United States Government Accountability Office

GAO Report to Congressional Requesters

NO CHILD LEFT 

BEHIND ACT 

Education Should 

Clarify Guidance and 

Address Potential 

Compliance Issues for 

Schools in Corrective 

Action and 

Restructuring Status 

September 2007 

 

GAO-07-1035 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2007

NO CHILD LEFT BEHIND ACT 

Education Should Clarify Guidance and 

Address Potential Compliance Issues for 

Schools in Corrective Action and 

Restructuring Status 

Highlights of GAO-07-1035, a report to 

congressional requesters 

The No Child Left Behind Act of 

2001 (NCLBA) focused national 

attention on improving schools so 

that all students reach academic

proficiency by 2014. In the 2006-

2007 school year, about 4,500 of the 

54,000 Title I schools failed to

make adequate yearly progress 

(AYP) for 4 or more years. Schools 

that miss AYP for 4 years are

identified for corrective action, and

after 6 years, they must be

restructured. GAO examined 

(1) the characteristics of Title I

schools in corrective action and 

restructuring; (2) the actions that 

schools in corrective action and 

restructuring implemented; (3) the 

assistance those schools received

from districts and states; and 

(4) how Education supports states 

in their efforts to assist these 

schools. GAO administered two 

Web-based surveys to a nationwide

sample of schools in corrective 

action and restructuring status and

conducted site visits to five states.

What GAO Recommends

GAO recommends that the

Secretary of Education provide 

guidance on when schools in 

corrective action may continue 

previously implemented corrective 

actions rather than implementing

new ones; direct states to report 

information on activities taken by

each school in corrective action or

restructuring; and take additional 

steps to ascertain whether states

are ensuring that districts provide 

the required assistance to schools. 

Education agreed with these 

recommendations. 

Nationwide, the 2,790 Title I schools that were in corrective action or 

restructuring status in the 2005-2006 school year were more frequently 

located in urban areas and in a few states. These schools served higher 

percentages of minority, poor, and middle-school students than other Title I 

schools, and many report that factors such as neighborhood violence and 

student mobility pose additional challenges to improving student academic

performance. As state proficiency targets continue to increase to 100 percent 

in 2014, the number of schools in corrective action and restructuring may 

increase. 

A majority of schools in corrective action or restructuring status 

implemented required activities. However, in some cases, schools may not 

be meeting NCLBA requirements. GAO estimates that 6 percent of schools 

did not take any of the required corrective actions and that about a third 

continued corrective actions implemented during earlier years of school 

improvement but did not take a new action after entering corrective action 

status. While this course of action may be an appropriate path for some 

schools to take, the Department of Education has not provided guidance to 

districts delineating when continuing a corrective action is appropriate and 

when it is not. In addition, about 40 percent of schools did not take any of 

the five restructuring options required by NCLBA. While states are required 

to report annually to the Department of Education the measures taken by 

schools in improvement status, Education does not require states to report 

on the specific measures taken for each school. 

GAO estimates that 42 percent of the schools in corrective action or 

restructuring did not receive all required types of assistance through their 

school districts, although most received discretionary assistance from their 

state educational agencies. Districts are required to ensure that several types

of assistance are provided to all schools in improvement status, including 

those in corrective action and restructuring status. This assistance includes

help in analyzing students’ assessment data and revising school budgets so 

that resources are allocated to improvement efforts. NCLBA generally does 

not require states to provide specific kinds of assistance to schools in 

corrective action or restructuring; however, they are required to develop a 

statewide system of support, including school support teams to provide 

technical assistance to schools and districts. Most schools received some 

type of assistance from the state educational agency. 

 

Education provides technical assistance and research results to states 

primarily through its Comprehensive Centers Program. Education also has 

provided more material in its Web-based clearinghouse to address a greater 

number of topics and is developing an initiative to outline practical steps for 

schools in improvement, including those in restructuring. 

www.gao.gov/cgi-bin/getrpt?GAO-07-1035.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cornelia Ashby 

at (202) 512-7215 or ashbyc@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 6

Schools in Corrective Action and Restructuring Were More Often 

Located in Urban School Districts and Served Higher 

Percentages of Minority, Poor, and Middle-School Students Than 

Other Title I Schools 13 

Most Schools Used a Corrective Action or Restructuring Option, 

but Some May Not be Meeting NCLBA Requirements 22 

Many Schools in Corrective Action and Restructuring Did Not 

Receive All Required Assistance through Their School Districts; 

However, Most Received Assistance from Their State 31 

Education Provides Technical Assistance and Research on School 

Improvement, Including Some Specific Information on School 

Restructuring 35

Conclusions 38

Recommendations 39

Agency Comments and Our Evaluation 39 

Appendix I Scope and Methodology 41 

Objective 1: Analysis of School Characteristics 41 

Objectives 2 and 3: Implementation of Corrective Action and

Restructuring and State and District Assistance 44 

Objective 4: Education’s Efforts to Support State Implementation 50 

Appendix II Number of Schools in Corrective Action, Planning for 

Restructuring, and Implementing Restructuring, by 

State in 2005-2006 and 2006-2007 51 

Appendix III Comments from the Department of Education 53 

Appendix IV GAO Contacts and Acknowledgments 55 

Related GAO Products 56 

Page i GAO-07-1035 Schools in Corrective Action and Restructuring
Tables 

Table 1: Timeline for Implementing Interventions for Schools That 

Do Not Make Adequate Yearly Progress 8 

Table 2: Allowable Activities for Schools in Corrective Action and 

Restructuring 9

Table 3: NCLBA Technical Assistance Districts Are Required to 

Ensure for Schools Identified for Improvement, Including 

Those in Corrective Action and Restructuring 10 

Table 4: Education, State, and District Responsibilities for 

Monitoring States, Districts, and Schools Identified for 

Improvement 12

Table 5: Percentage of Schools in Corrective Action and 

Restructuring and All Other Title I Schools in 2005-2006, by

Locale 14

Table 6: Percentage of Schools Nationwide in Corrective Action 

and Restructuring in the Top 5 School Districts in School 

Year 2005-2006 14 

Table 7: Percentage of Students with Selected Characteristics, 

Comparing Schools in Corrective Action and Restructuring 

with All Other Title I Schools, by Locale 17 

Table 8: Percentage of Schools in Corrective Action and 

Restructuring Compared to All Other Title I Schools, by 

Grade Level 18 

Table 9: Grade Level Definitions 42 

Table 10: School Districts Selected for Site Visits 49 

Table 11: Number of Schools in Corrective Action, Planning 

Restructuring, and Implementing Restructuring, by State in

2005-2006 and 2006-2007 51 

Page ii GAO-07-1035 Schools in Corrective Action and Restructuring
Figures 

Figure 1: Number of Title I Schools Identified for Corrective 

Action, Planning for Restructuring, and Implementing 

Restructuring in 2005-2006 13 

Figure 2: Number of Schools in Corrective Action and 

Restructuring in School Year 2005-2006, by State 15 

Figure 3: Number of Schools in Corrective Action and 

Restructuring for the 3 Most Recent School Years 19 

Figure 4: Change in the Number of Schools in Corrective Action 

and Restructuring from 2005-2006 to 2006-2007, by State 21 

Figure 5: Corrective Actions Allowed under NCLBA and Estimated 

Percentage of Schools That Implemented Each Action in 

2005-2006 23

Figure 6: Restructuring Options Allowed under NCLBA and 

Estimated Percentage of Schools That Implemented Each 

Option 25

Figure 7: Among Schools Implementing “Other” Major 

Restructuring, Estimated Percentage of Schools 

Implementing Various Activities 27 

Figure 8: The Estimated Percentage of Schools in Corrective 

Action and Restructuring That Received Each Form of 

Required Technical Assistance through Districts in School 

Year 2005-2006 32 

Figure 9: Estimated Percentage of Schools in Corrective Action and 

Restructuring in 2005-2006 That Received State Assistance 35 

Figure 10: Education’s Content and Regional Centers 36 

Page iii GAO-07-1035 Schools in Corrective Action and Restructuring
Abbreviations 

AYP adequate yearly progress 

CCD Common Core of Data 

CSPR Consolidated State Performance Reports 

Education Department of Education 

ESEA Elementary and Secondary Education Act of 1965 

IASA Improving America’s Schools Act of 1994 

NCLBA No Child Left Behind Act of 2001 

SES supplemental education services 

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

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Page iv GAO-07-1035 Schools in Corrective Action and Restructuring
United States Government Accountability Office

Washington, DC 20548 

September 5, 2007 

The Honorable Edward M. Kennedy 

Chairman 

The Honorable Michael B. Enzi 

Ranking Member 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Edward M. Kennedy 

Chairman 

The Honorable Michael B. Enzi 

Ranking Member 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Christopher J. Dodd 

Chairman 

The Honorable Lamar Alexander 

Ranking Member 

Subcommittee on Children and Families 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Christopher J. Dodd 

Chairman 

The Honorable Lamar Alexander 

Ranking Member 

Subcommittee on Children and Families 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

Over the past 40 years, the Elementary and Secondary Education Act of 

1965 (ESEA) has authorized billions of dollars in federal grants to states 

and school districts to improve educational opportunities for economically 

disadvantaged students. Despite this investment, the academic 

performance of disadvantaged students is still substantially lower than 

that of more advantaged students. Congress, with the enactment of the No 

Child Left Behind Act of 2001 (NCLBA)1

—the most recent reauthorization 

of ESEA—sought to address this issue by holding public schools 

accountable for the academic performance of their students by requiring 

that all students reach proficiency in reading, math, and science by 2014. 

In particular, districts and schools receiving funds under Title I of NCLBA 

are required to take certain actions when students do not make sufficient

progress toward meeting state proficiency targets.2

 However, many Title I

schools, which comprise over half of all public schools and serve about 

26 million students, continue to struggle to raise student achievement. In 

the 2006-2007 school year, about one-fifth of the 54,000 Title I schools had 

failed to make adequate yearly progress (AYP) for at least 2 consecutive 

Over the past 40 years, the Elementary and Secondary Education Act of 

1965 (ESEA) has authorized billions of dollars in federal grants to states 

and school districts to improve educational opportunities for economically 

disadvantaged students. Despite this investment, the academic 

performance of disadvantaged students is still substantially lower than 

that of more advantaged students. Congress, with the enactment of the No 

Child Left Behind Act of 2001 (NCLBA)

 

1

—the most recent reauthorization 

of ESEA—sought to address this issue by holding public schools 

accountable for the academic performance of their students by requiring 

that all students reach proficiency in reading, math, and science by 2014. 

In particular, districts and schools receiving funds under Title I of NCLBA 

are required to take certain actions when students do not make sufficient

progress toward meeting state proficiency targets.2

 However, many Title I

schools, which comprise over half of all public schools and serve about 

26 million students, continue to struggle to raise student achievement. In 

the 2006-2007 school year, about one-fifth of the 54,000 Title I schools had 

failed to make adequate yearly progress (AYP) for at least 2 consecutive 

1

Pub. L. No. 107-110. 

2

In this report, we refer to Title I, Part A of NCLBA as “Title I.” Other Parts of Title I (Parts

B through I) generally are targeted at specific populations or purposes and are commonly 

referred to by their program names, such as Education of Migratory Children. 

Page 1 GAO-07-1035 Schools in Corrective Action and Restructuring
years, and about 4,500 of these schools had not made AYP for 4 or more 

years. Under NCLBA, when a Title I school does not make AYP for 4 years, 

the school enters corrective action, and the district must take a statutorily 

prescribed action to improve the school, such as replacing selected 

teaching staff. If the school fails to make AYP for 6 years, the district is 

required to restructure the school by changing how the school is 

governed.3

 Such changes may include closing the school and re-opening it 

as a charter school or turning the operation of the school over to the state 

educational agency. As annual goals leading up to the 2014 deadline 

continue to increase, more schools are expected to enter corrective action 

and restructuring and will be required to take major action to improve. 

However, little is known about what specific corrective actions or 

restructuring options schools are currently implementing nationwide, the 

extent to which these actions are associated with making AYP, and the

support that schools in corrective action and restructuring have received 

from school districts and states as they attempt to improve student 

performance. In order to shed light on these issues and help the Congress

prepare for reauthorization of the NCLBA, you asked GAO to answer the 

following questions: (1) What are the characteristics of Title I schools in 

corrective action and restructuring? (2) To what extent have schools in 

corrective action and restructuring implemented corrective actions or 

restructuring options? (3) What assistance have schools in corrective 

action and restructuring received from districts and states? and (4) How 

has the Department of Education (Education) supported states in their 

efforts to assist schools in corrective action and restructuring status? 

