 

spent on instructional, administrative, and other noninstructional activities take into account direct and 

indirect expenditures. (For more information about how indirect expenditures were included in the 

analysis, see appendix I.) (5) Total Instructional, Administration, and Other Noninstructional 

percentages of total Title I expenditures may not sum to 100 percent due to rounding. (6) Expenditure 

data from Indianapolis are from calendar year 2000. 

In addition, four of the school districts spent a relatively small percentage 

of their Title I funds on other noninstructional expenditures, such as outof-district obligations, student transportation, building maintenance, and 

capital projects. Indianapolis spent the largest proportion of Title I funds 

Most Title I Funds Were 

Spent on Activities Related 

to Instruction 
Page 13 GAO-03-386 Title I Administrative Expenditures 

on other noninstructional expenditures, a majority of which were Title I 

payments to parochial, private, and charter schools.11

Title I funds were used to support staff in all of the school districts we 

studied. Table 4 provides the number of full-time equivalent teachers and 

teacher aides and other district staff funded by Title I as compared with 

the total full-time equivalent staff working in the school district. Title I 

staff represented between less than 1 percent and about 7 percent of total 

staff in the school districts. In districts with the smallest Title I grants, 

other district staff were funded only partially or not at all with the Title I 

grant. However, in the districts with the largest grants, other district staff, 

such Title I coordinators, were funded entirely by Title I. 

Table 4: Number of Full-Time Equivalent Staff Funded by Title I and the Total Staff 

in the School Districts, School Year 2000-01 

Funded by Title I 

School district 

Teachers & 

teacher aides Other staff Total staff 

Total district 

staff

Portsmouth, R.I. 2.33 0.00 2.33 345.50

Douglas County, Nev. 4.80 0.30 5.10 599.00

Jefferson Parish. La. 220.60 43.80 264.40 7,913a

Indianapolis, Ind. 205.68 56.49 262.17 5,800a

St. Louis, Mo. 329.50 96.50 426.00 6,324.00

San Diego, Calif. 175.17 126.09 301.26 15,059.49

Source: GAO’s analysis of school district staffing. 

a

Total district staff for Jefferson Parish and Indianapolis represents the number of employees rather 

than full-time equivalent staff. 

The proportions of Title I funding spent on various activities reflect the 

decisions and circumstances of school districts for a particular year. For 

example, in school year 2000-01 San Diego invested in teacher training in 

literacy at the start of a districtwide reform effort, which accounts for 

much of the high proportion (28 percent) spent on instructional support in 

that year. Similarly, Indianapolis spent 27 percent on instructional support 

in calendar year 2000, investing in pupil, teacher, and program support. 

Some school district officials noted that spending decisions might change 

in the future due to new federal requirements. They pointed out that a 

 11These payments may be used for instructional activities in parochial, private, or charter 

schools. However, because these payments are not for instruction at public schools they 

are, therefore, categorized as other noninstructional expenditures. 
Page 14 GAO-03-386 Title I Administrative Expenditures 

larger proportion of Title I funds may be needed for administrative and 

other noninstructional activities due to new requirements in the NCLB Act. 

For example, officials from two school districts said that the 

implementation of the school choice provisions in NCLB may increase 

transportation costs. A new requirement in NCLB stipulates that school 

districts must offer students in Title I schools that do not perform 

adequately for 2 consecutive years the option of transferring to another 

public school. School districts must provide transportation for, or pay the 

transportation costs of, the students who choose this option. 

This report provides insights from studies about administrative 

expenditures and a snapshot of Title I expenditures in six school districts 

for 1 year. Although definitions of administrative expenditures varied, the 

studies and our work in six districts suggest that despite the flexibility 

school districts have in the use of these federal funds, they limited Title I 

spending for administration and spent most Title I funds on instruction. 

We received comments from Education on a draft of this report, which are 

reprinted in appendix II. Education found the report to be informative and 

noted that the report should be useful to the Congress, Education itself, 

and state and local grantees. 

We are sending copies of this report to the Secretary of Education, 

appropriate congressional committees, and other interested parties. 

Copies will also be made available at no charge on GAO’s Web site at 

http://www.gao.gov. If you or your staff have any questions or wish to 

discuss this material further, please call me at (202) 512-7215. 

