EDUCATION OF 

HOMELESS 

STUDENTS

Improved Program 

Oversight Needed

Report to Congressional Requesters

July 2014

GAO-14-465

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-465, a report to

congressional requesters

July 2014

EDUCATION OF HOMELESS STUDENTS 

Improved Program Oversight Needed

Why GAO Did This Study

The McKinney-Vento Homeless

Assistance Act established a grant 

program to help the nation’s homeless 

students—more than one million in 

school year 2011-12—have access to 

public education. Under the Education 

for Homeless Children and Youth grant 

program, states and their school 

districts are required to identify 

homeless children and provide them 

with needed services and support. In 

fiscal year 2014, Education received 

about $65 million to administer this 

program. Education provided formula 

grants to states, which competitively 

awarded funds to school districts to 

help meet program requirements. GAO 

was asked to review program

implementation and oversight. 

GAO examined (1) how districts 

identify and serve homeless students 

and challenges they face (2) how 

Education and states collaborate with 

other service providers to address 

student needs and any barriers, and 

(3) the extent to which Education 

monitors program compliance. GAO 

reviewed relevant federal laws, 

guidance, and reports, and analyzed 

Education’s state and school district 

survey data from school year 2010-11. 

GAO also interviewed federal officials, 

and state and local officials in 20 

school districts—representing a mix of 

urban, suburban, and rural districts and 

grant status—in four states, selected 

for geographic diversity and other 

characteristics, such as experience 

with natural disasters. 

What GAO Recommends

GAO recommends that Education 

develop a plan to ensure adequate 

oversight of the EHCY program.

Education concurred with our 

recommendation. 

What GAO Found

To identify and serve homeless students under the Education for Homeless 

Children and Youth (EHCY) program, officials in the 20 school districts where 

GAO conducted interviews reported conducting a range of activities to support 

homeless youth, but cited several challenges. With regard to GAO’s interviews, 

13 of the 20 districts identified homeless students through housing surveys at 

enrollment, while all 20 relied on referrals from schools or service providers. 

However, officials in 8 of the 20 districts noted that the under-identification of 

homeless students was a problem. Districts GAO reviewed provided eligible 

students with transportation to and from school, educational services, and 

referrals to other service providers for support such as health care or food

assistance. Among the challenges that officials in the 20 districts cited were

limited staff and resources to provide services, the cost of transportation, student 

stigma associated with homelessness, and responding to students made 

homeless by natural disasters. Nationally, school districts surveyed most recently 

in school year 2010-11 by the Department of Education (Education) reported 

providing many services while facing similar challenges. 

Education’s EHCY program manager and state program coordinators have 

collaborated with other government agencies and with private organizations by 

sharing information, participating in interagency councils on homelessness, and 

providing technical assistance to relevant staff. In addition, state EHCY program

coordinators have provided training to school districts and helped connect local 

programs to ensure homeless students receive various services. However, 

federal and state officials frequently cited limited resources and differing federal 

definitions of homelessness as constraints to greater collaboration. 

Education has protocols for monitoring state EHCY programs, but no plan to 

ensure adequate oversight of all states, though monitoring is a key management 

tool for assessing the quality of performance over time and resolving problems 

promptly. Prior to fiscal year 2010, it had been Education’s policy to monitor 50 

states and 3 area programs at least once during a 3-year period, and it did so for 

fiscal years 2007 to 2009. Subsequently, the department adopted a risk-based 

approach in fiscal year 2010 and monitored 28 states over the next 3 years. In 

fiscal year 2013, Education again changed its approach to EHCY program 

monitoring and has monitored 3 state programs since then. Department officials 

cited other priorities and a lack of staff capacity as reasons for the decrease in 

oversight. As a result, Education lacks assurance that states are complying with 

program requirements. GAO found gaps in state monitoring of districts that could 

weaken program performance, reinforcing the importance of effective federal 

monitoring of states. 

Declining Frequency of Federal Monitoring for EHCY Compliance since Fiscal Year 2007

View GAO-14-465. For more information, 

contact Kay Brown at (202) 512-7215 or 

brownke@gao.gov.
Page i GAO-14-465 Education of Homeless Students

Letter 1 

Background 5

Selected School Districts Leveraged Existing Resources to 

Identify and Serve Homeless Students, but Faced Resource 

Limitations and Other Challenges 10

Federal and State Agencies Use Numerous Strategies to 

Collaborate to Improve Services to Homeless Students despite 

Barriers 22

Education Currently Lacks a Comprehensive Oversight Plan and 

Faces Limitations in Using its Performance Data to Assess 

Program Results 32

Conclusions 46

Recommendation for Agency Action 47

Agency Comments and Our Evaluation 47

Appendix I Scope and Methodology 50

Appendix II Education for Homeless Children and Youth Program Monitoring 

Indicators 53

Appendix III Comments from the Department of Education 54

Appendix IV Comments from the U.S. Interagency Council on Homelessness 56

Appendix V GAO Contact and Staff Acknowledgments 58

Related GAO Products 59

Contents
Page ii GAO-14-465 Education of Homeless Students

Tables

Table 1: Examples of Federal Programs that May Also Serve 

Homeless Children and Youth 9

Table 2: Selected Examples of Federal Education for Homeless 

Children and Youth (EHCY) Program Collaboration 

Activities within the Department of Education, with Other 

Federal Agencies, and with States 23

Table 3: Number of States Using Various Approaches to Monitor 

Districts, School Year 2010-11 39

Table 4: Required Data Elements from Grantee and Non-grantee 

School Districts 42

Figures

Figure 1: Excerpt of Possible Housing Situations from an Example 

of an Education for Homeless Children and Youth 

Eligibility Determination Form 11

Figure 2: Examples of Referral Sources for Homeless Students 12

Figure 3: Percent of Homeless Students Enrolled Nationwide by 

Primary Nighttime Residence, School Year 2011-12 14

Figure 4: Most Common Services Grantee School Districts 

Reported Providing to Homeless Children and Youth, 

School Year 2010-11 17

Figure 5: Time Spent on Collaboration and Top Collaboration 

Activities, Reported by State Education for Homeless 

Children and Youth (EHCY) Program Coordinators for 

School Year 2010-11 26

Figure 6: Examples of State Education for Homeless Children and 

Youth Program Collaboration Activities 27

Figure 7: Hours Worked by State Education for Homeless 

Children and Youth (EHCY) Program Coordinators and 

Number of Paid Staff in State EHCY Program Offices for 

School Year 2010-11 30

Figure 8: Overview of Education’s Monitoring Process for the 

Education for Homeless Children and Youth Program 34

Figure 9: Frequency of Federal Monitoring for Education for 

Homeless Children and Youth (EHCY) Program 

Compliance since Fiscal Year 2007 35

Figure 10: Frequency of State Monitoring of Grantee and Nongrantee Districts, by Number of States, School Year 

2010-11 40
Page iii GAO-14-465 Education of Homeless Students

Abbreviations

21st CCLC 21st Century Community Learning Centers

CoC Continuum of Care

Education Department of Education

EHCY Education for Homeless Children and Youth

ESEA Elementary and Secondary Education Act of 1965, as 

 amended

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development

LEA Local Educational Agency

LGBTQ Lesbian, Gay, Bisexual, Transgender, or 

 Questioning

MEP Migrant Education Program

NAEHCY National Association for the Education of Homeless 

 Children and Youth

NCHE National Center for Homeless Education

RHY Runaway and Homeless Youth programs 

SASA Student Achievement and School Accountability

SEA State Educational Agency

USICH United States Interagency Council on Homelessness

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

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Page 1 GAO-14-465 Education of Homeless Students

441 G St. N.W.

Washington, DC 20548

July 31, 2014

The Honorable Tom Harkin

Chairman

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable Patty Murray

United States Senate

In school year 2011-12, more than 1.1 million children and youth enrolled 

in our nation’s public schools were identified as homeless, according to 

data from the U.S. Department of Education (Education).1 Homeless 

children and youth may face a variety of barriers to continuing their 

education, including frequent moves, a lack of transportation to and from 

school, and a lack of adequate supplies and services, such as 

counseling, that may be necessary to help them remain in school. 

Research on homeless and highly mobile children suggests that they face 

challenges with academic achievement and school completion. We 

previously reported that students who change schools more frequently 

tend to have lower scores on standardized reading and math tests and 

drop out of school at higher rates than their less mobile peers.2 In 

addition, according to a study of an urban school district from school 

years 2005-06 to 2009-10, homeless and highly mobile children were 

more likely to exhibit lower levels of academic achievement compared 

with other students.3

The Education for Homeless Children and Youth (EHCY) program, 

initially authorized by Title VII-B of the McKinney-Vento Homeless 

Assistance Act (McKinney-Vento Act), helps address barriers to school 

 

1

Department of Education, National Center for Homeless Education, Education for 

Homeless Children and Youths Program: Data Collection Summary (March 2014).

2

GAO, K-12 Education: Many Challenges Arise in Educating Students Who Change 

Schools Frequently, GAO-11-40 (Washington, D.C.: Nov. 18, 2010).

3

J. J. Cutuli et al., “Academic Achievement Trajectories of Homeless and Highly Mobile 

Students: Resilience in the Context of Chronic and Acute Risk,” Child Development, vol. 

84, no. 3 (2013). 
 