To provide information on these topics, we collected data through 

multiple methods. We obtained data on which schools were in corrective 

action and restructuring for the 2005-2006 school year. States reported 

these data to Education through the Consolidated State Performance 

Report process, which collects annual information from states on ESEA 

programs. We matched data on these schools with additional data in 

Education’s Common Core of Data (CCD), conducted descriptive analyses 

of selected characteristics, and compared them to all other Title I schools. 

We also administered two Web-based surveys sent to 470 principals in a 

nationwide sample of schools in corrective action and restructuring during 

 3

Of the 4,509 schools that had not made AYP for 4 or more consecutive years, 2,330 were in 

corrective action; 937 were planning for restructuring; and 1,242 were in restructuring

status. 

Page 2 GAO-07-1035 Schools in Corrective Action and Restructuring
the 2005-2006 school year. We administered the surveys between January 

and March 2007 and received a combined response rate of about 

70 percent. Percentage estimates from the surveys have margins of error 

of plus or minus 8 percentage points using a 95 percent confidence 

interval, unless otherwise noted. While we did not fully validate specific 

information that school officials reported in our survey, we took several 

steps, including corroborating evidence of some schools’ improvement 

status, to ensure that the information provided by school officials was 

sufficiently reliable for the purposes of this report. We conducted site 

visits to 5 states (California, Illinois, Maryland, New York, and 

Pennsylvania) and 10 school districts with schools in corrective action, 

restructuring, or both, as well as 20 schools in those districts. The states, 

districts, and schools selected for site visits not only provided variation 

across such characteristics as geographic location and district size, but 

also generally resembled all schools in corrective action and restructuring 

in terms of students’ racial, ethnic, and economic characteristics. 

Together, schools in these 5 states accounted for over 59 percent of 

schools in corrective action and restructuring nationally in the 2005-2006 

school year. We also interviewed state officials from several states (Idaho,

South Dakota, Texas, and Virginia) that had few schools in correction 

action or restructuring to obtain information on how their state 

educational agencies are working with districts on school improvement 

issues. We reviewed relevant federal laws, regulations, and agency 

guidance and interviewed Education officials to obtain information about 

how they monitor and provide assistance to states and districts. We also 

interviewed officials in some of Education’s comprehensive and regional 

assistance centers. We analyzed relevant Education documents and 

studies and reports issued by policy and research organizations on schools 

in corrective action and restructuring and interviewed staff in many of 

these organizations. See appendix I for detailed information on both 

surveys as well as our other data collection methods. We conducted our 

work from August 2006 through August 2007 in accordance with generally 

accepted government auditing standards. 

The 2,790 Title I schools nationwide in corrective action and restructuring 

status in the 2005-2006 school year—comprising about 5 percent of all 

Title I schools and serving over 2 million students—were more frequently 

located in urban school districts and a few states and served higher 

percentages of poor, minority, and middle-school students than other Title 

I schools. Nationwide, almost two-thirds of the 1,155 corrective action and 

1,635 restructuring schools were in urban districts, compared to about 

one-quarter of other Title I schools. Five states—California, Illinois, 

Results in Brief 

Page 3 GAO-07-1035 Schools in Corrective Action and Restructuring
Michigan, New York, and Pennsylvania—collectively had over 60 percent 

of these schools, but less than 30 percent of all Title I schools. When 

compared to all other Title I schools, those in corrective action and 

restructuring served more than twice as many racial or ethnic minority 

students—96 percent compared to 37 percent—and a higher percentage of 

students who were economically disadvantaged—83 percent compared to 

54 percent. More than twice as many of these schools served middle 

school students as compared to all other Title I schools. Nationwide, the 

number of schools in corrective action and restructuring increased 

substantially to 4,509 in the 2006-2007 school year from 2,790 in the 

previous year. As state proficiency targets continue to increase until they 

reach 100 percent by 2014, the number of schools in corrective action and 

restructuring may grow, because many schools now in early stages of 

improvement may continue to struggle to make AYP. 

Though many schools had implemented a corrective action or 

restructuring option, some schools may not be meeting NCLBA 

requirements. Among schools in corrective action status, we estimate that 

94 percent implemented at least one required corrective action and that 

about three-quarters used more than one corrective action. Hiring an 

outside expert and changing the internal structure of the school were the

most frequently implemented actions, with each implemented by about 

60 percent of schools. However, based on our survey, we estimate that 

6 percent of schools did not take any of the required corrective actions. 

About a third continued corrective actions implemented during earlier 

years of school improvement after entering corrective action status. 

Education officials told us that if a school had previously implemented a 

corrective action, an additional action might not be required if the school

provided evidence that the intervention is producing results that are likely 

to enable the school to exit improvement status. As of July 2007, 

Education had not developed guidance on when continuing prior actions 

without implementing a new one is acceptable. About 60 percent of 

schools in restructuring implemented a restructuring option as required by

NCLBA, and the two most frequently selected options were “other” major 

restructuring, such as reconfiguring the grade levels served by the school, 

and replacing selected school staff. Yet many schools in restructuring may 

not have undertaken restructuring options as prescribed under NCLBA. 

States are required to report annually to Education on the measures taken 

to address the achievement problems of schools in improvement status, 

including schools in corrective action and restructuring. However, 

Education does not require states to report on the specific measures taken 

for each school, and therefore, the department has limited information on 

whether states have found that some districts may not be in compliance 

Page 4 GAO-07-1035 Schools in Corrective Action and Restructuring
with NCLBA requirements. A much higher percentage of schools that fully

implemented activities, regardless of which activity they chose, made AYP 

compared with those that had not fully implemented activities.

Nevertheless, we found that no one particular corrective action or 

restructuring option was associated with making AYP, nor was the number 

of activities undertaken associated with AYP. 

We estimate that 42 percent of the schools in corrective action and 

restructuring did not receive all required types of assistance through their

school district, although most received discretionary assistance from their 

state educational agency. Districts are required to ensure that several 

types of assistance are provided to all schools in improvement status, 

including those in corrective action and restructuring. This assistance 

ranges from analyzing student assessment data to revising school budgets 

so that resources are allocated to improvement efforts. NCLBA generally

does not require states to provide specific kinds of assistance to schools in 

corrective action and restructuring. However states are required to 

develop a statewide system of support, including school support teams 

that are available to provide technical assistance to schools and districts. 

We estimate that most schools received some type of assistance from the 

state. For example, 60 percent of schools received assistance from a state 

support team and almost two-thirds received help from instructional 

experts or highly skilled educators. Additionally, almost half of the schools 

received state funds that were used for school improvement activities such 

as professional development. 

Education provides technical assistance and research primarily through its 

Comprehensive Centers Program. The department replaced its former 

assistance centers and various education consortiums with 16 regional

centers and 5 content centers to meet the requirements of the Education 

Sciences Reform Act of 2002. These centers are to help low performing 

schools and districts close achievement gaps and meet the goals of 

NCLBA. The centers provide assistance and research to states on 

developing approaches for improving schools. In addition, Education has 

expanded the material in its Web-based What Works Clearinghouse to 

address a greater number of topics and revised its district and school 

improvement guidance by adding more material on school restructuring. 

While the clearinghouse had little information on promising practices for 

schools in corrective action and restructuring, Education is developing an 

initiative targeted to principals, teachers, and other educators that is to 

develop practical steps to improve schools on the basis of scientifically 

based research identified by the clearinghouse and may have information 

on school restructuring by the end of 2007. 

Page 5 GAO-07-1035 Schools in Corrective Action and Restructuring
To enhance school efforts to increase student achievement, we 

recommend that Education provide guidance to districts on when schools 

may continue previously implemented corrective actions rather than 

taking new ones. We also recommend that Education obtain more specific 

information from states on the specific improvement activities 

implemented by each school in corrective action and restructuring as well 

as more specific information on compliance issues states identified as part 

of their monitoring activities. Finally, we recommend that the department 

take additional steps through its monitoring process to ascertain whether 

states are ensuring that districts provide the assistance required by 

NCLBA. Education agreed with our recommendations and stated it would 

explore options for providing more guidance, gathering additional 

information from states, and improving its monitoring activities. 

Under NCLBA, states are required to establish performance goals and hold 

their Title I schools accountable for students’ performance by determining 

whether or not schools have made AYP. Schools that have not met their 

state’s performance goals for 2 or more consecutive years are identified 

for improvement and must implement certain activities that are meant to

improve student academic achievement. Districts and states play a role in 

this process by providing technical assistance to schools. In addition, 

states are responsible for monitoring district and school compliance with

NCLBA. Education provides states and districts with guidance on school

improvement and monitors states for compliance with NCLBA 

requirements. 

Prior to NCLBA, the Congress attempted to hold states accountable for the

annual performance of their schools by requiring them to collect 

assessment data, develop criteria to determine whether schools and 

districts were performing satisfactorily, and conduct student assessments. 

The 1994 reauthorization of ESEA—Improving America’s Schools Act 

(IASA)—required that schools be designated for improvement for failure 

to make AYP for 2 consecutive years and that districts take corrective 

action as a final intervention for schools that repeatedly missed AYP.4

However, under IASA states assessed AYP in different ways and used 

different measures to evaluate school performance. NCLBA added several

Background 

States and Districts Are 

Held Accountable for the 

Performance of Their 

Schools and Must Take 

Action to Improve Student 

Achievement When 

Schools Do Not Make AYP 

for 2 or More Years

 4

Pub. L. No. 103-382. 

Page 6 GAO-07-1035 Schools in Corrective Action and Restructuring
new provisions to address these differences and to strengthen 

accountability. These provisions include: 

• The requirement that states develop plans that include academic 

standards and establish performance goals for meeting AYP that would 

lead to 100 percent of their students being proficient in reading, 

mathematics, and science by 2014.5

 To measure their progress, states 

were required to establish academic proficiency goals for making AYP 

and to administer an annual assessment to students in most grade 

levels.6

 In addition, each school’s assessment data must be 

disaggregated in order to compare the achievement levels of students 

within certain designated groups with the state’s proficiency targets. 

These student groups include the economically disadvantaged, major 

racial and ethnic groups, students with disabilities, and those with 

limited English proficiency, and each of these groups generally must 

make AYP in order for the school to make AYP. 

• A timeline for implementing specific interventions based on the 

number of years the school missed AYP.7

 For a school that fails to meet 

AYP for 2 consecutive years, districts must offer students in these 

schools the opportunity to transfer to a higher-performing public 

school in the district, and after the third year, they must also offer 

supplemental education services (SES), such as tutoring. In addition, 

the school must also develop an improvement plan in consultation with 

the district, school staff, parents, and outside experts. These plans, 

which are subject to district approval, must incorporate strategies to 

address the specific academic issues that caused the school to be 

identified for improvement. Under NCLBA, if a school fails to make 

AYP for 4 consecutive years, it is required to implement one of the 

corrective actions identified in the legislation. In addition, a new 

intervention to change the governance of schools—school 

restructuring—was introduced for schools that miss AYP for 5 or more 

 5

This requirement applies to all states and students in public schools regardless of whether

the school receives Title I funding or not. 

6

Students in grades 3 to 8 must be annually assessed in reading and mathematics, while 

high school students are only required to be assessed once in these subjects. Assessments 

in science, which were first required under NCLBA in school year 2007-2008, are required

at least once in grades 3 to 8, grades 6 to 9, and grades 10 to 12. 20 U.S.C. 

§ 6311(b)(3)(C)(v) – (vii). 

7

The timelines and other requirements for these improvement strategies are outlined in 

20 U.S.C. § 6316(b). 

Page 7 GAO-07-1035 Schools in Corrective Action and Restructuring
years. (See table 1.) Districts are responsible for selecting and 

implementing the corrective actions and restructuring options for these 

schools. Schools exit improvement status if they make AYP for 

2 consecutive years. 

Table 1: Timeline for Implementing Interventions for Schools That Do Not Make 

Adequate Yearly Progress 

Adequate 

yearly progress 

School status in 

the next year 

NCLBA interventions for 

Title I schools

First year missed Not Applicable None 

Second year missed Needs Improvement 

(First Year of Improvement) 

Required to offer public school

choicea

Third year missed Needs Improvement 

(Second Year of Improvement) 

Required to offer public school

choice and SES 

Fourth year missed Corrective Action 

(Third Year of Improvement) 

Implement certain corrective 

actions and offer public school

choice and SES 

Fifth year missed Planning for Restructuring 

(Fourth Year of Improvement)

Plan for a change in 

governance and offer public 

school choice and SESb

Sixth year missed Implementation of Restructuring 

(Fifth Year of Improvement) 

Implement a change in 

governance and offer public 

school choice and SES 

Source: GAO analysis of NCLBA and Education’s regulations. 

a

At this stage, the school must also develop the school improvement plan. 

b

While NCLBA does not require that corrective actions must be continued after a school enters 

restructuring, Education officials noted that in practice, many schools continue corrective actions after 

entering restructuring status. 