Marnie S. Shaul 

Director, Education, Workforce, 

 and Income Security Issues 

Concluding 

Observations 

Agency Comments 
Appendix I: Scope and Methodology 

Page 15 GAO-03-386 Title I Administrative Expenditures 

The objectives of our review were to report on (1) how five studies define 

Title I administrative expenditures and what they found about the 

percentage of funds spent on these activities and (2) what proportion of 

Title I funds was spent on administrative activities compared with 

instructional and other activities in six school districts. 

To assess how selected studies define Title I administrative expenditures, 

we conducted a literature review of studies and reports related to Title I 

and what they found about the percentage of funds spent on these 

activities. Each of these studies included an estimate of the percentage of 

Title I funds that school districts spent on administrative activities. 

Because there is no common agreement on what constitutes 

administrative expenditures, for the purposes of this study, we identified a 

set of expenditure categories as “administrative” based on federal 

guidance, previous studies, and interviews with subject matter experts. To 

assess what proportion of Title I funding specific school districts spent on 

administrative activities compared with instructional and other activities, 

we conducted site visits to five school districts and telephone interviews 

with officials from an additional school district. We gathered information 

about Title I administrative expenditures for the 2000-01 school year1

 and 

analyses of expenditure reports from six school districts. Officials in six 

school districts we surveyed provided us with feedback on which of our 

three expenditure categories they considered to be administrative 

expenditures. We contracted with a consulting firm to analyze school 

district Title I expenditures using the three expenditure categories. Due to 

the limited number of districts, however, our findings cannot be 

generalized to school districts nationwide. We conducted our review 

between April 2002 and January 2003 in accordance with generally 

accepted government auditing standards. 

To assess how selected studies define Title I administrative expenditures, 

we conducted a literature review of studies and reports related to Title I. 

Literature was gathered by conducting bibliographic searches of major 

educational databases2

 and through consultation with experts in school 

 1

Expenditure data from five of the six districts are from the 2000-01 school year. 

Expenditure data from Indianapolis, however, are from calendar year 2000. Hereafter, we 

will refer to the year of our data collection as school year 2000-01. 

2

Databases searched include Pro Quest, Education Resource Information Center, and the 

Database of Department of Education Publications in ERIC. 

Appendix I: Scope and Methodology 

Objectives 

Scope and 

Methodology 

Literature Review 
Appendix I: Scope and Methodology 

Page 16 GAO-03-386 Title I Administrative Expenditures 

finance. We examined five studies that met the following criteria: (1) 

included data on school district Title I spending on administration; (2) 

reviewed school districts located in more than one state; and (3) was 

published after 1990. Each of the studies reviewed included an estimate of 

the percentage of Title I funds that school districts spent on administrative 

activities. The studies we examined include: 

• U.S. Department of Education, Planning and Evaluation Service, Study 

of Education Resources and Federal Funding (Washington, D.C.: 

2000). 

• U.S. Department of Education Office of Inspector General, Following 

Title I, Part A and Secondary School Vocational Education Program 

Dollars to the Schools in 36 LEAs Visited (Atlanta, Ga.: 1998). 

• U.S. Department of Education, Planning and Evaluation Service, 

Elementary and Secondary Education Division, The Use of Federal 

Education Funds for Administrative Costs (Washington, D.C.: 1998). 

• Abt Associates Inc., The Chapter 1 Implementation Study, Interim 

Report (Cambridge, Mass.: 1992). 

• U.S. General Accounting Office, Compensatory Education-Most 

Chapter 1 Funds in Eight Districts Used for Classroom Services,

GAO/HRD-92-136FS (Washington, D.C.: Sept. 30, 1992). 

To assess what proportion of Title I funding spent by specific school 

districts on administrative activities compared with instructional and other 

activities, we gathered information about Title I administrative 

expenditures for the 2000-01 school year through site visits to five school 

districts and analysis of their expenditure reports. We gathered 

information about a sixth school district through telephone interviews 

with district officials and analysis of its expenditure reports. 