Page 2 GAO-14-465 Education of Homeless Students

enrollment, attendance, and success for homeless children and youth.4

The act requires state educational agencies to ensure that homeless 

children and youth have equal access to the same free appropriate public 

education, including a public preschool education, as provided to other 

children. Congress appropriated about $65 million to carry out the EHCY 

program in fiscal year 2014.5 The McKinney-Vento Act authorizes 

Education to provide federal grants to states to administer and oversee 

activities under the EHCY program.6 In turn, states award a majority of 

these funds on a competitive basis to select school districts in their state 

(grantee districts), based on factors such as the needs of homeless 

children and youth within a particular district and the ability of the district 

to meet those needs.7 Regardless of whether a school district receives 

EHCY program funds, all districts must comply with certain program 

requirements, which include ensuring that homeless children and youth 

are appropriately identified, immediately enrolled in school, and receive 

the educational and other services for which they are eligible, such as 

transportation to and from school. In addition, as GAO has reported in the 

past, collaboration presents an opportunity to increase the efficiency and 

effectiveness of federal programs.8

 

4

Stewart B. McKinney Homeless Assistance Act, Pub. L. No. 100-77, §§ 721-725, 101 

Stat. 482, 525-28 (codified as amended at 42 U.S.C. §§ 11431-11435). In 2000, the law 

was renamed the McKinney-Vento Homeless Assistance Act. Pub. L. No. 106-400, 114 

Stat. 1675 (2000). The EHCY program was significantly amended by the McKinney-Vento 

Homeless Education Assistance Improvements Act of 2001, enacted as part of the No 

Child Left Behind Act of 2001, Pub. L. No. 107-110, §§ 1031-1034, 115 Stat. 1425, 1989-

2007 (2002). 

Because no one system of services 

can meet every need of students experiencing homelessness, and 

5

See generally Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, div. H, tit. III, 

128 Stat. 5, 391-92 (2013). The amount for the EHCY program was specified in a report 

from the Senate Committee on Appropriations. S. Rep. No. 113-71, at 166 (2013).

6

See 42 U.S.C. § 11432. In general, subject to minimum award requirements, the amount 

that a state receives for the EHCY program is based on the proportion of funds allocated 

nationally that it receives under Title I, Part A of the Elementary and Secondary Education 

Act of 1965, as amended (ESEA). 

7

See 42 U.S.C. § 11433. For purposes of this report, we use the term “school district” to 

refer to a local educational agency. In addition, for the purposes of our report, we refer to 

districts that received an EHCY grant from their state as “grantee districts,” and those that 

did not as “non-grantee districts.” 

8

GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, and 

Duplication and Achieve Other Financial Benefits, GAO-13-279SP (Washington, D.C.: 

Apr. 9, 2013).
 

Page 3 GAO-14-465 Education of Homeless Students

funding for the EHCY program is set at relatively modest levels, 

collaboration at the federal, state, and local levels is essential to address 

the academic and non-academic needs of homeless students. The 

McKinney-Vento Act requires states and school districts to coordinate and 

collaborate with other programs and service providers that also serve 

these children and youth. In light of the issues facing homeless students, 

you asked us to examine the implementation and oversight of the EHCY 

program.

This report addresses (1) how school districts identify and serve 

homeless students and the challenges in doing so, (2) how Education and 

states collaborate with other agencies and service providers to address 

the needs of homeless students and barriers to collaboration, and (3) the 

extent to which Education monitors compliance with the EHCY program 

requirements and how Education assesses program results.

To gather information on how the EHCY program is implemented at the 

local level, we visited three states—Colorado, New Jersey, and 

Washington—and interviewed officials in Texas by phone.9 We selected 

states that represent geographic diversity and based on the 

recommendations of experts, including the National Association for the 

Education of Homeless Children and Youth (NAEHCY)10

 

9

It was not the purpose of this report to assess states’ or districts’ compliance with the 

McKinney-Vento Act.

and other 

national organizations working on issues related to homelessness, to 

obtain a mix of states implementing promising practices in their EHCY 

programs as well as experiencing challenges. In addition, we sought 

variation in the number of homeless students states identified in recent 

years and the size of states’ EHCY grants, among other factors. We also 

selected two states that have recently experienced natural disasters to 

see how they coped with sudden increases in the number of homeless 

students. In each state, we interviewed state and school district officials. 

In total, we spoke with school district officials from 20 different school 

districts, nine of which were grantee districts. We selected these districts 

10NAEHCY is a membership organization made up of local homeless education liaisons, 

educators, school counselors, social workers, registrars, nurses, child advocates, shelter 

staff, state and federal policy specialists, and partners from community-based and national 

non-profit organizations. It provides professional development, resources, and training 

support on meeting the educational needs of children and youth experiencing 

homelessness.
 

Page 4 GAO-14-465 Education of Homeless Students

with the assistance of state EHCY program coordinators to represent a 

mix of urban, suburban, and rural districts, as well as grantee and nongrantee districts. In the states we visited, we also met with school officials 

and youth or their families who have experienced homelessness. 

Information obtained from these states and school districts is nongeneralizable. To obtain generalizable and national-level information on 

states and grantee school districts, we analyzed Education data from two 

surveys covering school year 2010-11, which we found to be sufficiently 

reliable.11

We conducted this performance audit from July 2012 through July 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

We assessed the reliability of the survey data by performing 

electronic testing of the data elements, reviewing relevant documentation, 

and interviewing agency officials knowledgeable about the data. We used 

the survey data to examine how states and school districts implement the 

EHCY program and how states monitor school districts, among other 

things. All estimates obtained from the school district-level survey have 

margins of error of no greater than six percentage points. To obtain 

information on how Education administers the EHCY program and 

collaborates with other agencies, we interviewed Education officials and 

officials from other federal agencies, including the Departments of Health 

and Human Services (HHS) and Housing and Urban Development 

(HUD), as well as the U.S. Interagency Council on Homelessness 

(USICH). We also reviewed relevant documents—including federal laws 

and regulations, monitoring protocols, and policy memos—and examined 

Education’s findings on the EHCY program from state monitoring reports. 

See appendix I for additional information on our scope and methodology.

 

11Education is expected to release a report based on these surveys in 2014.
 

Page 5 GAO-14-465 Education of Homeless Students

The EHCY program is the key federal education program targeted to 

homeless children and youth, and, in school year 2011-12, more than 1.1 

million were enrolled in our nation’s public schools,12 according to 

Education data.13

• are sharing the housing of others due to loss of housing, economic 

hardship, or a similar reason (commonly referred to as “doubled-up”);

For purposes of the program, a homeless child or youth 

is one who lacks a fixed, regular, and adequate nighttime residence. This 

includes children who:

• are living in motels, hotels, trailer parks, or camping grounds due to 

the lack of alternative adequate accommodations;

• are living in emergency or transitional shelters; are abandoned in 

hospitals; or are awaiting foster care placement;

• have a primary nighttime residence that is a public or private place not 

designed for or ordinarily used as a regular sleeping accommodation 

for human beings;

• are living in cars, parks, public spaces, abandoned buildings, 

substandard housing, bus or train stations, or similar settings; and

• are migratory children who qualify as homeless due to their living 

circumstances, as described above.14

Education’s Office of Student Achievement and School Accountability 

(SASA)—within the Office of Elementary and Secondary Education—

provides EHCY formula grants to states, which must comply with certain 

 

12These data include only those children and youth enrolled in school who were identified 

and reported as homeless by school districts; these data do not include homeless children 

and youth enrolled in school who were not identified or reported by school districts or 

homeless children and youth not enrolled in school. Due to changes in how the data 

collection instrument for states was pre-populated beginning in school year 2011-12, the 

number of homeless students that year cannot be compared to prior years. However, 

Education reported a 13 percent increase in the number of homeless students enrolled—

from 939,903 to 1,065,794—between school years 2009-10 and 2010-11. 

13Department of Education, National Center for Homeless Education, Education for 

Homeless Children and Youths Program: Data Collection Summary (March 2014).

1442 U.S.C. § 11434a(2). In this report, when we refer to the EHCY program definition of 

homelessness, we mean this definition. “Migratory child” is defined in section 1309 of the 

ESEA, see 20 U.S.C. § 6399(2).

Background

The Education for 

Homeless Children and 

Youth Program
 

Page 6 GAO-14-465 Education of Homeless Students

requirements.15 For example, the McKinney-Vento Act requires each 

state that receives funds to establish an Office of Coordinator for 

Education of Homeless Children and Youths, with responsibilities that 

include carrying out the state plan.16

States are generally required to award no less than 75 percent of their 

grant to school districts on a competitive basis.

The state plan describes, among 

other things, procedures that will be used to identify homeless children 

and youth, strategies to address challenges, such as enrollment delays, 

and a demonstration of the state’s efforts to review and revise policies to 

remove barriers to the enrollment and retention of homeless children and 

youth. Among other responsibilities, state educational agencies report 

data to Education on the educational needs of their homeless students; 

provide technical assistance to school districts and monitor their 

compliance with the program; and facilitate collaboration between the 

state and other service providers that serve homeless children and youth 

and their families.

17 Grants to school 

districts, awarded for a period of up to 3 years, are to be used for 

activities that facilitate the enrollment, attendance, and success of 

homeless children and youth in school. Grants to districts are to be 

awarded based on the need of the school district for assistance and the 

quality of the application submitted.18

 

15See generally 42 U.S.C. § 11432. In addition to the 50 states, the District of Columbia, 

Puerto Rico, the outlying areas (the U.S. Virgin Islands, Guam, American Samoa, and the 

Northern Mariana Islands) and the Bureau of Indian Affairs also receive funds. Apart from 

the outlying areas and the Bureau of Indian Affairs, funds are generally allocated to states 

based on each state’s share of ESEA Title I, Part A funds.

In determining which districts to 

fund, states are required to consider certain factors, such as the needs of 

homeless children and youth enrolled in the school district, the types of 

services to be provided under the program, and the extent to which the 

services will be coordinated with other services available to homeless 

children and youth. Districts are authorized to use these funds to support 

a range of activities for homeless students, such as tutoring, 

transportation, and referrals to health care services, as well as to provide 

16 For the purposes of this report, we refer to the Office of Coordinator as the state 

coordinator for the EHCY program. 