Schools in corrective action must implement at least one of six activities 

such as replacing selected school staff or implementing a new curriculum.8

Schools that do not make AYP after 5 years must plan for restructuring, 

which means that the district must decide how to change the school’s 

governance. Restructuring, the most severe of the NCLBA interventions, 

requires that the school implement a major change to how the school is 

operated, such as reorganizing into a public charter school or contracting 

with an outside organization such as a private management company to 

operate the school.9

 If the school does not make AYP during the planning

 8

20 U.S.C. § 6316(b)(7). 

9

20 U.S.C. § 6316(b)(8). 

Page 8 GAO-07-1035 Schools in Corrective Action and Restructuring
phase, the school enters restructuring. The corrective action and 

restructuring activities allowed under NCLBA are shown below in table 2. 

NCLBA does not address actions that districts must take after 

implementing restructuring and the school continues to fail to make AYP. 

Education officials said that they have encouraged states and districts to 

continue to try different interventions with these schools. 

Table 2: Allowable Activities for Schools in Corrective Action and Restructuring

Corrective actions Restructuring options

The district must implement at least one of the following actions: 

• Replace the school staff who are relevant to the failure to make 

AYP 

• Institute and fully implement a new curriculum

• Significantly decrease management authority at the school 

level 

• Appoint an outside expert to advise the school on its progress 

toward making adequate yearly progress 

• Extend the school year or the school day 

• Restructure the internal organizational structure of the school 

The district must implement at least one of the following options: 

• Reopen the school as a charter school 

• Replace all or most of the school staff (which may include the 

principal) who are relevant to the failure to make AYP 

• Contract with another organization or company to operate the 

school 

• Turn the operation of the school over to the state 

• Implement any other major restructuring of the school’s 

governance, such as: 

• Expand or narrow the grades served; 

• Close the school and re-open it as a theme school (for 

example, a math and science academy) 

Source: GAO analysis of NCLBA (20 U.S.C. § 6316(b)(7) and (8)) and Education’s guidance. 

Both Districts and States 

Provide Technical 

Assistance to Schools in 

Improvement 

The school district bears the primary responsibility for ensuring that its 

schools in improvement, including those in corrective action and 

restructuring, receive technical assistance, although the state also plays a 

role in providing assistance. The purpose of the district’s assistance is to 

strengthen and improve the school’s instructional program by helping the 

school address the issues that caused it to make inadequate progress in 

student achievement.10 Specifically, the district must ensure that each 

school identified for improvement receives assistance based on 

scientifically based research in three areas: analysis of student assessment 

 10Districts are required to ensure that their schools receive this technical assistance, but 

they do not have to provide it directly themselves. Instead, they may elect to provide it 

through other entities such as an institution of higher education, private organizations, 

educational service agencies, or other entities with experience in helping schools improve 

academic achievement. 20 U.S.C. § 6316(b)(4)(B)(iv). 

Page 9 GAO-07-1035 Schools in Corrective Action and Restructuring
data, identifying and implementing instructional strategies, and analysis of 

the school budget, as shown in table 3 below.11

Table 3: NCLBA Technical Assistance Districts Are Required to Ensure for Schools Identified for Improvement, Including 

Those in Corrective Action and Restructuring

Data analysis 

The district must ensure that school staff receive assistance in analyzing student assessment data to identify and develop solutions in 

areas such as 

• Instructional deficiencies 

• Parental involvement and professional development requirements 

Identification and implementation of strategies 

The district must ensure that the school receives help to identify and implement 

• Instructional strategies and methods that are grounded in scientifically based research and address specific issues that cause 

the school to be identified for improvement 

• Professional development relevant to implementation of such strategies and methods 

Budget analysis 

The district must ensure that the school is provided with 

• Assistance in analyzing and revising its budget to fund activities most likely to increase student achievement 

Source: GAO analysis of NCLBA. 

The state educational agencies are also responsible for making several 

forms of technical assistance available to schools in improvement and 

overseeing the improvement activities of districts. States generally are 

required to reserve and allocate 4 percent of the state’s total Title I 

allocation for school improvement activities, with 95 percent of these 

funds going directly to the districts. States are to prioritize their assistance 

to districts that, among other things, serve the lowest achieving schools, 

such as those in corrective action and restructuring. They also are 

required to develop and sustain a statewide system of support that 

provides technical assistance to schools, with a priority given to those in 

improvement status. In addition, in developing the statewide system of 

support, the state agency must: 

• Establish school support teams to work in schools throughout the state 

that are identified for improvement. The purpose of these teams is to 

assist schools to strengthen their instructional programs and must 

include individuals who are knowledgeable about scientifically based 

 1120 U.S.C. § 6316(b)(4) and 34 C.F.R. § 200.40.

Page 10 GAO-07-1035 Schools in Corrective Action and Restructuring
research and practice and its potential for improving teaching and 

learning. 

• Designate and use distinguished teachers and principals who are 

chosen from Title I schools and have been especially successful in 

improving academic achievement. 

• Devise additional approaches to improve student performance, for 

example, by drawing on the expertise of other entities, such as

institutions of higher education, educational service agencies, or 

private providers of scientifically based technical assistance.

Education Provides 

Assistance to States and 

Districts and Monitors for 

Compliance 

Education provides assistance to states in implementing NCLBA and 

monitors states for compliance. Specifically, Education provides 

assistance to states and districts in several ways such as issuing 

regulations, providing guidance and policy letters, and through its 

comprehensive centers. For example, the department published 

nonregulatory guidance that was specific to schools in improvement and 

provided information on the actions that districts and states must take to 

reform their schools in compliance with NCLBA.12 To help build the 

capacity of states to meet NCLBA goals, Education awarded almost 

$57 million in fiscal year 2006 to the 21 comprehensive centers. These 

include 16 regional centers established to provide technical assistance to 

states within defined geographic areas. In addition, Education established 

five content centers that work closely with the regional centers to provide 

technical assistance to states on school improvement. One content center 

focuses on school improvement issues. 

Education monitors each state agency to determine, among other issues, 

whether the state is ensuring that districts are implementing NCLBA 

requirements for school improvement. Education, the state agency, and 

districts all play a role in ensuring that schools are meeting NCLBA 

requirements. Their monitoring responsibilities are presented in table 4. 

 12See LEA and School Improvement: Non-Regulatory Guidance (Department of

Education, Washington, D.C.: July 21, 2006). 

Page 11 GAO-07-1035 Schools in Corrective Action and Restructuring
Table 4: Education, State, and District Responsibilities for Monitoring States, Districts, and Schools Identified for

Improvement

Stakeholder Roles and responsibilities 

Education Monitor states to assess the extent to which states provide leadership and guidance for districts and 

schools in implementing policies and procedures that comply with NCLBA

State educational agency Monitor districts to ensure they are 

• Meeting NCLBA requirements for such things as school choice, providing SES, and providing 

technical assistance to schools identified for improvement; 

• Providing guidance to their Title I schools to ensure they are complying with NCLBA program 

requirements; and 

• Ensuring that schools identified for improvement, corrective action, or restructuring implement 

required activities 

School district Monitor Title I schools identified for improvement for developing the school improvement plan and 

implementation of school improvement activities, including parental involvement activities

Source: GAO analysis of NCLBA and Education’s monitoring plan for Title I programs. 

Education monitors states in two ways: (1) routinely gathers and analyzes 

data collected from Web-based searches and documents, such as 

Consolidated State Performance Reports,13 and (2) on-site visits at least 

once every 3 years to monitor state compliance with Title I. During these 

site visits, states are monitored to ensure that they are complying with 

Title I program requirements, which includes providing the necessary 

guidance and support to schools that are in improvement, including those 

in corrective action and restructuring. In addition, according to

Education’s monitoring guidelines, Education officials visit selected 

districts in each state and ask for evidence on how schools are 

implementing required actions and meeting timeframes. Once the review is 

complete, Education issues a report to the state containing findings, 

recommendations, and required actions needed to address identified 

problems. A state is generally given 30 business days to respond to the 

findings and required actions and also to provide a timeline for addressing 

each issue. A state with significant findings may have conditions attached 

to its Title I Grant and if it fails to adequately address the identified 

deficiencies, the Secretary generally may withhold the state’s Title I funds 

that are used for state administration until all requirements have been 

satisfied. 

 13State may apply and report annually on multiple ESEA programs through a single 

consolidated application and report. These annual reports include information on

numerous ESEA programs. 

Page 12 GAO-07-1035 Schools in Corrective Action and Restructuring
Schools in corrective action and restructuring status in the 2005-2006 

school year were more frequently located in urban school districts and a 

few states and served higher percentages of minority, poor, and middleschool students than other Title I schools.14 In the 2005-2006 school year, 

2,790 Title I schools were in corrective action, planning for restructuring, 

or implementing restructuring (see fig. 1). These schools comprised about 

5 percent of all Title I schools and served over 2 million students. Data for 

the 2006-2007 school year show that the numbers of schools in corrective 

action and restructuring are growing, a trend that is likely to continue. 

Figure 1: Number of Title I Schools Identified for Corrective Action, Planning for 

Restructuring, and Implementing Restructuring in 2005-2006 

Schools in Corrective 

Action and 

Restructuring Were 

More Often Located in 

Urban School 

Districts and Served 

Higher Percentages of 

Minority, Poor, and 

Middle-School 

Students Than Other 

Title I Schools 

0

200

400

600

800

1,000

1,200

1,400

Number of schools

Source: GAO analysis of Education data.

Corrective

Planning for

Implementing

action

restructuring

restructuring

1,155

908

727

 14The number of schools in corrective action, planning for restructuring or implementing 

restructuring are from the 2005-2006 school year. Their characteristics and comparisons to

all other Title I schools are based on data from the 2004-2005 school year, the latest data 

available at the time we began our analyses. The Common Core of Data (CCD) refers to

schools as Title I eligible. For the purposes of our analysis, we refer to these school as 

Title I schools.

Page 13 GAO-07-1035 Schools in Corrective Action and Restructuring
Schools in corrective action and restructuring were predominantly located 

in urban areas, especially compared to all other Title I schools, as shown 

in table 5. 

Table 5: Percentage of Schools in Corrective Action and Restructuring and All 

Other Title I Schools in 2005-2006, by Locale 

Schools in Corrective 

Action and Restructuring 

Were Concentrated in 

Urban Areas and a Few 

States 

Locale 

Schools in corrective 

action and restructuring All other Title I schools

Urban 63 27

Suburban 22 26

Town/Rural 15 44

Source: GAO analysis of data provided by Education. 

Note: Locale data for 3 percent of all other Title I schools were missing. 

Examples of urban areas with relatively higher numbers of schools in 

corrective action and restructuring include Chicago, Detroit, Los Angeles, 

New York, and Philadelphia. Nationwide, school districts in these 5 cities 

alone contained over 25 percent of all schools in corrective action and 

restructuring, as shown in Table 6. By comparison, these 5 districts 

contained less than 4 percent of all other Title I schools. 

Table 6: Percentage of Schools Nationwide in Corrective Action and Restructuring

in the Top 5 School Districts in School Year 2005-2006 

School district Schools in corrective action and restructuring

City of Chicago 10

New York City 7

Los Angeles Unified 3

Philadelphia City 3

Detroit City 2

Source: GAO analysis of data provided by Education. 

Note: Three other school districts (local educational agencies) each had 2 percent of the total of 

schools in corrective action and restructuring: Hawaii Department of Education (56 schools), the 

District of Columbia Public Schools (45 schools), and Baltimore City Public Schools (42 schools). 

The Hawaii Department of Education and the District of Columbia Public Schools each serves

simultaneously as a state educational agency and a local educational agency (school district). New 

York City reported its number of schools by regions within the school district. For our report, we 

summed across regions within New York City to arrive at one number for the district as a whole. 

Consequently, schools in corrective action and restructuring were 

concentrated in a few states. Five states—Illinois, New York, California, 

Pennsylvania and Michigan—collectively had over 60 percent of these 

Page 14 GAO-07-1035 Schools in Corrective Action and Restructuring
schools, but less than 30 percent of all Title I schools nationwide. In 

contrast, a majority of states had 20 or fewer schools in corrective action 

and restructuring, as shown in figure 2. 

Figure 2: Number of Schools in Corrective Action and Restructuring in School Year 

2005-2006, by State 

Source: GAO analysis of Education data; (Map), Map Resources.

N.H.

Mass.

R.I.

Conn.

N.J.

Del.

Md.

D.C.

Hawaii

Ala.

Ariz. Ark.

Calif.