We selected the school districts based on the characteristics described in 

our congressional mandates, including variation in enrollment size, ethnic 

composition, economic condition, and geographic location. We also 

considered the ability of the consultant to analyze the expenditures of 

school districts selected. All school districts, with the exception of San 

Diego, California, used a financial reporting model called In$ite, which is 

used by Fox River Learning, the consulting firm we worked with to 

categorize expenditures. Although the school district did not use the 

Site Visits 
Appendix I: Scope and Methodology 

Page 17 GAO-03-386 Title I Administrative Expenditures 

model, we selected San Diego because it added to the geographic 

dispersion of the sample and represented a large metropolitan area. See 

table 5 for characteristics of the school districts selected. In addition to 

San Diego, we selected school districts in the following locations: 

Portsmouth, Rhode Island; Douglas County, Nevada; Jefferson Parish, 

Louisiana; Indianapolis, Indiana; and St. Louis, Missouri. Because of the 

limited number of districts selected, our findings cannot be generalized to 

school districts nationwide. 

Table 5: Characteristics of School Districts Selected, School Year 2000-01 

School district 

Student 

enrollment Locale & region 

% Minority 

enrollment

% Eligible for 

free/reduced 

price lunch

Portsmouth, R.I. 2,869 Small town, 

northeast 

4% 7%

Douglas County, Nev. 7,022 Rural, west 14% 21%

Jefferson Parish, La. 51,413 Urban fringe of a 

large city, south 

61% 68%

Indianapolis, Ind. 41,108 Large central 

city, midwest 

68% 76%

St. Louis, Mo. 41,400 Large central 

city, midwest 

83% 83%

San Diego, Calif. 141,804 Large central 

city, west 

73% 62%

Source: Locale and region from National Center for Education Statistics Common Core of Data. Student enrollment, percent minority 

enrollment, percent eligible for free and reduced price lunch reported by the school districts for school year 2000-01. 

To compare the six school districts, we identified a set of expenditure 

categories as “administrative,” based on federal guidance, previous 

studies, and interviews with experts in school finance.3

 We identified those 

administrative activities mentioned most frequently by experts or 

identified in the documents we reviewed. See table 6, which illustrates 

which of these three categories each district included in its definition of 

Title I administrative expenditures. 

During our interviews, school district officials stated whether they 

considered our three categories of expenditures to be administrative 

 3

We consulted with the following school finance experts: Dr. Lawrence Picus, University of 

Southern California; Dr. Jay Chambers, American Institutes for Research; Stephanie 

Stullich, Planning and Evaluation Service, U.S. Department of Education; Dr. Donald 

Tetreault, University of South Carolina; and Dr. William Fowler, National Center for 

Education Statistics, U.S. Department of Education. 

Our Categorization of 

Administrative Activities 
Appendix I: Scope and Methodology 

Page 18 GAO-03-386 Title I Administrative Expenditures 

expenditures under the program. School district officials in all six school 

districts agreed that salaries and benefits of Title I coordinators and 

administrative support staff were administrative expenditures under the 

Title I program. However, agreement on the other two categories of 

expenditures was not unanimous. 

Table 6: Six School Districts’ Views of Whether Three Categories of Expenditures Are Title I Administrative Expenditures 

Three categories of expenditures 

Category 1 

The salaries and fringe benefits 

of Title I coordinatorsa

managers and administrative 

support staff who are engaged 

in basic program operation and 

management, such as office 

administration and program 

coordination.

Category 2 

The related costs of 

coordinators, managers, and 

administrative support staff of 

Title I, such as equipment, 

supplies, furniture and business 

services required to support the 

administrative function, and 

auditing and legal services and 

data processing.

Category 3 

Salaries, fringe benefits, and 

related indirect expenditures 

for district or school level 

administrative leadership 

(including school board, 

superintendent, school 

principal, and vice principal) 

involved in directing and 

supervising staff who are 

providing instruction or 

instruction-related services for 

Title I programs. 