1742 U.S.C. §§ 11432(e)(1), 11433(c)(1). States that receive the minimum state award 

amount are required to distribute no less than 50 percent to districts. States may use the 

remaining funds for state-level activities. 

1842 U.S.C. § 11433(c).
 

Page 7 GAO-14-465 Education of Homeless Students

professional development for educators and support coordination 

between schools and other agencies.19 According to Education data, in 

school year 2011-12, fewer than a quarter of school districts nationwide 

(3,531 out of 16,064) received EHCY program funds; these districts 

enrolled 68 percent of the homeless students identified that year.20

Education also allows states to use a regional approach to award their 

competitive grants. Through such an approach, according to the National 

Center for Homeless Education (NCHE), 21

Regardless of whether a school district receives EHCY program funds, all 

school districts are required to comply with certain requirements of the 

McKinney-Vento Act, including designating a homeless liaison to ensure 

that homeless children and youth are appropriately identified and 

provided the educational services for which they are eligible, among other 

things.

a state may provide funds to 

established regional educational entities, geographic clusters of school 

districts defined by the state, clusters self-selected by neighboring school 

districts, or some combination of these approaches. According to 

Education’s survey of states in school year 2010-11, the most recent 

survey data available, 16 states reported that they provided funds through 

an intermediate educational agency or consortia.

22

• remain in their school of origin, if in their best interest;

Under the McKinney-Vento Act, homeless children and youth 

have certain rights, including the right to:

23

 

1942 U.S.C. § 11433(d). 

20Data from school year 2011-12 are the most recent data available. 

21NCHE is Education’s technical assistance and information center for the EHCY 

program. It provides research, resources, and information that help communities address 

the educational needs of children experiencing homelessness. NCHE also supports 

educators and service providers by producing training and awareness materials, and 

providing training at regional and national conferences and events. 

2242 U.S.C. § 11432(g)(1)(J)(ii), (g)(6).

23The “school of origin” is the school that the child or youth attended when permanently 

housed or the school in which the child or youth was last enrolled. 42 U.S.C. § 

11432(g)(3)(G). In determining the best interest of a child or youth, a district must, to the 

extent feasible, keep a homeless child or youth in the school of origin unless doing so is 

contrary to the wishes of the child or youth’s parent or guardian. 42 U.S.C. § 

11432(g)(3)(A)-(B). 
 

Page 8 GAO-14-465 Education of Homeless Students

• immediately enroll in the selected school, even without the records, 

such as proof of residency, typically required;24

• receive services comparable to those offered to other students for 

which they are eligible, such as transportation, educational services, 

and free school meals.

and

25

Other programs administered by Education and other federal agencies, 

many of which receive more federal funding than the EHCY program, 

may also support the needs of homeless children and youth (see table 1 

for selected examples). For example, under Title I, Part A of the 

Elementary and Secondary Education Act of 1965, as amended (ESEA), 

school districts are required to set aside funds as necessary to provide 

comparable services for homeless students who do not attend Title I 

schools.26 In addition, grantee school districts are required to coordinate 

with other organizations serving homeless children and youth, including 

those operating programs funded under the Runaway and Homeless 

Youth Act.27 The populations served by these programs vary, and for 

some programs, eligibility for services does not depend on being 

homeless. Among the programs that do target homeless populations, 

some use definitions of homelessness that are different from the one 

used by the EHCY program.28

 

2442 U.S.C. § 11432(g)(3)(C).

2542 U.S.C. § 11432(g)(4).

2620 U.S.C. § 6313(c)(3)(A). Under Education’s regulations, school districts are also 

directed to reserve Title I funds as reasonable and necessary to conduct “other authorized 

activities,” which, according to Education officials, could include providing additional 

support to homeless students who do attend Title I schools. 34 C.F.R. § 200.77(g). In 

addition, the Consolidated Appropriations Act, 2014 authorized school districts to use Title 

I funds to support homeless liaisons and provide transportation for homeless students to 

their schools of origin. Education notified state Title I directors and EHCY state 

coordinators of these new flexibilities in a letter dated March 21, 2014.

2742 U.S.C. § 11432(g)(5). Runaway and Homeless Youth programs provide temporary 

emergency shelter, transitional housing, street outreach services, and maternity group 

home programs for youths to help them transition to self-sufficiency.

28For example, a different provision in the McKinney-Vento Act defines homeless 

individuals eligible for services under the Homeless Assistance programs administered by 

HUD. See 42 U.S.C. § 11302. Other programs, such as the Head Start program 

administered by HHS, use the EHCY definition of homeless children and youth. 42 U.S.C. 

§ 9832(11).

Other Federal Programs 

that May Also Support 

Homeless Children and 

Youth
 

Page 9 GAO-14-465 Education of Homeless Students

Table 1: Examples of Federal Programs that May Also Serve Homeless Children and Youth 

Federal 

Agency Program Description 

Funding for fiscal 

year 2014 (in 

millions of dollars)

Education Improving Basic Programs Operated 

by Local Educational Agencies (Title I, 

Part A of the Elementary and 

Secondary Education Act) 

Provides financial assistance to school districts and 

schools with high concentrations of children from lowincome families to help ensure that all children meet 

challenging state academic standards 

14, 384.8 

Education Individuals with Disabilities Education 

Act, Parts B and C

Part B supports special education and related 

services for children with disabilities aged 3–21 and 

Part C supports early intervention services for 

children younger than 3 years of age 

12,264.6 

Education Migrant Education Program Aims to ensure that migratory children are provided 

with appropriate education services that address 

their special needs and receive full and appropriate 

opportunities to meet the same challenging state 

academic content and student academic 

achievement standards that all children are expected 

to meet, among other purposes 

374.8 

Education 21st Century Community Learning 

Centers

Supports the creation of community learning centers 

that provide academic enrichment opportunities 

during non-school hours for children, particularly 

students who attend high-poverty and low-performing 

schools 

1,149.4 

HHS Head Start Serves preschool-age children and their families and 

promotes the school readiness of children from birth 

to age 5 from low-income families by enhancing their 

cognitive, social, and emotional developmenta

 

8,598.1 

HHS Runaway and Homeless Youth Supports temporary emergency shelter, transitional 

housing, street outreach services, and maternity 

group home programs to serve and protect runaway 

and homeless youth 

114.1 

HUD Homeless Assistance Programs 

(including Emergency Solutions Grants 

and Continuum of Care Program)

Provide emergency shelter, supportive services, 

transitional housing, permanent housing, and 

prevention resources to assist individuals in shelters 

or on the streets attain permanent housing and selfsufficiency 

2,105.0 

Source: Education, HHS, and HUD agency program descriptions and budget documents for fiscal year 2015, reporting appropriated amounts for fiscal year 2014. | GAO-14-465

Note: This table is not intended to be exhaustive; other programs may also serve homeless children 

and youth that are not described here.

a

Homeless children are automatically eligible for the Head Start program. 

The McKinney-Vento Act also created the U.S. Interagency Council on 

Homelessness (USICH), which currently consists of 19 federal cabinet 
 

Page 10 GAO-14-465 Education of Homeless Students

secretaries and agency heads.29 The Homeless Emergency Assistance 

and Rapid Transition to Housing (HEARTH) Act of 2009 established as 

the mission of USICH to coordinate the federal response to 

homelessness and create a national partnership at every level of 

government and with the private sector to reduce and end 

homelessness.30

To identify homeless students, officials in a majority of school districts (13 

of 20) said their districts systematically requested some information on 

the housing status of new students using a form during the enrollment 

process.31

 

29See 42 U.S.C. §§ 11311-11320. Title II of the McKinney-Vento Act established the 

“Interagency Council on the Homeless” in 1987. The Consolidated Appropriations Act, 

2004, renamed it the “United States Interagency Council on Homelessness.” Pub. L. No. 

108-199, div. G, § 216, 118 Stat. 3, 394. 

Two of these districts also requested housing information from 

every student every year to help identify eligible students whose housing 

circumstances may have changed following enrollment. According to the 

National Center for Homeless Education (NCHE), using a questionnaire 

at enrollment can help school districts increase their identification of 

homeless students (see fig. 1).

30Pub. L. No. 111-22, div. B, § 1004, 123 Stat. 1632, 1666 (codified at 42 U.S.C. § 

11311).

31Officials in the remaining seven districts told us they used other methods to identify 

homeless students. For example, districts may identify students as homeless informally at 

enrollment through conversations with new students. 

Selected School 

Districts Leveraged 

Existing Resources to 

Identify and Serve 

Homeless Students, 

but Faced Resource 

Limitations and Other 

Challenges

Selected School Districts 

Largely Relied on 

Enrollment Forms and 

Referrals to Identify 

Homeless Students, but 

Faced Challenges and 

Noted Problems with 

Under-Identification
 

Page 11 GAO-14-465 Education of Homeless Students

Figure 1: Excerpt of Possible Housing Situations from an Example of an Education 

for Homeless Children and Youth Eligibility Determination Form

Please choose which of the following situations the student currently resides in (you can 

choose more than one): 

_____ House or apartment with parent or guardian

_____ Motel, car, or campsite

_____ Shelter or other temporary housing

_____ With friends or family members (other than or in addition to parent/guardian)

If you are living in shared housing, please check all of the following reasons that apply:

_____ Loss of housing

_____ Economic situation

_____ Temporarily waiting for house or apartment

_____ Provide care for a family member

_____ Living with boyfriend/girlfriend

_____ Loss of employment

_____ Parent/Guardian is deployed

_____ Other (Please explain)

Are you a student under the age of 18 and living apart from your parents or guardians?

Yes No

Source: National Center for Homeless Education. | GAO-14-465

To identify students who were not identified at enrollment or whose 

housing status changed during the year, homeless liaisons in the 20 

school districts we interviewed also relied on referrals from school staff or 

other service providers (see fig. 2).32

 

32Under the McKinney-Vento Act, liaisons are to ensure that homeless students are 

identified by school personnel and through coordination with other entities and agencies. 