Ga.

Ill. Ind.

Iowa

Kans.

La.

Maine

Mo.

Nebr.

N.Mex.

N.Y.

N.Dak.

Oreg.

Pa.

Tex.

Wisc.

Fla.

Miss.

N.C.

Ohio

Okla.

S.Dak.

Wyo.

Alaska

Idaho

Mont.

Wash.

Nev.

Utah

Colo.

Mich.

Minn.

Va.

W.

Va.

Ky.

S.C.

Tenn.

Vt.

0 (5)

1-20 (23)

21-99 (18)

100+ (5)

Number of schools (states)

Page 15 GAO-07-1035 Schools in Corrective Action and Restructuring
In general, states with large numbers of schools identified for

improvement when NCLBA was passed had more schools in corrective 

action and restructuring in the 2005-2006 school year than those with few 

schools in improvement in 2001.15 Prior to NCLBA, states had identified 

schools for improvement, and when NCLBA was passed in the 2001-2002 

school year, it generally required states to maintain the prior improvement 

status of schools.16 Consequently, many schools that were in earlier stages 

of improvement in school year 2001-2002 entered corrective action and

restructuring in subsequent years. 

Schools in Corrective 

Action and Restructuring 

Served a Higher 

Percentage of Minority, 

Economically 

Disadvantaged, and Middle 

School Students, 

Compared to All Other 

Title I Schools 

Schools in corrective action and restructuring also had a much higher 

percentage of racial or ethnic minority students compared to all other Title 

I schools (96 percent compared to 37 percent) and also enrolled a higher

percentage of economically disadvantaged students (83 percent compared 

to 54 percent).17 These differences varied substantially when the location

of the school is accounted for, as seen in table 7.

 15We also analyzed these data taking into account the number of schools as a percentage of

all Title I schools by state. In general, states with a higher percentage of Title I schools in 

improvement when NCLBA was passed also had a higher percentage in schools in

corrective action and restructuring in 2005-2006. 

1620 U.S.C. § 6316(f). 

17For this analysis, we compared the percentage of students who are members of racial or 

ethnic minority groups or who qualified for free- or reduced priced meals in the median 

schools when all schools were ranked by the percent of those characteristics in the 

schools. 

Page 16 GAO-07-1035 Schools in Corrective Action and Restructuring
Table 7: Percentage of Students with Selected Characteristics, Comparing Schools 

in Corrective Action and Restructuring with All Other Title I Schools, by Locale 

Locale 

Schools in corrective 

action and restructuring All other Title I schools

Minority status 

Urban 98 84

Suburban 93 34

Rural/Town 93 11

Poverty status

Urban 83 70

Suburban 81 45

Rural/Town 83 49

Source: GAO analysis of data provided by Education. 

Note: The table shows the percentage of students who are members of racial or ethnic minority 

groups or who qualified for free-or reduced-priced meals in the median schools (by locale) when all 

schools were ranked by the percent of those characteristics in the schools. 

Schools in corrective action and restructuring varied in terms of the grade 

level of students that they served. Compared with all other Title I schools, 

middle schools were considerably over-represented among schools in 

corrective action and restructuring while primary schools were 

underrepresented, as seen in table 8.18

 18Our finding on middle schools is similar to findings in other reports. See U.S. Department

of Education, National Assessment of Title I Interim Report, Vol 1: Implementation, 

Institute of Education Sciences (Washington, D.C.: February 2006); and Center on 

Education Policy, NCLB: Middle Schools are Increasingly Targeted for Improvement 

(Washington, D.C: 2006). We found no notable difference between the percentage of middle 

schools in corrective action and restructuring and the percentage of all other Title I schools 

based on whether they were located in an urban, suburban, or rural area. 

Page 17 GAO-07-1035 Schools in Corrective Action and Restructuring
Table 8: Percentage of Schools in Corrective Action and Restructuring Compared

to All Other Title I Schools, by Grade Level 

Grade level 

Schools in corrective 

action and restructuring All other Title I schools

Primary 52 70

Middle 32 15

High 12 10

Other 4 5

Source: GAO analysis of data provided by Education. 

Note: For the purposes of our analysis, we used the definitions of primary, middle, and high schools 

provided in the CCD, as described in appendix I of this report. 

Several factors might explain why middle schools are over-represented. 

Evidence from the National Assessment of Educational Progress—

especially for many of the urban school districts with numerous schools in 

corrective action or restructuring—shows that the percentage of students 

who score at a proficient level or above in math is generally lower in 

middle schools than in elementary schools.19 Other factors may also 

include being less qualified than their peers in elementary or middle 

schools, teachers in middle schools, and social and emotional challenges 

associated with students as they make the transition into middle schools.20

Yet another reason may be that because of NCLBA provisions about the 

minimum number of students in a school that would comprise a 

designated student subgroup, middle schools typically have to make AYP 

for more student subgroups than elementary schools.21

 19Results for reading are mixed, with proficiency rates higher for some district’s or groups

of middle school students than elementary school students, but lower for others. See U.S.

Department of Education, The Nation’s Report Card: Reading 2005. NCES 2006-451 

(Washington, D.C.: October, 2005). See The Nation’s Report Card: Mathematics 2005. 

NCES 2006-453 (Washington, D.C.: October, 2005); The Nation’s Report Card: Trial Urban 

District Assessment Mathematics, 2005, NCES 2006-457r (Washington, D.C.: February 

2006); The Nation’s Report Card: Trial Urban District Assessment Reading, 2005. NCES 

2006-455r (Washington, D.C.: February 2006). 

20RAND, Focus on the Wonder Years: Challenges Facing the American Middle School 

(Santa Monica, Calif.: 2004). 

21Center on Education Policy, NCLB: Middle Schools Are Increasingly Targeted for 

Improvement, NCLB Policy Brief 2 (Washington, D.C.: 2005). 

Page 18 GAO-07-1035 Schools in Corrective Action and Restructuring
Data for the 2006-2007 school year showed that the number of schools in 

corrective action and restructuring has increased. In 2006-2007, there were 

4,509 schools in corrective action and restructuring compared to 2,790 the 

year before, an increase of over 60 percent, and more than twice as many 

schools compared to just 2 years earlier. (See fig. 3.) 

Figure 3: Number of Schools in Corrective Action and Restructuring for the 3 Most

Recent School Years 

The Number of Schools in 

Corrective Action and 

Restructuring Has 

Increased Considerably 

from Last Year and May 

Continue to Do So 

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

5,000

Number of schools

Implementing restructuring

Planning for restructuring

Corrective action

Source: GAO analysis of Education data.

2004-

2005

2005-

2006

2006-

2007

2,112

727

1,155

908

1,047

1,065

4,509

1,242

937

2,330

2,790

Note: For the 2004-2005 school year, we used data from the National Assessment of Title I: Interim 

Report which had only one category for schools in restructuring and did not distinguish between 

schools planning for restructuring and those implementing restructuring. Also, this report, which was 

not updated, included data from some states that had not completed decisions for schools appealing 

their improvement status, resulting in fewer schools ultimately identified than was reported. 

Additionally, 41 states had more schools in corrective action and 

restructuring whereas only 8 states had fewer.22 (See fig. 4 and see app. II 

 22The number of schools in corrective action and restructuring for one state did not change 

between school years 2005-2006 and 2006-2007, and another state had yet to finalize its data 

for 2006-2007. 

Page 19 GAO-07-1035 Schools in Corrective Action and Restructuring
for a comprehensive list of the number of schools in corrective action and 

restructuring in each state.) Most notably, in 2006-2007, the state of Florida 

had 574 schools in those categories compared to only 32 such schools in 

2005-2006. According to a Florida state official, this increase is attributable 

to the fact that many schools have been struggling to meet the increasing

proficiency targets. Other states with large increases include California 

(increase of 376 schools) and Massachusetts (increase of 118 schools). A 

few states, such as Michigan, had fewer schools in corrective action and 

restructuring in 2006-2007 compared to the prior year. In Michigan’s case, 

it is not clear whether the decrease was related to state or district reform 

efforts, changes in criteria making it easier for schools to make AYP, or 

some combination of these factors.23

 23See Center on Education Policy, What Now? Lessons from Michigan about 

Restructuring Schools and Next Steps Under NCLB (Washington, D.C.: 2007). 

Page 20 GAO-07-1035 Schools in Corrective Action and Restructuring
Figure 4: Change in the Number of Schools in Corrective Action and Restructuring

from 2005-2006 to 2006-2007, by State 

Source: GAO analysis of Education data, (Map) Map Resources.

-23–0

1–20

21–99

100+

Data not available

N.H.

Mass.

R.I.

Conn.

N.J.

Del.

Md.

D.C.

Hawaii

Ala.

Ariz. Ark.

Calif.

Ga.

Ill. Ind.

Iowa

Kans.

La.

Maine

Nebr.

N.Mex.

N.Y.

N.Dak.

Oreg.

Pa.

Tex.

Wisc.

Fla.

Miss.

N.C.

Ohio

Okla.

S.Dak.

Wyo.

Alaska

Idaho

Mont.

Wash.

Nev.

Utah

Colo.

Mich.

Minn.

Va.

W.

Va.

Ky.

S.C.

Tenn.

Mo.

Vt.

Change in number of schools

Note: Missouri did not submit to Education its final list of schools identified for improvement in the 

2006-2007 school year. 

The general trend toward higher numbers of schools in corrective action 

and restructuring may continue. As of the 2006-2007 school year, more 

schools were identified for improvement than at any time since such data 

were tracked under IASA. As proficiency targets continue to increase up 

to 100 percent by 2014, many schools identified for improvement may not 

make AYP. Consequently, if these schools cannot meet the increasing 

proficiency targets, they will enter corrective action and ultimately 

restructuring. 

Page 21 GAO-07-1035 Schools in Corrective Action and Restructuring
Our survey results indicated that a majority of schools in corrective action 

and restructuring implemented required activities; however, in some cases 

schools may not be in compliance with NCLBA requirements.24 Although 

many schools in corrective action implemented multiple corrective 

actions, some did not take any corrective action. A majority of 

restructuring schools implemented a required restructuring option, but 

based on our survey results, about 40 percent of schools did not take any 

of the 5 restructuring options required by NCLBA, one of which is a broad 

category referred to as “other” major restructuring. Although there was no 

relationship between any of the specific activities and whether a school 

made AYP, a higher percentage of schools that fully implemented 

improvement activities made AYP compared with those that had not fully

implemented activities. 

Among schools in corrective action status, we estimate that 94 percent 

implemented at least one corrective action from those specifically 

identified by NCLBA, and about three-quarters had used more than one 

corrective action. Hiring an outside expert and changing the internal 

structure of the school were the most frequent actions, with each 

implemented by about 60 percent of schools. Outside experts are used to 

advise the school on its progress toward making adequate yearly progress. 

Among schools that changed their internal structures, about 85 percent 

increased small group work and about 75 percent reorganized the school 

schedule to increase opportunities for professional development. Many 

schools also reduced class size, created small learning communities, and 

implemented team teaching as part of the changes to the organizational 

structure. In addition to hiring outside experts and changing internal 

structure, about 40 percent of schools changed the curriculum. A smaller 

percentage of schools implemented certain forms of corrective actions 

such as extending the school year or day or decreasing management 

authority at the school level. Some officials explained that extending the 

school year or day would be costly to the district because teacher salaries

may have to increase to compensate for the additional instructional time. 

For the majority of schools, district officials played a significant role in 

determining the action taken. Figure 5 shows the allowed corrective

actions and the percentage of schools implementing each action. 

Most Schools Used a 

Corrective Action or 

Restructuring Option, 

but Some May Not be 

Meeting NCLBA 

Requirements 

Among Schools in 

Corrective Action, Almost 

All Took at Least One 

Corrective Action, but 

Some May Not Have Taken 

an Action As Required by 

NCLBA 

 24All survey findings are based on what school officials reported through GAO’s Web-based 

or paper survey. We did not verify whether schools had implemented the activities they 

reported taking. 

Page 22 GAO-07-1035 Schools in Corrective Action and Restructuring
Figure 5: Corrective Actions Allowed under NCLBA and Estimated Percentage of

Schools That Implemented Each Action in 2005-2006 

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools

Source: GAO survey.

Corrective actions

Decreased

management authority

Replaced 

Extended day

Extended year

staff

Implemented new

Changed internal

Hired outside

curriculum

structure

expert

62 61

41

26

16

10

5

Note: These sum to more than 100 percent because some schools implemented more than one 

action. 

Based on our survey, we estimate that 6 percent of schools in corrective 

action status did not take corrective actions. For example, in one school 

we visited, the principal told us that the school had not implemented any 

changes during its year in corrective action. He told us that the district 

provided no input on the required actions and that the state educational 

agency approved the school improvement plan without comment. 