School district 

Portsmouth, R.I. Yes Yes,b with exceptions Yes,b ,e with exceptions 

Douglas County, Nev. Yes No No 

Jefferson Parish, La. Yes Yes Yes,c with exceptions 

Indianapolis, Ind. Yes Yes Yes,d,e with exceptions 

St. Louis, Mo. Yes Yes Yese

San Diego, Calif. Yes Yes No 

Source: GAO analysis. 

a

For these categories, Title I coordinators are responsible for managing the Title I program for the 

district and are equivalent to managers or directors. 

b

Portsmouth agreed with Category 2, with the exception of coordinators and managers, and Category 

3, with the exception of school board. 

c

Jefferson Parish agreed with Category 3, with the exception of school principals and vice principals. 

d

Indianapolis agreed with Category 3, with the exception of school board and superintendent. 

e

Although Portsmouth, Indianapolis, and St. Louis considered expenditures associated with principals 

and vice principals to be allowable Title I expenditures, none charged any of their salaries to Title I in 

2000-01. 

Table 7 summarizes how we classified instructional, administrative, and 

other noninstructional expenditures for this study. 
Appendix I: Scope and Methodology 

Page 19 GAO-03-386 Title I Administrative Expenditures 

Table 7: Description of Instructional, Administrative, and Other Noninstructional 

Expenditures Used in This Study 

Expenditure Activities 

Instructional 

Instruction • Face-to-face teaching (salaries of instructional teachers 

and paraprofessionals, substitutes) 

Instructional support • Classroom materials (pupil-use technology and software; 

instructional materials, trips, and supplies). 

• Pupil support (guidance and counseling; library and 

media; extracurricular; and student health and services). 

• Teacher support (curriculum development; in-service, 

staff development and support; and sabbaticals). 

Administrative • The salaries and fringe benefits of Title I coordinators, 

managers, and administrative support staff who are 

engaged in basic program operation and management, 

such as office administration and program coordination. 

• The related expenditures of coordinators, managers, and 

administrative support staff of Title I, such as equipment, 

supplies, furniture, and business services (auditing, legal 

services, and data processing) required to support the 

administrative function. 

• Salaries, fringe benefits, and related indirect expenditures 

for district or school level administrative leadership 

(including school board, superintendent, superintendent’s 

cabinet, school principal, and vice principal) involved in 

directing and supervising staff who are providing 

instruction or instruction-related services for Title I 

programs. 

Other noninstructional 

(operations + other 

commitments) 

• Noninstructional pupil services (transportation, food 

service, and safety). 

• Facilities (building upkeep, utilities, and maintenance). 

• Budgeted contingencies. 

• Capital (debt service and capital projects). 

• Out-of-district obligations (parochial, private, charter and 

public school pass through; retiree benefits; 

enterprise/community service operations). 

• Legal obligations (claims and settlements). 

Source: GAO analysis. 

To expedite data collection and analysis, we contracted with a consulting 

firm selected via a competitive bidding process to analyze school district 

Title I expenditures. The expenditure reports were produced by Fox River 

Learning, an education consulting firm using their analytical tool, the 

In$ite model, formerly known as the Coopers and Lybrand Finance 

Analysis Model. The model is used by 400 school districts across the 

country. Five of the six school districts we selected for this study used the 

Education Consulting Firm 

Contract 
Appendix I: Scope and Methodology 

Page 20 GAO-03-386 Title I Administrative Expenditures 

model in the past for a variety of purposes, such as calculating the cost per 

student by school and identifying the proportion of funds spent on 

instruction and schools with the greatest needs. One school district, San 

Diego, did not use the model, but the consultant worked with the district 

to categorize its Title I expenditures using the model. Table 8 shows how 

our set of administrative expenditure categories relates to the model. 

Table 8: GAO Categories of Administrative Expenditures Compared with In$ite

Administration-Related Expenditure Categories 

GAO categories of administrative 

expenditures 

In$ite model administration-related 

expenditure categories 

The salaries and fringe benefits of Title 

I coordinators, managers, and 

administrative support staff who are 

engaged in basic program operation 

and management, such as office 

administration and program 

coordination. 

Program development/management

Salaries and related employment costs of staff 

who manage and coordinate the Title I 

program. Includes office costs and clerical 

costs associated with the administrator’s 

activities. 

The related expenditures of 

coordinators, managers, and 

administrative support staff of Title I, 

such as equipment, supplies, furniture, 

and business services required to 

support the administrative function, and 

auditing and legal services and data 

processing. 