42 U.S.C. § 11432(g)(6)(A)(i).
 

Page 12 GAO-14-465 Education of Homeless Students

Figure 2: Examples of Referral Sources for Homeless Students 

Officials said they provided information and training to a variety of staff in 

contact with students to help them recognize potential signs of 

homelessness, such as:

• students who provide home addresses of shelters or other students;

• students who request transportation changes;

• students with attendance problems or who are tardy;

• students who fall asleep in class; and

• students with dropping grades, hunger, or hygiene issues.

Officials we interviewed also discussed the importance of training staff to 

identify homeless students, as identifying currently enrolled students is 

less systematic than identifying new students at enrollment.

Despite ongoing efforts to identify homeless students through housing 

surveys and referrals, officials in 8 out of the 20 districts we interviewed 

noted a problem with the under-identification of homeless students. All 

four state EHCY program coordinators we interviewed acknowledged that 

school districts face financial disincentives to identifying homeless 

children and youth due to the cost of services districts must provide. 
 

Page 13 GAO-14-465 Education of Homeless Students

Officials from both grantee and non-grantee districts33 reported facing 

significant challenges in identifying all eligible students.34

Officials in 11 of the 20 districts we interviewed said they identified 

increasing numbers of homeless children and youth in recent years, and 

many noted the frequent mobility of some students, making it challenging 

for school staff to keep track of their homeless students.

Officials in 4 of the 20 districts said it was challenging to identify children 

and youth living doubled-up with others, particularly where living with 

extended family may be a cultural norm. In such cases, families may not 

consider themselves to be homeless or may be unaware of their rights to 

receive services under the program. For example, officials in one district 

told us that many of the district’s immigrant families who work for a local 

meat processor live with relatives in doubled-up conditions but do not 

consider themselves homeless. To help clarify program eligibility, one 

district we reviewed used its enrollment form to ask parents or guardians 

to check a box when they are “living ‘doubled-up’ due to economic 

emergency, not to save money or for cultural preference.” 

In one school district we reviewed, the enrollment form asks parents or 

guardians to check a box “if the student is homeless or living in 

temporary/transitional housing,” and asks whether the student is an 

“unaccompanied youth,” but does not describe eligible housing situations. 

As a result, a student who is living doubled-up due to economic 

circumstances may not be identified, even though this situation 

represents a majority of homeless students nationwide (see fig. 3).

 

33For the purposes of our report, we will refer to districts that received an EHCY grant 

from their state as “grantee districts,” and those that did not as “non-grantee districts.” 

34Three of four state EHCY program coordinators we interviewed said grantee and nongrantee districts generally face the same challenges. The fourth state EHCY program 

coordinator did not compare challenges between grantee and non-grantee districts. 

Student Mobility

Confusion Regarding Applying 

Eligibility Requirements

Limited Information from 

Housing Surveys
 

Page 14 GAO-14-465 Education of Homeless Students

Figure 3: Percent of Homeless Students Enrolled Nationwide by Primary Nighttime 

Residence, School Year 2011-12

Nationally, according to Education’s survey of grantee school districts in 

school year 2010-11, homeless liaisons spent a median amount of nearly 

2 hours per week on their responsibilities for the EHCY program.35

One liaison said there is confusion around “awaiting foster care 

placement,” a term used to describe some children and youth eligible for 

the EHCY program. Specifically, the liaison told us that she would receive 

requests for services for children in foster care, rather than for children 

awaiting foster care placement.

Many 

liaisons said that they juggled multiple responsibilities, including duties 

outside of the EHCY program. Officials in 7 of the 20 districts cited their 

limited availability to provide training and outreach or the lack of 

sufficiently trained school personnel as a challenge to identifying eligible 

students. In one state we visited the state EHCY program coordinator 

who surveyed homeless liaisons on the amount of time they spent on the 

EHCY program said she has found a link between the amount of time 

liaisons spend on the EHCY program and the number of homeless 

students they have identified.

36

Officials in 7 of the 20 districts said that stigma around being identified as 

homeless makes it challenging to identify eligible children and youth. One 

formerly homeless student we interviewed described her initial 

In another district, a liaison said that 

among the district’s many military families, the term “transition,” 

sometimes used to describe eligible families, has a meaning unrelated to 

homelessness.

 

35The 95 percent confidence interval for this median is from 1.6 to 1.9.

36In this state, according to the state educational agency, a child is awaiting foster care 

placement during the period of time between the initial placement of the child into state 

care and the 30-day shelter care hearing—at which time the court reviews the status of 

the child and either orders the child to return home or to remain in placement (i.e. in foster 

care). 

Limited Staff Availability for 

Training and Outreach

Confusion Regarding 

Terminology

Stigma
 

Page 15 GAO-14-465 Education of Homeless Students

identification as very traumatic because she did not want anyone at 

school to know about her housing status and did not want to be called 

homeless. She said she would rather have received bad grades in high 

school than have her teachers know of her situation. Another said that 

she did not want anyone to know she was homeless but found it difficult 

to hide when she had to resort to “couch-surfing” in the homes of many 

different people.

Some officials we spoke with suggested the districts under-identify 

unaccompanied homeless youth,37 including lesbian, gay, bisexual, 

transgender, or questioning (LGBTQ) youth who tend to be 

overrepresented in the homeless youth population.38

Officials in 5 of 20 districts told us that some families fear being known to 

government entities, such as child protective services, police, and 

immigration services. For example, officials in one district said parents 

may be afraid that the child protective services agency will remove their 

children from their custody if they are discovered to be homeless.

Officials in five 

districts told us they are involved in efforts targeted to LGBTQ youth. For 

example, an official in one of these districts said the district has been 

involved in focus groups and worked with service providers on how to 

better identify and serve these youth who may have separated from their 

families due to their LGBTQ identification.

Natural disasters, including floods and a hurricane that forced many 

families from their homes, also presented challenges for some districts 

we reviewed. To identify the large numbers of students displaced 

simultaneously in these districts, officials working in four of five districts 

we interviewed about their experiences with natural disasters relied 

heavily on staff and outside resources (e.g., shelters and community 

meetings).39

 

37Unaccompanied youth are those not in the physical custody of a parent or guardian. 42 

U.S.C. § 11434a(6). 

However, officials said that factors such as families’ 

38Andrew Cray, Katie Miller, and Laura E. Durso, Seeking Shelter: The Experiences and 

Unmet Needs of LGBT Homeless Youth, Center for American Progress (Washington, 

D.C.: September 2013).

39Officials in one of these districts said they relied on students to self-identify while 

another district also used previously scheduled parent-teacher conferences to identify 

students.

Identification of Homeless 

LGBTQ Youth

Fear of Government

Natural Disasters
 

Page 16 GAO-14-465 Education of Homeless Students

unwillingness to self-identify and frequent mobility following the disaster 

created challenges to identifying and serving students. For example, 

officials in a district affected by heavy flooding said that immediately 

following the flooding, families moved in with relatives or other families 

and did not necessarily consider themselves to be homeless. However, 

as time passed, the district had to identify families in another wave as 

families again were displaced from where they initially had moved.

Under-identification can negatively affect homeless students’ ability to 

access needed services and to succeed in school. For example, 

according to a formerly homeless youth we interviewed, prior to being 

identified as homeless during his final year of school, he had been 

receiving Fs on his report card. After being identified, he received a bus 

pass, school supplies, and a laptop—necessary supplies to help him 

graduate. Although he faced significant pressures outside of school, 

according to a school official, and challenges completing his schoolwork, 

he graduated and was able to obtain employment. Another 

unaccompanied homeless youth said that after he was identified as 

homeless he received assistance with school work and clothing for an 

internship, and was very happy to be able to stay at the same high 

school. Some officials we interviewed noted that children and youth not 

connected to school or other services can be particularly challenging to 

identify, leaving them most at risk of failing to receive necessary services.

Students experiencing homelessness have diverse needs, ranging from 

school-related to more basic needs. Nationally, grantee school districts in 

school year 2010-11 most frequently reported transportation to and from 

school, family or student preoccupation with survival needs, and frequent 

mobility from school to school as among homeless students’ greatest 

barriers to school enrollment, attendance, and success, respectively, 

according to Education’s survey of these school districts.40

 

40Officials in grantee school districts were asked to select among eight barriers to school 

enrollment, six barriers to school attendance, and nine barriers to school success, aside 

from “other (please specify).” 

Some officials 

we interviewed cited similar barriers. For example, a high school principal 

said that the most pressing need for homeless students in his school is 

for a safe place to sleep, and students who are worried about where they 

will sleep at night will not be focused on their studies. Some of the 

homeless youth we spoke with also indicated that stable housing or food 

Selected School Districts 

Leveraged Resources to 

Serve Homeless Students, 

but Faced Resource and 

Coordination Challenges
 

Page 17 GAO-14-465 Education of Homeless Students

were among their significant needs. Specifically, one unaccompanied 

homeless youth we interviewed—who has lived with a series of family 

members since leaving her mother’s home—said that while she currently 

sleeps on the couch in her uncle’s house, she worries every day about 

her next move as she does not know how long she will be allowed to stay.

To help address the needs of homeless students, grantee school districts 

in school year 2010-11 reported providing a variety of services, according 

to Education’s survey (see fig. 4).

Figure 4: Most Common Services Grantee School Districts Reported Providing to Homeless Children and Youth, School Year 

2010-11

Notes: The figure depicts services that an estimated 50 percent of grantee districts or more reported 

providing. All estimates in this figure have margins of error of less than six percentage points.