About a third of schools that went into corrective action in 2005-2006 did 

not take a new corrective action in that year. These schools took 

corrective action in earlier years of improvement and did not implement 

any further corrective actions after entering corrective action status. For 

example, some schools indicated that the school used an outside expert or

implemented a new curriculum in previous school years and had not 

implemented any additional corrective actions the year in which the 

Page 23 GAO-07-1035 Schools in Corrective Action and Restructuring
school entered corrective action status. Education officials told us that if a 

school implemented a corrective action in earlier stages of improvement 

(year 1 or 2 of improvement), an additional corrective action might not be 

required. They explained that whether a district must take additional 

actions depends in part on whether the school is showing improvement in 

student achievement. If the school showed evidence that the intervention 

is producing results that are likely to enable the school to exit

improvement status, an additional corrective action might not be 

necessary. On the other hand, Education officials noted that if the data 

indicates that the previous corrective actions have not addressed the 

school’s achievement problems they would expect the district to take 

additional corrective action. While it may be appropriate in some cases for 

schools to continue implementing the same actions, Education officials 

acknowledged that they have not provided written guidance on when 

continuing prior actions without implementing a new one would be 

acceptable. 

Department officials told us that while they had conducted Title I 

monitoring in every state, they had not found compliance issues 

specifically related to corrective action from their monitoring visits. States

are required to conduct annual reviews of district progress in part to 

ensure that districts are carrying out their responsibilities, one of which is 

taking at least one corrective action when necessary. However, states 

generally do not report to Education district noncompliance, such as 

failure to take corrective actions as required. Under NCLBA, states are 

required to annually submit to Education and make widely available the 

measures taken to address the achievement problems of schools in 

improvement status, including schools in corrective action. However, 

Education does not require states to report on the measures taken for each 

school. Instead, Education requires states to provide a brief summary of 

the measures taken across the state. Consequently, Education lacks 

information on which action was taken by each school, whether schools 

are taking actions at all, and whether or not states have taken any actions 

against schools or districts for failure to comply with NCLBA. 

Page 24 GAO-07-1035 Schools in Corrective Action and Restructuring
We estimate that a majority of schools in restructuring had implemented at 

least one of the five restructuring options allowed by NCLBA.25 According 

to NCLBA, each of these options is to result in a major change to the 

school’s governance. As figure 6 shows, about 40 percent of the schools 

implemented the “other” major restructuring of the school’s governance, 

which can include such actions as expanding or narrowing the grades 

served or creating smaller learning communities within the school.26 We 

estimate that 27 percent of schools replaced all or most of the staff related

to the school’s performance issues. 

Among Schools in 

Restructuring, Almost 

Two-Thirds Implemented a 

Restructuring Option; 

However, Many Schools 

May Not Be in Compliance 

with NCLBA Requirements 

Figure 6: Restructuring Options Allowed under NCLBA and Estimated Percentage

of Schools That Implemented Each Option

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools

Source: GAO survey.

Restructuring options

Became a

Taken over by the

Contracted with

Replaced staff

Chose “other”

charter school

state

an entity

major restructuring

40

27

9

5

1

 25The information provided in this section pertains only to those schools that were in the

implementation stage of restructuring in 2005-2006 school year. This section does not 

pertain to schools that were planning for restructuring. 

26Another study found similar results for schools implementing restructuring in the state of

California. See Center on Education Policy, Beyond the Mountains: An Early Look at

Restructuring in California (Washington, D.C.: 2007). 

Page 25 GAO-07-1035 Schools in Corrective Action and Restructuring
Of the 40 percent of schools that selected “other” major restructuring of 

the school’s governance, 44 percent created smaller learning 

communities—an approach taken by some of the schools we visited.27 For 

example, one middle school we visited created “academies” within the 

school. Each academy had its own theme, and students stay within the 

academy as they are promoted from grade to grade. Another 37 percent of

schools that chose the “other” option narrowed or expanded the range of 

grades served within the school, for example, changing a kindergartenthrough-grade-five elementary school to a kindergarten- through-gradeeight school. In one district we visited, officials reported that a 

kindergarten-through-grade-eight model creates a more positive learning 

environment than middle schools do as it creates a sense of family and 

relationships in schools. Figure 7 shows the various types of restructuring 

activities taken by schools implementing “other” major restructuring.28

 27Margins of error for estimates pertaining to schools that implemented “other” major

restructuring do not exceed 15 percent. 

28These categories reflect the examples of “other” major restructuring provided in 

Education’s 2006 guidance. 

Page 26 GAO-07-1035 Schools in Corrective Action and Restructuring
Figure 7: Among Schools Implementing “Other” Major Restructuring, Estimated

Percentage of Schools Implementing Various Activities

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools

Source: GAO survey.

“Other” major restructuring

grade range

Expanded or narrowed

Closed the school

learning communities

Created smaller

performing

school

Paired with a higher

Reopened theme school

12

44

6

37

0

In addition to the “other” major restructuring option, in an estimated 

27 percent of restructuring schools, all or most of the staff (primarily 

teachers and principals) who were relevant to the failure to make AYP 

were replaced. The schools we visited that replaced staff varied in terms 

of whether teachers, principals, or both were replaced. Our survey 

indicated that for many of these schools, it was difficult or very difficult to 

recruit new teachers as replacements. 

Very few schools in restructuring had contracted with an entity, such as a 

private management organization, become a charter school, or been taken

over by the state. Some states may not have authorized all restructuring 

options under state law or policy, which may explain why fewer schools 

have taken these options. For example, according to a recent report, while 

some states have policies that permit districts to turn schools over to 

Page 27 GAO-07-1035 Schools in Corrective Action and Restructuring
private management or to reopen schools as charter schools, others do 

not.29 In three of the five states we visited, state officials reported that their

state educational agencies currently do not take over schools.30 In one of 

these states, turning over school management to the state agency is 

permissible under state policy, but officials told us that the state does not 

have the capacity or expertise to do so.31 The amount of time it takes to 

plan for such a change may also be a factor in why these options are not 

often selected. For example, a district official reported that the district did

not have sufficient time during the restructuring planning process to 

seriously consider reopening as a charter school, contracting with a 

private management company, or turning the operation of the school over 

to the state. In about 70 percent of schools, the district played a significant 

role in determining the restructuring option taken. 

Although a majority of schools implemented a restructuring option, about 

40 percent of the schools that were in restructuring did not take any of the 

5 restructuring options prescribed under NCLBA, according to our survey 

results. Several principals of schools that had not restructured did not 

know why an option was not taken. In other cases, principals believed that 

the school board or district had decided not to restructure. In addition, 

one of the surveyed schools and some school and district officials we 

visited did not believe restructuring was necessary when student 

achievement was improving. For example, officials at one of the schools 

we visited that was planning for restructuring indicated that the district 

and school administration had determined that no changes were needed 

because they were confident that the actions already taken were helping

students. 

Nonetheless, about half of the schools that did not take one of the five 

restructuring options engaged in a variety of school improvement efforts. 

Some of these efforts may fall under the “other” major restructuring 

option, while others do not appear to be consistent with NCLBA 

 29Education Week (Editorial Projects in Education), “Quality Counts: 2007. From Cradle 

to Career: Connecting American Education from Birth to Adulthood,” (Bethesda, Md.: 

January 2007). 

30According to the same report, many states currently authorize turning over school 

management to the state educational agency through state policy. (Education Week 

(Editorial Projects in Education), (January 2007). 

31Another state educational agency we visited attempted to take over schools, but state 

officials told us that the state legislature prevented it from doing so. 

Page 28 GAO-07-1035 Schools in Corrective Action and Restructuring
requirements for restructuring. For example, one school implemented a 

new curriculum as a restructuring option, while at another school extra 

funding was used for small group instruction and after-school programs, 

both of which more closely resemble corrective action under NCLBA. In 

addition, in two districts we visited, officials allowed schools that were 

improving to continue efforts started under prior stages of improvement. 

However, we could not determine based on the information reported by 

survey respondents whether these activities would be considered 

restructuring under NCLBA. Further, several Education officials we spoke 

with could not determine whether or not the actions schools reported 

taking were in compliance without more information from the schools, 

such as other on-going districts efforts. 

Similar to our finding that many schools may not be implementing a 

restructuring option, Education’s 2006 interim report on Title I stated that

very few schools in restructuring status implemented a restructuring 

option prescribed by NCLBA, though many implemented actions NCLBA 

specifies for the corrective action stage of school improvement.32 Despite 

these findings, department officials told us that they did not have any 

monitoring findings related to restructuring requirements, nor did they 

know whether any states had found districts that had not implemented 

restructuring requirements, although they did find deficiencies in some 

districts’ review of school improvement plans. 

Education’s monitoring tools and reporting requirements do not fully 

address issues of compliance. While Education’s state monitoring tool 

includes questions about how states monitor the implementation of school 

improvement plans, Education officials acknowledged that the department 

may be able to strengthen its monitoring tool to determine whether state 

oversight of districts is adequate to ensure compliance. Also, since states 

are not required to report district noncompliance to Education and 

Education does not require states to report on the specific corrective 

actions and restructuring options taken to address the achievement 

problems of each school, federal officials have limited information on 

areas in which there are compliance issues as well as the extent to which 

districts are complying. 

 32Department of Education, National Assessment of Title I Interim Report, Vol. 1:

Implementation, Institute of Education Sciences (Washington, D.C.: February 2006).

Education explained its findings in part by noting that the survey did not specify whether 

schools were planning restructuring or implementing restructuring. 

Page 29 GAO-07-1035 Schools in Corrective Action and Restructuring
We estimate that over a third of schools that fully implemented a 

corrective action or restructuring option made AYP, as opposed to 

16 percent of schools that had mostly or partially implemented 

improvement activities.33 Several officials noted, and research shows, that 

school improvement efforts take more than a year to affect student 

achievement, so it is possible that these activities will help these schools 

make AYP over the next several years. Many district and school officials 

we interviewed told us that implementing a new curriculum takes time and 

that other improvement efforts can take several years to fully implement 

and to see results. Other factors also can affect school improvement 

efforts. For example, among the schools that made AYP, 76 percent of 

principals believed teacher quality helped or greatly helped school 

improvement activities in their school, opposed to only 53 percent among 

schools that had not made AYP.34 In addition to teacher quality, around 80 

percent of school officials believed that instructional support and 

resources, such as teacher aides and computers, helped or greatly helped 

their school improvement efforts. Schools lacking such support may find 

implementation of corrective action and restructuring more challenging. 

A Higher Percent of 

Schools That Fully 

Implemented Improvement 

Activities Made AYP 

Based on our survey results, none of the specific corrective actions or 

restructuring options was associated with making AYP, nor was making 

AYP associated with the number of activities undertaken, and these 

findings are consistent with recent research on school improvement.35

Many school officials believed that other factors affected student 

achievement and therefore, the schools’ ability to make AYP. About 

80 percent of school principals believed that community poverty impeded 

student achievement, while two-thirds believed community violence 

 33Our findings throughout this section are based on analyses that did not allow us to

determine whether the type of school improvement activity, level of implementation, or

number of activities taken caused schools to make AYP. However, we did test for whether 

these factors were related to making AYP, and found no statistically significant 

relationships. The RAND Corporation has conducted a study that emphasizes the 

importance of implementation of school reform efforts. See RAND, Evaluating 

Comprehensive School Reform Models at Scale: Focus on Implementation (2006), 

Arlington, VA.

34Among schools that made AYP, the 95 percent confidence interval for this estimate ranges 

from 65 percent to 87 percent of principals who believed teacher quality helped or greatly 

helped school improvement activities in their school. 

35Mintrop, H. and Trujillo, T., “Corrective Action in Low-Performing Schools: Lessons for 

NCLB Implementation from First-Generation Accountability Systems,” Education Policy

Analysis Archives, Vol. 13, Issue 48 (December 2005) and Ronald C. Brady, Can Failing 

Schools be Fixed? (Thomas B. Fordham Foundation, Washington, D.C.: January 2003). 

Page 30 GAO-07-1035 Schools in Corrective Action and Restructuring
impeded achievement. We found similar views during our site visits.36 For 

example, at two schools we visited, officials noted that the presence of 

gangs in the neighborhood affected student achievement, and teachers at 

one school commented that it was unsafe for students to visit the 

community library after dark. Several school and district officials 

observed that poverty affected students’ academic efforts. School officials 

noted that many poor students cannot stay late at school because they 

have family obligations, such as taking care of younger children. In 

addition, about two-thirds of school principals believed that student 

mobility (moving from one school to another) impeded student 

achievement, and several officials said that districtwide or statewide 

curricula had been implemented, in part, to address widespread student 

mobility by establishing a consistent instructional approach across 

schools. Moreover, we estimate that nearly half of school officials believed 

that low student attendance impeded student achievement at their school. 