Business services

Salaries and related employment costs 

associated with data processing, payroll, 

human resources, accounting and finance, 

auditing, and procurement. 

Salaries, fringe benefits, and related 

indirect expenditures for district or 

school-level administrative leadership 

(including school board, 

superintendent, superintendent’s 

cabinet, school principal, and vice 

principal) involved in directing and 

supervising staff who are providing 

instruction or instruction-related 

services for Title I programs. 

School management

Salaries and related employment costs of 

principals, assistant principals, and 

administrative support staff for the principal and 

assistant principals. 

District management

Salaries and related employment costs of the 

superintendent, the superintendent’s cabinet 

(deputies, senior administrators, researchers, 

and program evaluators), the school board, and 

the legal department. 

Source: GAO analysis. 

We did not verify the reliability of the data collected from school districts 

that were entered into the model. However, to assess the accuracy of the 

data school districts provided to the consultant, we reviewed the district’s 

most recent independent audit report related to the internal control 

structure. These reports did not disclose any material weaknesses in 
Appendix I: Scope and Methodology 

Page 21 GAO-03-386 Title I Administrative Expenditures 

internal controls. In addition, all school districts reported how they 

monitored Title I funds spent at the school level. 

We did not verify the reliability of the expenditure reports. However, we 

took steps to ensure the reliability of the consulting firm, including 

interviewing a current and a former user of the firm’s model and reviewing 

descriptions of the process the firm uses to input, categorize, and perform 

quality assurance on the data provided by school districts. The U.S. 

Department of Education worked with this finance analysis model when it 

was known as the Coopers and Lybrand Finance Analysis Model. In 

addition, all six school districts confirmed that the data from the 

expenditure reports included in this report were accurate. 

The proportion of Title I expenditures spent on instructional, 

administrative, and other noninstructional activities take into account 

direct and indirect expenditures. Direct expenditures are those that can be 

specifically identified with a program, such as the salaries and benefits of 

program administrators. Indirect expenditures are those that cannot be 

specifically identified with a program, such as general administrative 

services. 

The indirect cost rate represents the ratio of the school district’s total 

indirect costs to some element of its direct costs. The rates are calculated 

by state education agencies using a methodology that is approved by 

Education. Indirect cost rates may vary among school districts due to 

differing financial management and accounting policies. It is difficult to 

compare indirect cost rates among school districts. Under Title I, school 

districts must use a restricted indirect cost rate, which is a rate that does 

not include state and local costs that would be incurred with or without 

the existence of the federal program. 

Administrative expenditures were determined by adding the indirect 

administrative expenditures to the direct administrative expenditures. 

During the 2000-01 school year or fiscal year, three of the six school 

districts we reviewed did not charge indirect costs to Title I. For example, 

in Portsmouth, Rhode Island, district officials said that they used their 

allocation solely for salaries of teachers and teacher aides, leaving no 

additional dollars to charge to Title I. Three school districts, San Diego, 

Douglas County, and Indianapolis, did charge indirect costs to Title I. The 

indirect cost rates used by these school districts during the 2000-01 school 

year or fiscal year were 4.15 percent, 2.60 percent, and 2.01 percent 

applied to direct expenditures, respectively. Since accounting for indirect 

Indirect Cost Rates 
Appendix I: Scope and Methodology 

Page 22 GAO-03-386 Title I Administrative Expenditures 

expenditures varies among school districts, the consultant worked with 

school district officials to determine the category most appropriate for 

indirect expenditures. 
Appendix II: Comments from the U.S. 

Department of Education 

Page 23 GAO-03-386 Title I Administrative Expenditures 

Appendix II: Comments from the U.S. 

Department of Education 
Appendix III: GAO Contacts and Staff 

Acknowledgments 

Page 24 GAO-03-386 Title I Administrative Expenditures 

Eleanor L. Johnson, (202) 512-7209 

In addition to the staff named above, Virginia Vanderlinde and Catherine 

Roark made major contributions in leading and staffing this assignment. 

Julianne Hartman-Cutts and Corinna Nicolaou also made key 

contributions to this report. 

Appendix III: GAO Contacts and Staff 

Acknowledgments 

Contacts 

Acknowledgments 

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