Similarly, the school districts we reviewed provided a range of services 

and supports to address the various needs of homeless students, which 

presented some challenges. These include transportation, coordination 
 

Page 18 GAO-14-465 Education of Homeless Students

with other educational services, and partnering with community 

organizations:

Officials we interviewed said their districts provided eligible students with 

transportation to and from school, as required by the McKinney-Vento 

Act, through means such as public transit, district buses, taxi cabs, gas 

assistance and mileage reimbursements.41

However, district officials also reported challenges providing 

transportation due to cost and logistics. Nationally, according to 

Education’s survey of grantee districts in school year 2010-11, an 

estimated 52 percent of them ranked defraying the cost of transportation 

among the services on which they spent the most EHCY funds

Officials in 9 of the 20 districts 

also said they collaborated with neighboring districts to transport 

homeless students across district boundaries, such as by splitting 

transportation costs or dividing responsibility for routes to and from 

school.

42 and 

about one-third of districts (37 percent) reported that coordinating 

transportation services was among their responsibilities that took the 

most time. Officials in 7 of the 20 districts we interviewed reported similar 

challenges. For example, one homeless liaison said that in school year 

2011-12 the district spent $550,000 on cabs to transport homeless 

students.43

 

41State plans are required to contain assurances that the state and its school districts will 

adopt policies and practices to ensure that transportation is provided, at the request of the 

parent or guardian (or in the case of unaccompanied youth, the liaison) to and from the 

school of origin. 42 U.S.C. § 11432(g)(1)(J)(iii).

Officials in another district told us of a student who spent 4 

hours per day commuting to and from the child’s school of origin—the 

42The Consolidated Appropriations Act, 2014 authorized school districts to use ESEA Title 

I funds to provide transportation for homeless students to their schools of origin. 

Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, div. H, tit. III, 128 Stat. 5, 388 

(2013).

43Officials told us the district did not receive an EHCY grant. The state’s EHCY program 

coordinator said that to ensure that EHCY grant funds are not used solely to defray the 

costs of transportation, the state limits the amount of the grant districts can use for 

transportation purposes to 65 percent. 

Transportation
 

Page 19 GAO-14-465 Education of Homeless Students

school that the family had requested.44 While district officials did not think 

this was in the best interest of the child, officials said they did not think 

they could refuse to provide transportation due to the distance.45

Officials in the districts we interviewed coordinated with other education 

programs and districts to help address homeless students’ needs. For 

example, some districts used ESEA Title I, Part A funds to provide 

students with tutoring, uniforms, and funds for class fees, as well as 

hygiene kits, clothing and laundry vouchers, among other things.

Some 

district officials we spoke with also said coordinating transportation across 

districts can be difficult. For example, billing and being billed by other 

districts can be inefficient and problematic. A district transportation official 

we interviewed noted the significant amount of administrative work it 

takes to arrange a student’s transportation. For example, she said she 

could spend an entire day trying to figure out how to free up a bus driver 

to transport one homeless student to and from school when she also 

needs to worry about the transportation of another 500 students.

46

 

44The McKinney-Vento Act requires school districts to place homeless children or youth in 

either their school of origin or in a public school in the local attendance area where they 

are actually living, according to the best interest of the child or youth. 42 U.S.C. § 

11432(g)(3)(A). In making the best interest determination, the Act states that to the extent 

feasible, a school district shall keep a student in the school of origin, unless doing so is 

contrary to the wishes of the parent or guardian. If a district decides to place a student in a 

school that is not the school of origin or one requested by the parent or guardian, it must 

provide a written explanation to the parent or guardian along with a statement about their 

right to appeal the placement decision. 42 U.S.C. § 11432(g)(3)(B). 

Officials in 7 of the 20 districts said these funds also supported salaries 

for positions that support homeless students, such as EHCY program 

staff, social workers and homeless student advocates. In addition, 

officials in some districts said they have coordinated with staff from 

45According to Education guidance, school districts may consider the age of a child or 

youth, the distance of a commute, and the impact it may have on a student’s education, 

among other things, in determining what is feasible. 

46According to Education, homeless children and youth are automatically eligible for 

ESEA Title I, Part A services. Under Title I, Part A, school districts must reserve, or set 

aside, such funds as are necessary to provide comparable services to homeless children 

who are not attending Title I schools. 20 U.S.C. § 6313(c)(3)(A). For example, Title I, Part 

A funds may be used to provide educationally-related support services, such as tutoring, 

to children at shelters, motels, and other places where homeless children may live.

According to officials, Education’s regulations also permit school districts to reserve Title I 

funds to provide support to homeless students who do attend Title I schools. See 34 

C.F.R. § 200.77(g). 

Coordinating Educational 

Services
 

Page 20 GAO-14-465 Education of Homeless Students

special education programs to help facilitate services for homeless 

students; migrant education programs to help identify homeless migrant 

children; and in some instances, preschool programs to serve homeless

preschool-aged children. Officials in 5 of the 20 districts said their 

preschool programs reserved spaces for homeless preschool-aged 

children or prioritized these students for services,47 and in four of these 

districts, officials said the district transported homeless preschoolers to 

and from school.48

Officials in 11 of the 20 districts we interviewed cited challenges due to 

limited staff availability or resources with which to serve homeless 

students and adequately address their needs. For example, a school 

principal in a K-8 school we visited without full-time counselors or support 

staff said homeless students there have access to about 30 percent of the 

support services the school would like to offer them. In another high 

school we visited, officials said there is a severe lack of resources at the 

school to support homeless students. Specifically, according to officials, 

teachers currently fund a “food closet” on nearly every floor of the high 

school to meet the needs of hungry students.

Some officials also described coordinating with other 

districts. For example, officials in three districts said they coordinated with 

other districts to help homeless students obtain partial credit for work 

completed elsewhere but said that such efforts could be challenging. In 

one extraordinary case, we spoke with an official who said he worked for 

months to obtain a student’s transcript from an African refugee camp to 

be able to eventually verify the student had received 33 credits, 

exceeding the 22 necessary to graduate. According to a formerly 

homeless youth we interviewed, receiving credit for work completed was 

very important to help her meet graduation requirements as she moved 

across the country twice during high school and attended a total of four 

high schools.

 

47In some of the districts, the preschool programs officials referred to were Head Start 

programs. Homeless children who meet the EHCY program definition are automatically 

eligible for Head Start. Homeless preschoolers are also a target population under the 

McKinney-Vento Act. For example, each state plan must include procedures to ensure 

that homeless children have equal access to the same public preschool programs, 

administered by the state educational agency, as provided to other children in the state. 

42 U.S.C. § 11432(g)(1)(F)(i).

48In one of these districts, an official said that homeless preschoolers can ride the bus but 

must be accompanied by a sibling. According to Education guidance, a district must 

provide transportation for homeless preschoolers only if it provides transportation for other 

preschoolers.
 

Page 21 GAO-14-465 Education of Homeless Students

To expand their ability to serve homeless students’ needs, district and 

school officials also leveraged community resources to provide students 

with access to additional services and supports. For example, some 

officials we interviewed said that they referred homeless students or their 

families to organizations and agencies that provide health and mental 

health services, as well as to other community organizations, such as 

food pantries and shelters for students’ pressing needs.49 Officials in 6 of 

the 20 districts reported they assisted homeless youth in accessing public 

benefits, such as for health care or food. Officials in some districts also 

said they referred students to other federal programs, such as Head Start 

and Runaway and Homeless Youth (RHY) programs, and housing 

programs for services.50

School districts also played an important role in addressing the needs of 

students displaced by natural disasters and maintaining their school 

stability. For example, in the immediate aftermath, officials we interviewed 

in one of five districts about their experiences with natural disasters said 

In one district we visited officials said they 

improved referrals for services by developing trainings for an interagency 

committee comprised of various community stakeholders on resources 

and services available to homeless students. However, officials said that 

a lack of community resources affected their ability to meet student 

needs. For example, officials in a number of school districts we 

interviewed (9 of 20) said the lack of available or affordable housing 

options made it challenging to address the needs of homeless children 

and their families.

 

49Under the McKinney-Vento Act, liaisons must ensure that homeless children, youth, and 

their families receive referrals to health care, mental health, dental, and other appropriate 

services. 42 U.S.C. § 11432(g)(6)(A)(iii).

50Officials in four districts said that the use of different federal definitions of homelessness 

has created some challenges or confusion. Some HUD programs use a definition of 

homelessness that is different than the EHCY program definition. For example, according 

to officials we spoke with some families living doubled-up may not be eligible for HUD 

programs. As we have previously reported, the HEARTH Act of 2009 broadened the 

definition of homelessness used by HUD homeless assistance programs. However, the 

HEARTH Act did not fully align the definitions used by the EHCY program and the 

homeless assistance programs. For example, an individual or family who is sharing 

housing with others may be eligible for services under the homeless assistance programs, 

but only if they will imminently lose their housing, have no subsequent residence 

identified, and lack the resources or support networks need to obtain other permanent 

housing. Unaccompanied youth and homeless families with children and youth who meet 

the EHCY program definition may be eligible for homeless assistance programs as well, 

but only under certain other circumstances. See 42 U.S.C. § 11302(a)(5)-(6).

Partnering with Community 

Organizations
 

Page 22 GAO-14-465 Education of Homeless Students

three schools were used as emergency shelters for families. Officials in 

four districts said they received a great deal of community support 

through donations—such as mattresses, heaters, food, clothing and 

supplies—to help address the significant needs of displaced students and 

families. However, officials also reported challenges in serving large 

numbers of newly identified homeless students, sometimes without 

additional funds for services. For example, one district without EHCY 

grant funds spent $750,000 to transport displaced students to and from 

school and to pay tuition to other districts where some students began 

attending school, according to officials. Maintaining contact with families 

through their moves was also a challenge for some officials we 

interviewed. In one district, officials said they were unaware of the 

number of students who have not returned to their school of origin or who 

plan to relocate permanently to where they went after the storm. In 

addition, officials in another district discussed the need for counseling 

following the trauma that students faced in fleeing and coping with a 

natural disaster.