This finding was more prevalent among schools that had not made AYP 

compared to schools that had made AYP. Finally, several activities were 

undertaken by very few schools, such as state takeover or extending the 

school year, so these activities’ association with AYP could not be 

accurately assessed in this study. 

We estimate that more than 40 percent of the schools in corrective action 

and restructuring did not receive all of the required technical assistance, 

such as data analysis and professional development, through their school

district, but most of the schools received some technical assistance from 

their state. While states generally are not required to provide specific kinds 

of assistance to schools, they are required to develop a statewide system 

of support that is available to schools and districts and to provide 

technical assistance to schools if the district fails to do so. Most schools 

reported receiving technical assistance from their state educational 

agency, such as help from instructional experts or highly skilled 

educators. 

Many Schools in 

Corrective Action and 

Restructuring Did Not 

Receive All Required 

Assistance through 

Their School Districts; 

However, Most 

Received Assistance 

from Their State 

 36Our prior work has also documented some administrative challenges associated with 

student mobility. See GAO-05-879, No Child Left Behind Act: Education Could Do More to 

Help States Better Define Graduation Rates and Improve Knowledge about Intervention 

Strategies (Washington, D.C.: Sept. 20, 2005).

Page 31 GAO-07-1035 Schools in Corrective Action and Restructuring
We estimate that 42 percent of the schools in corrective action and 

restructuring had not received all of the required assistance in school year 

2005-2006 while about 56 percent did. Schools most frequently received 

technical assistance related to professional development (92 percent) and 

instructional strategies (90 percent). However, only about 70 percent 

received assistance with analyzing the school budget to ensure that 

resources were allocated toward improving student achievement. We also

found, based on our survey results, that 7 out of 313 schools (about 

2 percent) in corrective action and restructuring received no assistance. 

(See fig. 8 for the percentage of schools receiving each type of required 

technical assistance.) 

Many Schools in 

Corrective Action and 

Restructuring Did Not 

Receive All Required 

Assistance through 

Districts 

Figure 8: The Estimated Percentage of Schools in Corrective Action and 

Restructuring That Received Each Form of Required Technical Assistance through 

Districts in School Year 2005-2006 

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools

Source: GAO survey.

District assistance

Analyzed/revised budget

Identified instructional

strategies

Obtained professional

development

Identified professional

development

Identified problems

in instruction

Implemented parent

involvement requirement

Analyzed data

89

79

85

92

88 90

72

Education officials noted that through their monitoring site visits they 

found that some districts had not provided all of the assistance required. 

In these instances, Education officials said states could withhold Title I 

Page 32 GAO-07-1035 Schools in Corrective Action and Restructuring
funds from the districts that are out of compliance. However, Education 

could not tell us how often states take actions against districts for not 

providing required assistance, because according to one Education 

official, Education did not collect this information from states. 

Generally, school officials we met with told us that the district was 

actively involved in providing assistance to their schools. Almost all school 

principals and teachers that we interviewed specifically emphasized 

district efforts to train their administrators and teaching staff to analyze 

and use student testing data to target their instruction to areas of 

academic weakness and to students that needed additional assistance. In 

addition, they said that districts had targeted resources to provide 

professional development and implement effective instructional practices. 

For example, in most districts we visited, school officials said that literacy 

or math coaches had been hired to provide staff development or to work 

with teachers to identify instructional practices to improve instruction. 

Also, in some schools we visited, officials told us that districts assisted the 

schools in their efforts to increase parental involvement. For example, in 

New York City, the district helped some schools by approving a parent 

coordinator position to get parents more involved in their schools. 

Officials in some districts also reported reviewing school budgets to 

ensure that resources are allocated to programs that target student 

performance. In regard to budget assistance, district officials in Chicago 

told us that they must approve budgets of all schools in restructuring. In 

addition, principals in two California schools reported that the district 

reviewed their budgets and recommended expenditures that targeted 

school improvement activities. 

Most Schools Received 

Some Assistance from 

State Educational 

Agencies, and Almost Half 

of Schools Received State 

Funds for School 

Improvement 

Most schools received some assistance from their state educational 

agency, and almost half received state funds for school improvement. 

States are required to develop a statewide system of support that is 

available to assist districts. As a part of this system, states must create 

school support teams, which are composed of various participants, 

including highly qualified or distinguished educators, such as teachers and 

principals who can assist the school in strengthening its instructional 

program to improve student achievement. We estimate that about 

65 percent of schools received assistance from their state educational 

agency in developing the school improvement plan, and 60 percent 

received assistance from a school support team (fig. 9). Although state 

educational agencies generally are not required to provide specific kinds 

of technical assistance to schools in corrective action and restructuring, 

they are required to ensure that districts are providing all of the required 

Page 33 GAO-07-1035 Schools in Corrective Action and Restructuring
assistance to schools identified for improvement, and if the district has 

not, state educational agencies must step in and provide the assistance. 

An estimated 47 percent of the schools in corrective action and 

restructuring received state funds for school improvement activities in 

addition to federal Title I funds. While state funds were used for many 

different kinds of school improvement activities, more than 75 percent of 

the schools surveyed used the funds for professional development 

activities, classroom support such as instructional and resource materials,

or both. In addition, officials in four of the five states we visited told us 

that schools received state funds for school improvement activities. 

Maryland provides its schools guidelines on how the funds can and cannot 

be used and the guidelines emphasize that whenever possible, the funds 

should be used to improve instruction, such as purchasing textbooks or 

hiring more school staff. Schools in California and New York apply for 

state funds and must include a plan for how the funds will be used. 

Page 34 GAO-07-1035 Schools in Corrective Action and Restructuring
Figure 9: Estimated Percentage of Schools in Corrective Action and Restructuring

in 2005-2006 That Received State Assistance 

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools

Source: GAO survey.

State assistance

 Provided funding

Provided school

Provided

support team

instructional experts

Assisted with school

improvement plan

65 64

60

47

Education provides technical assistance and research results to states 

primarily through its Comprehensive Centers Program, consisting of 

16 regional centers and 5 content centers (fig. 10). The department 

replaced its former assistance centers and various education consortiums 

to meet the requirements of the Education Sciences Reform Act of 2002.37

The primary task of the content centers is to provide knowledge and

assistance by experts in school improvement to regional centers. The 

regional centers are to provide technical assistance to states on a wide 

range of topics related to NCLBA, in part based on information provided 

by the content centers. 

Education Provides 

Technical Assistance 

and Research on 

School Improvement, 

Including Some 

Specific Information 

on School 

Restructuring 37The comprehensive centers under this program replaced the former Comprehensive 

Regional Assistance Centers, the Regional Technology in Education Consortia, the 

Eisenhower National Clearinghouse for Mathematics and Science Education, and the

Regional Mathematics and Science Education Consortia. 

Page 35 GAO-07-1035 Schools in Corrective Action and Restructuring
Figure 10: Education’s Content and Regional Centers 

Alaska

Appalachia

California

Florida and islands

Great Lakes East

Great Lakes West

Mid-Atlantic

New England

New York

North Central

Northwest

Pacific

Southeast

West/Southwest

Mid-Continent Texas

Assessment and

accountability 

Innovation and

improvement 

Instruction

Teacher quality

High schools

Research

Technical

assistance 

Content centers Regional centers

Source: GAO Illustration of Education’s Comprehensive Centers Program.

One content center, the Center on Innovation and Improvement, provides 

a variety of services related to school improvement. The center developed 

a guide, Handbook on Restructuring and Substantial School 

Improvement,

38 which it has disseminated to regional centers, state 

educational agencies, and other organizations. The handbook provides 

information on using student data to identify a restructuring option and 

focusing instruction on state standards, among other topics. Other 

services include the center’s annual 2-day training for representatives from

the regional centers and additional workshops throughout the year on 

various improvement topics. The center produced a series of Web-based 

seminars during the spring and summer of 2007, also based on the 

handbook, for use by the regional centers. In addition, each regional 

center has developed an annual work plan, negotiated with the states for 

which it is responsible. For example, the New York Regional Center 

provides assistance to the state of New York and has negotiated a work 

plan with several goals related to school improvement. One goal is to help

 38See Herbert J. Walburg, editor. “Handbook on Restructuring and Substantial School 

Improvement” (Center on Innovation and Improvement, Lincoln, Ill.: 2007).

Page 36 GAO-07-1035 Schools in Corrective Action and Restructuring
the New York State Education Department build its school improvement 

capacity by assisting with delivery of research-based professional 

development related to adolescent literacy. 

Education developed the What Works Clearinghouse to review studies of 

educational interventions to determine which studies were conducted 

with a sound methodology and to what extent the interventions are 

effective. The clearinghouse has reviewed studies on topics such as 

preventing dropouts and increasing elementary and middle school 

achievement in mathematics. While these topics are likely to be of interest

for schools in corrective action and restructuring, the clearinghouse has 

not reviewed studies that specifically deal with practices employed by

schools in corrective action and restructuring. Moreover, several state, 

district, and school officials we interviewed indicated that they needed

more information on practices for improving schools in corrective action 

and restructuring. For example, an official in one district told us that they

had been attempting to create their own approaches to improve schools, 

but said that there was insufficient information, from federal or other 

sources, on improvement practices. Recognizing the need for information 

that may be more suited for teachers, principals, and other educators, 

Education officials reported that the department will launch a Web site in 

September 2007 related to their initiative, Doing What Works. Through this 

initiative, Education would review studies identified by the clearinghouse 

and develop materials, called “practice guides” for educators. According to

Education, a practice guide on school restructuring is in development and 

may be available by the end of 2007. 

In addition to the Comprehensive Centers and What Works Clearinghouse 

programs, Education implemented a variety of other initiatives that may 

assist officials in their efforts to improve schools. The department revised 

its guidance in July 2006 to provide more information on school 

restructuring. In addition, Education operates 10 Regional Education 

Laboratories that provide research on a variety of topics. For example, the 

Northwest Regional Education Laboratory is currently examining 

statewide systems of support and the factors that have helped schools 

make AYP. The laboratories are also available to provide assistance to any 

entity, such as school districts or schools, that may request information 

from them. Other resources include the Support for School Improvement 

newsletter, developed by the Council of Chief State School Officers and 

funded in part by Education. The newsletter focuses on topics such as 

school improvement policies and closing achievement gaps among student 

groups. Education also funds a clearinghouse for Comprehensive School 

Reform, which disseminates research on effective approaches to school 

Page 37 GAO-07-1035 Schools in Corrective Action and Restructuring
reform through publications such as a recent report on what improvement 

practices might work for schools in restructuring.39

Schools that reach corrective action and restructuring status face many 

challenges in raising the achievement levels of their students. These 

schools typically serve low-income students, and many report that factors 

such as neighborhood violence and student mobility pose additional 

challenges to engaging students and improving their academic 

performance. While most of these schools have implemented activities 

that are required by NCLBA, it is possible that a significant number of 

schools have not. Although Education has made efforts to provide 

guidance to districts on what actions are required and when, the 

department’s efforts do not address several specific issues that would 

allow states, districts, and schools to make well informed decisions that 

are in compliance with NCLBA. For example, many schools in corrective 

action continued efforts implemented previously but did not implement a 

new action. While this course of action may be a reasonable and 

appropriate path for some schools to take, Education has not provided 

guidance to districts delineating when continuing a corrective action—and 

not taking an additional one—is appropriate and when it is not. Without 

written guidance, some districts and schools that are not demonstrating 

sustained improvement may continue previous efforts in order to avoid 

having to make more changes. On the other hand, some districts may not 

know they can comply with NCLBA by continuing an action that is moving 

their schools forward and instead may be struggling to choose another 

prescribed activity that is not needed. 

Conclusions 

While Education monitors states to ensure compliance with NCBLA—and 

has found deficiencies in some districts’ reviews of schools’ improvement 

plans—department officials told us that they were unaware that some 

districts may not be implementing the required corrective action and 

restructuring activities because they do not collect that specific 

information. Collecting information on the activities of schools in 

corrective action and restructuring and on compliance issues identified by 

states would better position Education to target its guidance and 

monitoring on areas of greatest need. 

 39Learning Point Associates, School Restructuring Under No Child Left Behind: What 

Works When? A Guide for Education Leaders. (Naperville, Ill.: 2007).

Page 38 GAO-07-1035 Schools in Corrective Action and Restructuring
Finally, our review indicates that many schools may not be receiving all

the types of assistance that they are supposed to receive through their 

districts. However, Education officials told us that they have not found any 

instances in which schools in corrective action and restructuring have not 

received required assistance, and officials noted that Education does not 

track the extent to which states also have found such incidences. Schools

that are not receiving this assistance might not be able to make the kinds 

of dramatic improvement needed for their students, in part because they

may not be receiving the resources to improve as envisioned by NCLBA. 

The Secretary of Education should: 

• Ensure that guidance is provided to states and districts about when it 

may be appropriate to allow schools to continue corrective action 

implemented in earlier years of improvement and not take a new 

activity as the school moves into corrective action status. 

• Obtain more specific information from states on district 

implementation, such as the primary activity that each school in 

corrective action and restructuring is implementing as well as more 

specific information on compliance issues states have identified as part 

of their monitoring activities. This information should be analyzed to 

identify areas where further federal guidance is needed and to ensure 

that areas of noncompliance are being addressed by states. 

• Take additional steps through Education’s monitoring process to 

ascertain whether states are ensuring that districts provide the 

assistance required by NCLBA. 

Education provided us with written comments on a draft of this report. 

Education agreed with our three recommendations to provide more 

guidance to states and districts, obtain more information on district 

implementation of corrective action and restructuring activities, and take

additional steps to determine whether districts are providing assistance 

required by NCLBA. Specifically, Education agreed to explore options for 

sharing guidance on when schools may continue a corrective action while 

not taking a new one and commented that it will explore sharing guidance 

that address other issues related to schools in corrective action and 

restructuring that it has asked states to identify. While Education noted 

that it is generally informed on the actions taken in schools in corrective 

action and restructuring, it agreed that more information is needed from 

Recommendations 

Agency Comments 

and Our Evaluation 

Page 39 GAO-07-1035 Schools in Corrective Action and Restructuring
states on district implementation of corrective action and restructuring 

activities and that it will consider options for gathering additional 

evidence on how states ensure that districts are complying with corrective 

action and restructuring requirements. Finally, Education agreed to 

consider ways for revising its monitoring procedures in order to obtain 

more information on how states determine whether districts are providing 

technical assistance to these schools, the types of assistance they provide, 

and the actions states take to address areas of noncompliance. See 

appendix III for Education’s comments. Education also provided us with a 

few technical comments that we incorporated. 

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

other interested parties. We will also make copies available to others upon 

request. In addition, the report will be made available at no charge on 

GAO’s Web site at http://www.gao.gov. 

Please contact me at (202) 512-7215 if you or your staff have any questions 

about this report. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

Major contributions to this report are listed in appendix IV. 

Cornelia M. Ashby 

Director, Education, Workforce, 

and Income Security Issues 

Page 40 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

Page 41 GAO-07-1035 

Appendix I: Scope and Methodology 

To address the objectives of this study, we used a variety of methods. To 

obtain a national perspective, we conducted descriptive analyses of 

characteristics of schools in corrective action and restructuring and 

compared them to all other Title I schools nationwide. We selected a 

nationally representative sample of these schools and conducted two Webbased surveys—one of principals whose schools were in corrective action 

and another for schools implementing restructuring—to obtain 

information on implementation of corrective action and restructuring and

school district and state assistance to such schools. We also conducted 

site visits during which we interviewed state, district, and school officials 

representing 5 states and 10 school districts within these states, and we 

conducted phone interviews with state officials from 4 other states. We 

spoke with officials at Education involved in oversight and 

implementation of corrective action and restructuring in schools and 

reviewed Education’s data on schools identified for improvement. We also

interviewed several experts in the field of school improvement. We 

reviewed federal laws, regulations, and agency guidance. We conducted

our work from August 2006 through August 2007 in accordance with 

generally accepted government auditing standards. 

To address the first objective, we obtained lists of schools in corrective 

action, planning for restructuring, and implementing restructuring status

and their school districts from Education. States submitted these lists to 

Education through the No Child Left Behind Act (NCLBA) Consolidated 

State Performance Reports (CSPR) for school year 2004-2005, which 

contained each school’s improvement status for the 2005-2006 school year, 

among other data. Because states provided the names of schools in 

corrective action and restructuring in their 2004-2005 CSPRs, these 

schools comprised the national population of such schools. In some cases, 

states used different labels for identifying schools in corrective action and 

restructuring. For example, one state identified schools in corrective 

action by labeling them as “Year 3” schools. When states used terms other 

than corrective action and restructuring to indicate schools’ improvement 

status, we contacted state officials to clarify the label the state used. 

Education also provided us with numbers of schools in corrective action 

and restructuring for the 2006-2007 school year, which we compared to 

numbers from prior years. On the basis of our review of the data on 

improvement status for school years 2005-2006 and 2006-2007, we 

determined these sources to be sufficient for the purposes of our work. 

We used the lists of schools in corrective action and restructuring for the 

2005-2006 school year to develop our survey samples and for comparisons 

with other Title I schools not identified as needing improvement. 

Objective 1: Analysis 

of School 

Characteristics 

 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

Also in the CSPR, states provided each school’s nationally unique 

identification number, allowing us to link data on these schools with data 

provided in Education’s Common Core of Data (CCD). The CCD is a 

database of Education’s National Center for Education Statistics, which 

annually collects data from state educational agencies about all public 

schools, public school districts, and state educational agencies in the 

United States. At the time we began our analysis, the latest CCD data 

available were from the 2004-2005 school year. Although we based our 

analysis on schools in corrective action and restructuring in 2005-2006, the 

characteristics were based on one year prior. Upon linking schools 

identified in the CSPR to those in the CCD, we obtained data on the 

following characteristics: 

• locale: whether the school was located was in an urban, suburban, or 

rural area or town; 

• minority status: the percent of students in the school classified as 

American Indian/Alaskan Native, Asian/Pacific Islander, Black/NonHispanic, or Hispanic; 

• poverty status: the percent of students in the school who qualified for 

free- or reduced-priced meals; and 

• grade levels served: whether primary, middle, or high school grades. 

To define these levels, we used the definitions provided in the CCD, as 

listed in table 9. 

Table 9: Grade Level Definitions

Grade level served Low grade High grade 

Primary Pre-kindergarten to 3 Up to 8 

Middle 4 to 7 4 to 9 

High 7 to 12 12 

Source: Common Core of Data. 

Schools that did not fit these grade-level configurations were classified as

“other,” meaning any other combination, from the low grades of 

prekindergarten, kindergarten or first grade up to twelfth grade, consistent 

with the CCD definition. 

We compared the percentage of schools in corrective action and 

restructuring with all other Title I schools within each category of the 

Page 42 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

characteristics of locale and grade levels served. For minority status and 

poverty status, we compared schools in corrective action and

restructuring with all other Title I schools by comparing the 

characteristics of the median school within each group.1

 The median is the 

school in the middle of a list of schools when they are listed from highest 

to lowest along any given characteristic, such that one-half of the schools 

are listed above and the other half are listed below that school. For 

example, when all corrective action and restructuring schools were listed 

from highest to lowest in terms of poverty status, the school in the middle 

of that list had a poverty rate of 96 percent. In contrast, when all other 

Title I schools were listed from highest to lowest, the school in the middle 

of that list had a poverty rate of 37 percent. We chose to use the median 

school instead of calculating the average for all schools or all students, 

because so many schools had high rates of poverty and minority student 

representation, that the median more accurately characterized the typical

school in our dataset than did the average. 

We performed a series of tests and took additional steps as needed to

assess the reliability of the data used. For the lists of schools obtained in 

the CSPR and the CCD, we checked to ensure that data were consistent, 

that subtotals added to overall totals and that data provided for 1 year 

bore a reasonable relationship to the next year’s data and to data reported

elsewhere, including state education reports. We also spoke with 

Education officials about their follow-up efforts to verify the data. At the 

time of our review, Education reported that the 2004-2005 data had been 

verified. 

On the basis of our review of these data, we determined these sources to 

be sufficiently reliable for the purposes of our work. We also considered 

school improvement-related findings from Education studies, including 

the National Assessment of Title I Interim Report, Vol. 1: 

Implementation (2006). To ensure the findings from these studies were 

sufficiently reliable, we reviewed each study’s methodology, including 

data sources and analyses, limitations, and conclusions. We found these 

studies to be sufficiently reliable for the purposes of our work. 

 1

We also used locale (urban, suburban, town/rural) to enhance our analyses of minority 

status and poverty status in order to account for the clustering of minority students and 

students who are poor in urban areas. 

Page 43 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

To address the second objective on school’s implementation of corrective 

action and restructuring and the third objective on district and state 

assistance, we designed and administered two Web-based surveys to a 

nationally representative sample of school principals: one for schools in 

corrective action and one for schools in restructuring, as of the 2005-2006 

school year. The surveys were conducted between January and March 

2007. To obtain the maximum number of responses, we sent follow-up 

e-mail notifications with a link to the surveys to those who had not 

completed the survey approximately 1 week after the initial launch and 

additional six follow-up notifications every week thereafter. In addition, 

approximately 3 weeks after the Web surveys began, we provided a mail 

survey to those who had not responded. The surveys included questions 

about corrective actions or restructuring options the school had taken.

Both surveys included questions about factors that may have influenced 

student achievement and assistance provided by the state and district. We 

also conducted site visits to 5 states and 10 school districts and 20 schools 

within these states, during which we conducted interviews and obtained 

documentation on school improvement efforts and related topics. Finally, 

we reviewed Education’s regulations, guidance, and monitoring tools and

interviewed department officials about monitoring and guidance related to

corrective action and restructuring. Specifically, we reviewed the NCLBA, 

associated regulations, Local Education Agency and School Improvement 

Guidance (revised July 2006), monitoring tools and indicators used during 

Education’s site visits, and selected monitoring reports and findings. 

Based on data obtained from the CSPR, the study population of 

1,163 schools consisted of all public Title I schools that were in corrective 

action in the 2005-2006 school year. We selected a random sample of 

schools in the population and calculated the sample size to achieve a 

precision of plus and minus 8 percent at the 95 percent confidence level

for an expected proportion of 50 percent.2

 To ensure the sample sizes were 

adequate, we set the sample size assuming we would obtain a 70 percent 

response rate. The total sample size was 240 schools. In the sample, each

school in the population had a known, nonzero probability of being 

selected. Each selected school was subsequently weighted in the analysis 

Objectives 2 and 3: 

Implementation of 

Corrective Action and 

Restructuring and 

State and District 

Assistance 

Corrective Action Survey 

Sample Design and Errors 

 2

Since the margin of error for a proportion estimate with a given sample size is greatest at 

50 percent, we were conservative when planning the sample size. 

Page 44 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

to account statistically for all the schools in the population, including 

those that were not selected. 

Because we surveyed a sample of schools, survey results are estimates of 

a population of schools and thus are subject to sampling errors that are 

associated with samples of this size and type. Since we followed a 

probability procedure based on random selections, our sample is only one 

of a large number of samples that we might have drawn. As each sample 

could have provided different estimates, we express our confidence in the 

precision of our particular sample’s results as a 95 percent confidence 

interval (for example, plus or minus 8 percentage points). This is the 

interval that would contain the actual population value for 95 percent of 

the samples we could have drawn. As a result, we are 95 percent confident 

that each of the confidence intervals in this report will include the true 

values in the study population. We excluded 8 of the sampled schools, 

because they were not in corrective action status in the 2005-2006 school 

year, were not Title I schools or had closed, and therefore were 

considered out of scope. All estimates produced from the sample and 

presented in this report are representative of the in-scope population. All

percentage estimates included in this report have margins of error of plus 

or minus 8 percentage points or less, unless otherwise noted. 

We took steps to minimize nonsampling errors that are not accounted for 

through statistical tests, like sampling errors. In developing the Web 

survey, we conducted several pretests of draft instruments. We pretested 

the survey instrument with school officials in Aurora, Illinois; Berkeley, 

California; and Orange, New Jersey, between October and November 2006.

We selected schools in these states because they contained large numbers 

of schools in corrective action and thus it was likely that schools from 

these states would be included in our sample. In the pretests, 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 

surveys 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. We

revised the survey on the basis of information we gathered in the pretests. 

A second step we took to minimize nonsampling errors was using a Webbased 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 and make 

Page 45 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

estimations were independently verified to ensure the accuracy of this 

work. 

While we did not fully validate specific information that school officials 

reported in our survey, we took several steps to ensure that the 

information was sufficiently reliable for the purposes of this report. For 

example, data from mailed surveys were double-keyed to ensure data 

entry accuracy, and the information was analyzed using statistical 

software. We obtained corroborating evidence of schools’ improvement 

status when the information provided by the school conflicted with the 

information we had received from the Department of Education. In 

addition, we verified the responses of those schools that reported that the 

school had made AYP. When survey responses did not align with the 

information that we obtained from state Web sites and school report 

cards, we made changes to the survey responses based on documentary 

evidence. After the survey was closed, we also made comparisons between 

select items from our survey data and another national-level data set.3

 We 

found our survey data were reasonably consistent with the external 

sources. On the basis of our checks, we believe our survey data are 

sufficiently reliable for the purposes of our work. 