Homelessness Following a Natural Disaster

Three families we interviewed who were displaced from their homes following a 

hurricane—two of whom moved at least twice in the months following—told us of the 

important role their children’s school played in helping to address their many needs. In 

addition to transportation and school supplies, the school provided homeless families with 

free before- and after-school care for students, food, gift cards, and clothing—some of 

which were donated by other organizations, businesses, and school districts, within and 

outside the state. According to school officials, families were also offered counseling 

services, though meeting students’ needs for counseling has been a challenge. Officials 

described how children faced significant trauma following the storm. For example, one 

student carried a sibling on her back to escape rising floodwaters.

Source: Interviews with school officials and families. | GAO-14-465

Federal and State 

Agencies Use 

Numerous Strategies 

to Collaborate to 

Improve Services to 

Homeless Students 

despite Barriers
 

Page 23 GAO-14-465 Education of Homeless Students

The federal EHCY program manager collaborates with officials from other 

Education programs, federal agencies, and states (see table 2).51 These 

collaborative efforts are designed to share information with other 

programs likely to serve homeless students and increase awareness 

about the EHCY program and the rights of, and services available to, 

homeless students, among other things. In addition, the EHCY program 

manager provides training and technical assistance to state program 

coordinators. GAO has previously found that collaboration is essential for 

increasing the efficiency and effectiveness of federal programs and 

activities in areas where multiple agencies or programs have similar 

goals, engage in similar activities, or target similar beneficiaries.52

Table 2: Selected Examples of Federal Education for Homeless Children and Youth (EHCY) Program Collaboration Activities 

within the Department of Education, with Other Federal Agencies, and with States

Examples of collaboration activities with officials and staff from 

other Department of Education (Education) programs, offices, or 

initiatives Collaboration partners within Educationa

• EHCY program manager presents information to individuals 

responsible for implementing other Education programs, 

according to the EHCY program manager.

Officials responsible for administering:

• Elementary and Secondary Education Act, Title I, Part A 

programs

• Migrant Education Program

• Elementary and Secondary Education Act, Title III 

programsb

• Officials from other Education programs/offices present at EHCY 

state coordinator conferences, according to the EHCY program 

manager.

Officials responsible for administering:

• Migrant Education Program

• Office of Special Education and Rehabilitative Services 

programs

• Early Learning Initiative (Office of Early Learning)

• Officials from other Education programs/offices present at the 

annual National Association for the Education of Homeless 

Children and Youth conference, according to the EHCY program 

manager.

Officials responsible for administering:

• Elementary and Secondary Education Act, Title I, Part A 

programs

• Office of Safe and Healthy Students programs

 

51The federal EHCY program manager has primary responsibility for overseeing the 

EHCY grant making process; providing technical assistance, including serving as the 

contract representative for NCHE; program monitoring and oversight; reviewing program 

performance data; and coordinating interagency collaboration efforts. 

52GAO-13-279SP. 

The Federal EHCY 

Program Manager 

Collaborates with Officials 

from Other Education 

Programs, Federal 

Agencies, and States to 

Increase Awareness about 

Homeless Education
 

Page 24 GAO-14-465 Education of Homeless Students

Examples of collaboration activities with officials and staff from 

other Department of Education (Education) programs, offices, or 

initiatives Collaboration partners within Educationa

• Officials from other Education programs generally review 

materials developed by the National Center for Homeless 

Education (NCHE) that pertain to their programs, according to 

Education officials.

Officials responsible for administering:

• Elementary and Secondary Education Act, Title I, Part A 

programs

• Migrant Education Program

• Office of Special Education and Rehabilitative Services 

programs 

• Office of Early Learning programs

• EHCY program manager discusses relevant issues with staff 

from other Education programs, such as data on the number of 

students applying for financial aid for college as “independent,” 

according to the EHCY program manager.c

• Office of Postsecondary Education

Examples of collaboration activities with other federal agencies 

and entities

Collaboration partners from other federal 

agencies/entities

• As a member of the U.S. Interagency Council on Homelessness 

(USICH), Education shares responsibility with other agencies in 

fulfilling the council’s mission to “coordinate the Federal 

response to homelessness and to create a national partnership 

at every level of government and with the private sector to 

reduce and end homelessness in the nation while maximizing the 

effectiveness of the Federal Government in contributing to the 

end of homelessness.”d

• U.S. Interagency Council on Homelessness 

• Initiative to facilitate data sharing at the local level, according to 

Education and other federal officials.e • U.S. Interagency Council on Homelessness

• Department of Housing and Urban Development 

• Initiative to better understand how to prevent homelessness 

among lesbian, gay, bisexual, transgender, or questioning 

(LGBTQ) youth.

• U.S. Interagency Council on Homelessness

• Department of Housing and Urban Development

• Department of Health and Human Services

• Department of Justice

Examples of collaboration activities with states

• Provides technical assistance and training to state EHCY 

program coordinators, as required by the McKinney-Vento Act, 

often through NCHE.f

o NCHE develops and shares issue briefs, tool kits, and other 

materials; disseminates information via its website and 

listserv; conducts training webinars and self-paced online 

training; and operates a helpline available to state and local 

EHCY program officials and staff, and others.

• Provided additional technical assistance after recent natural 

disasters, according to Education and state officials.

o NCHE is hosting a natural disaster workgroup of state EHCY 

program coordinators to develop a new section of the state 

coordinator handbook on preparing for, and responding to, 

natural disasters, according to Education and state officials.

 

Source: GAO analysis of documentation and interviews with officials from the Department of Education, other federal agencies, and states. | GAO-14-465

a

Selected examples of Education offices, programs, and initiatives with which the EHCY program 

manager collaborates.
 

Page 25 GAO-14-465 Education of Homeless Students

b

Title III of the Elementary and Secondary Education Act of 1965 (ESEA), as amended, authorizes 

federal funding for language instruction for limited English proficient and immigrant students.

c

A student’s dependency status determines whose financial information he or she is required to 

provide when filling out the Free Application for Federal Student Aid to apply for federal financial aid 

for college or university. Students determined to be “dependent” must provide financial information 

about their parents as well as themselves, whereas students determined to be “independent” must 

only provide their own financial information (and their spouse’s if married). By law, unaccompanied 

homeless youth are considered “independent” and do not have to provide their parents’ financial 

information. 20 U.S.C. § 1087vv(d)(1)(H).

d

42 U.S.C. § 11311. USICH has developed a federal strategic plan to prevent and end homelessness 

called Opening Doors: Federal Strategic Plan to Prevent and End Homelessness. This plan has four 

main goals. They are (1) Finishing the job of ending chronic homelessness by 2015; (2) Preventing 

and ending homelessness among veterans by 2015; (3) Preventing and ending homelessness for 

families, youth, and children by 2020; and (4) Setting a path to ending all types of homelessness.

USICH monitors and reports on the progress of implementation of the strategic plan, including the 

activities of agencies and programs. 

e

HUD officials told us that they have also collaborated with the EHCY program manager, HHS, and 

USICH on initiatives to obtain an accurate count of children and youth experiencing homelessness 

and better understand the characteristics of those children and youth, and with the EHCY program 

manager and USICH on aligning housing status indicators and developing a cross walk of definitions 

of homelessness across programs to improve local collaboration and data analysis. In addition HUD 

has worked with the EHCY program manager on an initiative to identify and spread innovative 

practices employed by homeless housing providers to ensure fair and equal education of homeless 

children and youth, according to HUD officials. 

f

Education is required to provide support and technical assistance to a state educational agency to 

assist it in carrying out its EHCY responsibilities, if requested by the state educational agency. 42 

U.S.C. § 11434(b).

State EHCY program coordinators collaborate with other state agencies, 

service providers and school districts to improve services to homeless 

children and youth. The McKinney-Vento Act requires state EHCY 

coordinators to facilitate coordination between the state educational 

agency and other state agencies and to collaborate with school district 

homeless liaisons, service providers, and community organizations, 

among others.53 According to Education data from its survey of state 

EHCY program coordinators covering school year 2010-11, 30 state 

coordinators ranked coordinating with other organizations and agencies 

to provide and improve services to homeless children and youth among 

the three activities on which they spend the most time.54

 

5342 U.S.C. § 11432(f)(4)(5).

Thirty-six state 

coordinators reported that building programmatic linkages among various 

programs, agencies, or organizations was among the top three 

54Providing technical assistance was the only activity that more state coordinators (42) 

reported among the top three activities on which they spend their time. In addition, 24 

ranked raising awareness and understanding among districts of the requirements of the 

McKinney-Vento Act and the role of the district homeless liaison among the top three 

activities. 

State Educational 

Agencies Collaborate with 

Other State Agencies, 

Service Providers, and 

School Districts
 

Page 26 GAO-14-465 Education of Homeless Students

collaboration efforts that improved program administration and/or services 

to homeless children and youth (see fig. 5).

Figure 5: Time Spent on Collaboration and Top Collaboration Activities, Reported by State Education for Homeless Children 

and Youth (EHCY) Program Coordinators for School Year 2010-11

The collaborative activities state EHCY program coordinators engage in 

may vary depending on whether they are collaborating with school 

districts, other programs, interagency councils, or non-governmental 

entities (see fig. 6).
 