We received survey responses from 68 percent of the Title I schools in 

corrective action in our sample. After the survey was closed, we analyzed

the survey respondents to determine if there were any differences between 

the responding schools, the nonresponding schools, and the population. 

We performed this analysis for four characteristics—percentage of 

minority students, percentage of students with free lunch, region, and

locale. We found no significant differences between the estimates for the 

survey respondents and the overall population values for these 

characteristics. On the basis of the 68 percent response rate and this 

analysis, we chose to include the survey results in our report and produce 

sample-based estimates to the population of schools in corrective action in

the 2005-2006 school year. 

Response Rate 

 3

We compared our district survey data to data on schools in corrective action reported by 

Education in the National Assessment of Title I Interim Report , Vol. 1: Implementation, 

Institute of Education Sciences (Washington, D.C.: February 2006). 

Page 46 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

The study population of 920 schools consisted of public Title I schools that 

were implementing restructuring in the 2005-2006 school year. This 

population was obtained from the CSPR data provided by Education, as 

described above. We used the same sample design for the restructuring 

Web survey as the design used for the corrective action survey. The total 

sample size was 230 schools. 

Restructuring Survey 

Sample Design and Errors 

We determined that 12 of the sampled schools were out of scope because 

they were not implementing restructuring in the 2005-2006 school year. All 

estimates produced from the sample and presented in this report are 

representative of the in-scope population. All percentage estimates 

included in this report have margins of error of plus or minus 8 percentage

points or less, unless otherwise noted. 

As with the corrective action survey, we took steps to minimize 

nonsampling errors. We pretested the survey instrument with school 

officials in Detroit, Michigan and Syracuse, New York, between October 

and November 2006. We selected schools in these states because the states

contained large numbers of schools implementing restructuring and thus it 

was likely that schools from these states would be included in our sample. 

The pretests were conducted in the same manner as those done for the 

corrective action survey. On the basis of the pretests, the Web instrument 

underwent some revisions. Again, use of a Web-based survey also 

minimized nonsampling errors as did independently verifying programs 

used to analyze the survey data and make estimations. 

Steps taken to ensure that the information was sufficiently reliable for the 

purposes of this report mirror those taken for the corrective action survey, 

including obtaining corroborating evidence of schools’ improvement 

status when the information provided by the school conflicted with the 

information we had received from the Department of Education. When a

survey response did not align with the information that we obtained from

state Web sites and school report cards, we made changes based on our 

documentary evidence. We checked a sample of schools that claimed to 

have made AYP to verify these responses and found that the responses 

were accurate. Again, we made comparisons between select items from 

Page 47 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

our survey data and other national-level data sets,4 and found our survey 

data were reasonably consistent with the external sources. On the basis of 

our checks, we believe our survey data are sufficient for the purposes of 

our work. 

We received survey responses from 74 percent of the Title I schools 

implementing restructuring in our sample. After the survey was closed, we 

analyzed the survey respondents to determine if there were any 

differences between the responding schools, the nonresponding schools, 

and the population, as was done for the corrective action survey. We

found no significant differences between the estimates for the survey 

respondents and the overall population values for these characteristics. 

On the basis of the 74 percent response rate and this analysis, we chose to 

include the survey results in our report and produce sample-based 

estimates to the population of schools in restructuring in the 2005-2006 

school year.

Response Rate 

Combined Surveys Many of the questions on the corrective action survey and restructuring 

survey were the same. For example, on both surveys we asked about the 

assistance provided by the state and district, the factors that impeded or 

facilitated student achievement, and the factors that helped or hindered 

implementation of school improvement efforts. For such questions, we 

combined the survey responses for reporting purposes. We weighted the 

respondents so that the estimates are for the in-scope combined 

population of corrective action and implementing restructuring schools. 

Because we surveyed a sample of schools, our results are estimates of a 

population of Title I schools in corrective action and implementing 

restructuring and thus are subject to sampling errors that are associated 

with samples of this size and type. All percentage estimates included in 

this report have margins of error of plus or minus 8 percentage points or 

less, unless otherwise noted. 

 4

We compared our district survey data to data on schools in restructuring reported by

Education in the National Assessment of Title I Interim Report, Vol. 1: Implementation, 

Institute of Education Sciences (Washington, D.C.: February 2006). We also compared our 

survey data to data on schools in restructuring reported by the Center on Education Policy 

in Wrestling the Devil in the Details: An Early Look at Restructuring in California

(Washington, D.C.: February 2006). 

Page 48 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

To understand corrective action and restructuring implementation at the 

local level, we conducted site visits to 5 states and 10 districts and 

20 schools within these states between October 2006 and March 2007. The 

5 states we chose were: California, Illinois, Maryland, New York, and 

Pennsylvania. Together, these 5 states had 59 percent of schools in 

corrective action and restructuring nationwide in the 2005-2006 school

year and are located in a variety of geographic regions. We interviewed 

state officials on state efforts to oversee and assist schools in corrective 

action and restructuring. 

Site Visits 

Within each of the 5 states, we visited 2 school districts, for a total of 

10 school districts, as shown in table 10. The 10 districts were selected 

because they had experience implementing corrective action and 

restructuring. When viewed as a group, the districts also provided 

variation across characteristics such as geographic location and district 

size. 

Table 10: School Districts Selected for Site Visits

School District City, State 

Baltimore City Public School System Baltimore, Md.

Brentwood Union Free School District Brentwood, N.Y.

Chicago Public Schools Chicago, Ill. 

East Aurora School District #131 Aurora, Ill. 

Los Angeles Unified School District Los Angeles, Calif. 

New York City Department of Education New York, N.Y. 

Pomona Unified School District Pomona, Calif.

Prince George’s County Public Schools Upper Marlboro, Md. 

School District of Philadelphia Philadelphia, Pa. 

York City School District York, Pa. 

Source: GAO.

During the site visits, we interviewed state and district officials as well as 

officials representing 20 schools, including principals, teachers, and other 

school staff involved with school improvement activities in order to 

provide in-depth information and illustrative examples of our more general 

findings. The selected schools resembled the population of schools in 

corrective action and restructuring in terms of the grade levels served, and 

the students’ racial, ethnic, and economic characteristics. While in many 

cases district officials selected the schools we visited, all of the schools 

had experience implementing corrective action or restructuring. Through 

Page 49 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix I: Scope and Methodology 

our interviews with state, district, and school officials, we collected 

information on corrective actions and restructuring options implemented, 

factors affecting student achievement, and state and district assistance 

provided to schools in corrective action and restructuring. 

To address the fourth objective on Education’s efforts to assist states’ 

implementation of corrective action and restructuring provisions, we 

conducted interviews with representatives of the offices of Title I, 

Planning, Evaluation, and Policy Development, What Works 

Clearinghouse, Comprehensive Centers Program, and General Counsel. 

We also interviewed officials with the Center on Innovation and 

Improvement, the California and New York Regional Centers, and the 

Northwest Regional Education Laboratory. 

Objective 4: 

Education’s Efforts to 

Support State 

Implementation 

In addition, we interviewed experts in the field on school improvement, 

including those at the American Institutes for Research, Center on 

Education Policy, Council of the Great City Schools, Council of Chief State 

School Officers, Education Commission of the States, and RAND 

Corporation. We reviewed several studies on school improvement, 

corrective action, and restructuring. 

Page 50 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix II: Number of Schools in Corrective

Action, Planning for Restructuring, and

Implementing Restructuring, by State in 2005-

2006 and 2006-2007 

Table 11: Number of Schools in Corrective Action, Planning Restructuring, and Implementing Restructuring, by State in 2005-

2006 and 2006-2007 

2005-2006 2006-2007

State 

Corrective 

Action 

Planning for

Restructuring

Implementing 

Restructuring Totals

Corrective 

Action

Planning for

Restructuring

Implementing 

Restructuring Totals

Alabama 0 13 27 40 3 5 18 26

Alaska 34 5 8 47 35 30 12 77

Arizona 25 20 4 49 36 12 14 62

Arkansas 4 1 0 5 54 19 4 77

California 406 153 247 806 482 343 357 1,182

Colorado 22 13 3 38 21 16 14 51

Connecticut 4 0 6 10 63 1 6 70

Delaware 2 0 0 2 3 0 1 4

District of 

Columbia 

45 0 0 45 33 0 0 33

Florida 32 0 0 32 544 30 0 574

Georgiaa19 0 66 85 23 19 48 90

Hawaii 2 13 41 56 38 3 50 91

Idaho 0 0 0 0 12 0 0 12

Illinois 151 211 20 382 93 177 138 408

Indiana 10 9 6 25 18 6 9 33

Iowa 0 0 0 0 4 0 0 4

Kansas 0 2 0 2 3 2 0 5

Kentucky 3 6 0 9 56 1 5 62

Louisiana 23 0 6 29 3 4 0 7

Maine 0 0 0 0 4 0 0 4

Maryland 6 6 41 53 15 2 46 63

Massachusetts 32 10 19 61 129 24 26 179

Michigan 22 40 58 120 46 16 37 99

Minnesota 7 1 0 8 10 3 0 13

Mississippi 0 1 1 2 12 0 1 13

Missourib0 7 0 7

Montana 0 0 30 30 4 1 31 36

Nebraska 0 2 0 2 0 1 0 1

Nevada 16 2 0 18 18 9 0 27

New Hampshire 1 0 0 1 2 0 0 2

New Jersey 34 61 0 95 100 16 49 165

New Mexico 16 28 24 68 29 17 48 94

Appendix II: Number of Schools in Corrective 

Action, Planning for Restructuring, and 

Implementing Restructuring, by State in 2005-

2006 and 2006-2007

Page 51 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix II: Number of Schools in Corrective

Action, Planning for Restructuring, and

Implementing Restructuring, by State in 2005-

2006 and 2006-2007 

2005-2006 2006-2007

State 

Corrective 

Action 

Planning for

Restructuring

Implementing 

Restructuring Totals

Corrective 

Action

Planning for

Restructuring

Implementing 

Restructuring Totals

New York 95 43 147 285 67 77 166 310

North Carolina 12 5 0 17 59 10 2 71

North Dakota 3 2 3 8 3 2 14 19

Ohio 25 24 29 78 76 19 33 128

Oklahoma 3 3 4 10 10 3 2 15

Oregon 0 1 0 1 9 0 1 10

Pennsylvania 30 5 83 118 29 15 63 107

Rhode Island 6 2 0 8 9 2 2 13

South Carolina 26 6 7 39 69 27 10 106

South Dakota 13 0 2 15 7 12 2 21

Tennessee 0 13 24 37 10 1 19 30

Texas 3 0 0 3 33 2 0 35

Utah 1 0 1 2 0 0 1 1

Vermont 0 0 0 0 2 0 0 2

Virginia 9 3 0 12 12 2 2 16

Washington 6 9 0 15 26 4 8 38

West Virginia 1 0 1 2 6 0 1 7

Wisconsin 6 7 0 13 7 4 2 13

Wyoming 0 0 0 0 3 0 0 3

Totals 1,155 727 908 2,790 2,330 937 1,242 4,509

Source: GAO analysis of Education data. 

a

For the 2005-2006 school year, Georgia required schools in corrective action to plan for 

restructuring. We reported these schools as in status as corrective action. 

b

For the 2006-2007 school year, Missouri had yet to report which of its schools were identified for 

improvement, corrective action, or restructuring. 

Page 52 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix III: Comments from the Department Appendix III: Comments from the of Education 

Department of Education 

Page 53 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix III: Comments from the Department 

of Education 

Page 54 GAO-07-1035 Schools in Corrective Action and Restructuring
Appendix IV: 

A

GAO Contacts and 

cknowledgments 

Page 55 GAO-07-1035 

Appendix IV: GAO Contacts and 

Acknowledgments 

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

Bryon Gordon, Assistant Director, and Elizabeth Morrison managed the 

assignment. Cara Jackson, Jason Palmer, and Nancy Purvine made 

significant contributions to this report in all aspects of the work. 

Susannah Compton, Nancy Hess, Jean McSween, and Jerome Sandeau 

provided analytical assistance. Sheila McCoy provided legal support, and 

Karen Burke developed the report’s graphics. 

GAO Contact 

Acknowledgments 

 Schools in Corrective Action and Restructuring
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(130594) Page 57 GAO-07-1035 Schools in Corrective Action and Restructuring
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