Page 27 GAO-14-465 Education of Homeless Students

Figure 6: Examples of State Education for Homeless Children and Youth Program Collaboration Activities

State EHCY program collaboration activities with other state agencies, 

programs, service providers, and associations have included raising 

awareness of the program, developing joint products, such as strategic 

plans, and efforts to better connect students to services. For example, 

state EHCY program staff in one state told us they collaborate with the 

state’s health department and Children’s Health Insurance Program to 

make sure students have access to immunizations and help homeless 

families apply for health insurance for their children. Additionally, they 

collaborate with the state agriculture department to ensure homeless 

children have immediate access to free school meals. One state 

coordinator told us that she has partnered with the 21st Century 

Community Learning Centers (21st CCLC) program, which allowed the 

state to increase the number of high schools receiving 21st CCLC funding 
 

Page 28 GAO-14-465 Education of Homeless Students

from 5 to 37 and increased the resources available to serve homeless 

students.55

State EHCY program coordinators we interviewed provide technical 

assistance and training to school districts, as required by the McKinneyVento Act,

In addition, three state coordinators we spoke with told us that 

they have worked with universities in their states to, for example, provide 

information about students experiencing homelessness and barriers they 

face to higher education. Officials in one state told us that this 

collaboration has led over 30 public institutions of higher learning to 

identify a single point of contact within the school to advocate for 

homeless students.

56 but the amount and type of assistance varies, particularly in 

districts that do not receive EHCY grants. According to Education’s 

survey of state EHCY program coordinators, nearly half (24 of 50), 

responded that providing technical assistance was the activity on which 

they spend the most time, and 42 said it was among the top three 

activities. While district homeless liaisons we spoke with generally told us 

that they receive a good deal of technical assistance and support from 

their state coordinator, in one state we visited, non-grantee school district 

liaisons told us that they have limited interactions with their state 

coordinator.

Both federal and state officials frequently cited limited staff capacity as a 

barrier to greater collaboration. At the federal level, the EHCY program is 

administered by Education’s Office of Student Achievement and School 

Accountability (SASA) and run largely by a single individual – the EHCY 

program manager. The EHCY program manager has primary 

responsibility for administering the EHCY program. In addition, this 

individual is responsible for overseeing a second Education program – 

ESEA Title I, Part D (Prevention and Intervention Programs for Children 

and Youth Who Are Neglected, Delinquent, or At Risk). The EHCY 

program manager told us that capacity is a challenge to additional 

 

55The 21st Century Community Learning Centers (21st CCLC) program is an Education 

program which supports the creation of community learning centers that provide academic 

enrichment opportunities during non-school hours for children, particularly students who 

attend high-poverty and low-performing schools. Some states, if they are approved for a 

waiver by Education, may also offer expanded learning time programs within the school 

day. 

5642 U.S.C. § 11432(f)(6).

Federal and State 

Agencies Face Similar 

Barriers to Greater 

Collaboration
 

Page 29 GAO-14-465 Education of Homeless Students

collaboration. For example, he only attends conferences for Title I and 

other Education programs every few years. Similarly, while state EHCY 

program coordinators we spoke with generally felt that there is significant 

collaboration with other entities, several also told us that staff capacity 

was a significant barrier to further collaboration. State coordinators are 

generally responsible for managing the EHCY grant process, monitoring 

and overseeing implementation of the EHCY program at the school 

district level, and providing technical assistance and training to school 

district personnel, including homeless liaisons; sometimes in several 

hundred school districts. Many state coordinators have responsibilities in 

addition to those for the EHCY program. According to Education’s survey 

data from school year 2010-11, 23 of the 50 state EHCY program 

coordinators reported working 30 hours or more per week on EHCY 

program responsibilities. The same survey found that more than half of 

the states (27) had one or fewer full-time employees working in the state 

EHCY program office (see fig. 7). For example, one state coordinator we 

spoke with was also the coordinator for another education program, which 

she said takes up about 40 percent of her time.57

 

57While such arrangements might facilitate collaboration between the two programs under 

the same coordinator, it may also create challenges to collaboration with other programs 

due to the additional responsibilities of that single individual for multiple programs.
 

Page 30 GAO-14-465 Education of Homeless Students

Figure 7: Hours Worked by State Education for Homeless Children and Youth (EHCY) Program Coordinators and Number of 

Paid Staff in State EHCY Program Offices for School Year 2010-11

According to state EHCY program coordinators, resource constraints 

have prevented additional collaboration efforts. For example, three state 

coordinators told us they must choose which partners to collaborate with 

at the expense of others. In one of these states, this has meant limited 

collaboration with RHY programs. In GAO’s previous work, we have 

emphasized the importance of agencies identifying and leveraging 

sufficient funding to accomplish their objectives and to initiate or sustain 

their collaborative efforts and we suggested approaches to help them do 

so.58

Federal and state officials also said that differing definitions of who is 

considered “homeless” under various federal programs was another 

 

58GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012); GAO, 

Results-Oriented Government: Practices that Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005); 

GAO, Managing for Results: Implementation Approaches Used to Enhance Collaboration 

in Interagency Groups, GAO-14-220 (Washington, D.C.: Feb. 14, 2014).
 

Page 31 GAO-14-465 Education of Homeless Students

barrier to collaboration.59 Because the population eligible for services 

under each program differs, the populations contained in data collected 

by one agency will be different than in data collected by other agencies, 

making data sharing more difficult. The federal EHCY program manager 

told us that the lack of a consistent definition across programs 

administered by Education and HUD has created a challenge to 

increasing data sharing at the local level between school districts and 

Continuums of Care (CoC).60

 

59GAO has previously reported on the lack of a common definition of homelessness 

across federal agencies and programs. See GAO, Homelessness: A Common Vocabulary 

Could Help Agencies Collaborate and Collect More Consistent Data, 

Because a relatively small number of 

students considered homeless under Education’s definition may be 

eligible for services funded by CoCs, these entities sometimes feel that 

the additional work necessary to share the data is not worthwhile, 

according to the EHCY program manager. Nationally, most homeless 

students are “doubled up.” Officials from one state told us that because 

this is the case in their state, though school districts want to provide wraparound services that meet the wide variety of homeless youths’ needs, 

GAO-10-702 

(Washington, D.C.: June 30, 2010). As we reported in 2012, the HEARTH Act of 2009 

broadened the definition of homelessness used by HUD homeless assistance programs. 

See GAO, Homelessness: Fragmentation and Overlap in Programs Highlight the Need to 

Identify, Assess, and Reduce Inefficiencies, GAO-12-491 (Washington, D.C.: May 10, 

2012). However, the HEARTH Act did not fully align the definitions used by the EHCY 

program and the homeless assistance programs.

60The CoC program is designed to assist individuals (including unaccompanied youth) and 

families experiencing homelessness and to provide the services needed to help such 

individuals move into transitional and permanent housing, with the goal of long-term 

stability. The program is designed to promote community-wide planning and strategic use 

of resources to address homelessness; improve coordination and integration with 

mainstream resources and other programs targeted to people experiencing 

homelessness; improve data collection and performance measurement; and allow each 

community to tailor its program to the particular strengths and challenges within that 

community. HUD awards CoC program funding competitively to nonprofit organizations, 

states, and/or units of general purpose local governments, which may contract or subgrant 

with other organizations or government entities to carry out the grant’s day-to-day program 

operations.
 

Page 32 GAO-14-465 Education of Homeless Students

these students may be ineligible for services through HUD programs.61

However, one school district in one of the states we reviewed has entered 

into an agreement with the local CoC that allows school district personnel 

to access and enter data into the CoC’s Homeless Management 

Information System. This partnership allows the school district and CoC 

partners to track the services homeless students have received, evaluate 

the need for additional services, and make referrals for those services, 

among other functions. A state EHCY program coordinator we spoke with 

told us that a common definition would allow Education and HUD 

programs to pool data, increasing collaboration and efficiency. This 

official said that instead of redundant data collection, resources could be 

used to provide additional services.

 

61Under the EHCY program, homeless children and youth include those who are sharing 

the housing of others due to loss of housing, economic hardship, or a similar reason. 42 

U.S.C. § 11434a(2)(B)(i). Under the Continuum of Care program, an individual or family 

who is sharing housing with others may be considered homeless, but only if they will 

imminently lose their housing, have no subsequent residence identified, and lack the 

resources or support networks need to obtain other permanent housing. Unaccompanied 

youth and homeless families with children and youth who meet the EHCY program 

definition may meet the definition of homeless for the Continuum of Care program as well, 

but only under certain other circumstances. See 42 U.S.C. § 11302(a)(5)-(6).

Education Currently 

Lacks a 

Comprehensive 

Oversight Plan and 

Faces Limitations in 

Using its 

Performance Data to 

Assess Program 

Results
 

Page 33 GAO-14-465 Education of Homeless Students

Education has protocols and procedures in place to monitor state EHCY 

programs. According to Education guidance, monitoring is the regular and 

systematic examination of a state’s administration and implementation of 

a federal education grant, contract, or cooperative agreement.62 To hold 

states accountable to provide a free appropriate public education to 

homeless students,63 Education evaluates the degree to which states 

meet certain standards, called monitoring indicators64

• monitoring of school districts;

(see appendix II). 

These include data on:

• implementation of procedures to identify, enroll, and retain homeless 

students by coordinating and collaborating with other program offices 

and state agencies;

• provision of technical assistance to school districts;

• efforts to ensure that school district grant plans for services to eligible 

homeless students meet all requirements;

• compliance with statutory and other regulatory requirements 

governing the reservation of funds for state-level coordination 

activities; and

• prompt resolution of disputes.

Education’s monitoring involves a review of documents, followed by an 

on-site or videoconference review, and preparation of a final report that 

includes any compliance findings for which the state must take corrective 

 

62In addition, GAO’s Standards for Internal Control in the Federal Government state that 

internal control should generally be designed to assure that ongoing monitoring occurs in 

the course of normal operations, is performed continually, and is ingrained in the agency’s 

operations. See GAO, Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

63The McKinney-Vento Act requires Education to determine the extent to which state 

educational agencies are ensuring that each homeless child and youth has access to a 

free appropriate public education. 42 U.S.C. § 11434. In some states, preschool programs 

are operated under the authority of entities other than the state educational agency or 

school districts. Because the McKinney-Vento Act requirements only apply to state 

educational agencies and school districts, Education has no role in monitoring homeless 

education in preschool programs operated by other entities.

64U.S. Department of Education, Student Achievement and School Accountability 

Programs (SASA) Monitoring Plan for Formula Grant Programs (March 2013). The 

published indicators provide guidance for all states regarding the purpose and intended 

outcomes of monitoring by describing what is being monitored and providing the criteria 

for judging the quality of implementation.

Education Has Protocols 

for Monitoring State EHCY 

Programs but Lacks a 

Plan to Ensure Oversight 

of All States
 

Page 34 GAO-14-465 Education of Homeless Students

action (see fig. 8).65 Between fiscal years 2007 and 2009, Education’s 

policy was to monitor 50 states and 3 other areas (i.e., 53 “states”)66

Figure 8: Overview of Education’s Monitoring Process for the Education for 

Homeless Children and Youth Program

at 

least once during that 3-year time period and it followed this policy.

Starting in fiscal year 2010, Education adopted a risk-based approach to 

select states for monitoring to more efficiently target and prioritize limited 

resources, resulting in longer gaps between monitoring visits in some 

states. Education conducts an annual risk assessment to evaluate which 

states have the highest risk of noncompliance, according to the EHCY 

program manager. The agency weighs the following four risk assessment 

criteria equally: the state’s academic proficiency levels for students 

experiencing homelessness, the tenure of the state EHCY program 

coordinator, whether there are multiple or recurring EHCY monitoring 

 

65A finding is a compliance issue that has a required corrective action by the state 

educational agency.

66In addition to the 50 states, Education’s Office of Student Achievement and School 

Accountability (SASA) also monitors the District of Columbia, the Commonwealth of 

Puerto Rico, and the Bureau of Indian Education. For the purposes of this report, we refer 

to all of these as states. Education also provides EHCY grants to the outlying areas (the 

U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands), but 

according to SASA officials these areas consolidate their eligible federal funds under Title 

V and are therefore monitored by a different office, the Office of School Support and Rural 

Programs, within the Office of Elementary and Secondary Education. 
 

Page 35 GAO-14-465 Education of Homeless Students

findings, and a financial review of the state’s EHCY grant expenditures.67

Figure 9: Frequency of Federal Monitoring for Education for Homeless Children and 

Youth (EHCY) Program Compliance since Fiscal Year 2007

Education also considers the size of the state’s EHCY grant allocation 

and the length of time since a state was last monitored. Since Education 

adopted this approach in fiscal year 2010, it has monitored 31 of the 53 

states for the EHCY program—28 from October 2009 to September 2012 

and 3 from October 2012 to July 2014. Of the 22 remaining states, 

Education last monitored 7 states in fiscal year 2007, 6 in fiscal year 

2008, and 9 in fiscal year 2009 (see fig. 9).

Note: Between fiscal years 2007 and 2009, Education monitored 53 entities for EHCY compliance, 

including the 50 states, the District of Columbia, the Commonwealth of Puerto Rico, and the Bureau 

of Indian Education. For the purposes of this report, we refer to all of these as states.

In the fall of 2012 Education began monitoring states that had received 

waivers from certain ESEA requirements under an initiative Education 

calls “ESEA Flexibility” and since that time, has monitored three states for 

 

67Education’s final determination of the level of risk averages the risk levels for its EHCY 

program as well as for another Education program under Title I, Part D (State Agency 

Program for Neglected and Delinquent Children and Youth), which uses the same criteria.
 

Page 36 GAO-14-465 Education of Homeless Students

compliance with the EHCY program.68 Under Education’s ESEA flexibility 

initiative, 44 of the 53 states69 currently have waivers from specific 

requirements of the ESEA, as amended. In these states, Education has 

conducted regular monitoring, but the monitoring only covers compliance 

with the ESEA waiver requirements and does not include monitoring for 

compliance with the EHCY program. As a result, the states with ESEA 

waivers currently have little EHCY program oversight at the federal 

level.70 Education officials cited the shift to a risk-based approach to 

monitoring the EHCY program, the more recent need to focus on ESEA 

flexibility waiver monitoring, and a lack of staff capacity as the primary 

reasons why they have not been able to monitor the states as frequently 

in recent years as in the past. Education officials said they intend to 

continue to monitor the EHCY program in the future, but the agency has 

not determined when or how it will do so. Standards for internal control 

emphasize the need for federal agencies to establish plans to help ensure 

goals and objectives can be met, including compliance with applicable 

laws and regulations.71

As a result of reducing the number of monitoring visits, Education has 

been unaware of the compliance status of some states for an extended 

Absent a plan for future monitoring of grantees, 

Education cannot be sure that problems will be identified and resolved 

promptly.

 

68The ESEA authorizes the Secretary of Education to waive, with certain exceptions, any 

statutory or regulatory requirement of ESEA for states or school districts that receive 

ESEA funds and submit a waiver request that meets statutory requirements. 20 U.S.C. § 

7861. In 2011, Education invited states to request waivers of specific requirements of the 

ESEA, as amended. To be approved, Education required states to develop and implement 

specified changes, including comprehensive plans to improve educational outcomes for all 

students, close achievement gaps, increase equity, and improve the quality of instruction. 

Education reviewed requests and granted waivers to 45 states through school year 

2013−14; however, one state’s waiver is not being renewed after the 2013-14 school year, 

making the current total 44 states with waivers. Under the ESEA, waivers can be effective 

for up to 4 years, although they may be extended. These waivers do not exempt states 

from requirements of the McKinney-Vento Act.

69The states currently without ESEA waivers are the Bureau of Indian Education, 

California, Iowa, Montana, Nebraska, North Dakota, Vermont, Washington, and Wyoming.

70According to Education officials, although the agency has not conducted on-site 

monitoring of the EHCY program for these states, it has conducted annual risk 

assessments and analyzed state and school district performance data. Officials also said 

that Education responds to complaints it may receive and provides technical assistance.

71See GAO/AIMD-00-21.3.1.
 

Page 37 GAO-14-465 Education of Homeless Students

period of time. According to GAO’s Standards for Internal Control in the 

Federal Government, monitoring is a key management tool that helps 

agencies assess the quality of performance over time and ensure that the 

problems are promptly resolved.72

Because of Education’s limited monitoring of some states, it may not be 

aware of states’ current practices and whether they comply with program 

requirements and their state plans, which Education has not required 

states to update since 2002.

Additionally, one state EHCY program 

coordinator we interviewed said that federal monitoring ensures a higher 

level of compliance with the McKinney-Vento Act and that it is in a state’s 

best interest to be monitored regularly. According to this program 

coordinator, monitoring helps states improve how they address homeless 

students’ needs and provides important leverage within the state to 

ensure that program funds are used as intended. Of the 22 states that 

Education has not monitored since at least fiscal year 2009, 10 had been 

required to take corrective actions following their last review to address 

compliance concerns. While Education found these actions to be 

sufficient, according to officials, Education is currently unaware of 

whether these states have remained in compliance and it is possible that 

they (or other states) may have new or recurring compliance issues. For 

example, one of the states we visited had not monitored its grantees onsite since school year 2008-09, whereas NCHE recommends states 

monitor grantees on-site at least once every 3 years.

73 According to agency officials, Education 

has not requested updates to state plans because it has been waiting for 

the next reauthorization of the EHCY program before requesting new 

state plans.74

 

72See 

The EHCY program manager said that the agency reviews 

state plans as part of its monitoring review and that some states have 

GAO/AIMD-00-21.3.1. 

73Under the McKinney-Vento Act, states are required to develop plans that describe how 

they will implement the program and submit the plans to Education. 42 U.S.C. § 11432(g). 

Education is responsible for reviewing state plans using a peer review process and 

evaluating whether state laws, policies, and practices described in the plan adequately 

address the problems of homeless children and youths relating to access to education and 

placement as described in the plan. 42 U.S.C. § 11434(a).

74The EHCY program was last reauthorized as part of the ESEA reauthorization in 2002. 

Reauthorization of the EHCY program is again being considered as part of future ESEA 

reauthorization, according to Education officials. Education officials said that clearance 

from the Office of Management and Budget would be needed before they can require 

states to update their state plans.
 

Page 38 GAO-14-465 Education of Homeless Students

updated their plans with new activities and goals.75 Some states have 

implemented programmatic changes since the plans were initially 

required in 2002. For example, one state we visited changed its service 

delivery model in recent years by adopting a regional approach to award 

grants to lead school districts that are responsible for providing services 

to other districts in their region. This state’s EHCY coordinator confirmed 

that the state has not submitted any state plan updates to Education 

since 2002. However, because Education is no longer consistently 

monitoring all states for compliance, the agency is also unable to 

determine whether states’ current practices are consistent with their 

existing state plan. GAO’s Standards for Internal Control in the Federal 

Government suggest that management continually assess and evaluate 

whether internal control activities—such as reviewing and monitoring 

compliance with state plans—are effective and up-to-date.76

The McKinney-Vento Act requires each state to describe in its plan how it 

will ensure that all school districts comply with EHCY program 

requirements, but does not specify how states must monitor compliance 

or where they should focus their efforts.77 NCHE’s guidance78

 

75Education is currently developing a template that will allow states to voluntarily update 

their state plans online, according to officials; however, they said this website is unlikely to 

be completed before next year.

to states on 

monitoring districts acknowledges the challenge of monitoring all districts 

on site annually—given resource constraints—and recommends that 

states utilize a combination of strategies, such as on-site monitoring for 

grantee districts and desk monitoring, i.e., phone calls or written 

correspondence, for non-grantee districts. According to Education’s 

survey of states in school year 2010-11, states use a variety of 

approaches in monitoring districts. Most states (43 out of 50) monitored 

grantees on-site and about half (26 out of 50) did so for non-grantees. 

States also commonly use desk monitoring, with about two-thirds (34 out 

of 50) using this approach for grantees and about half (26 out of 50) doing 

so for non-grantees (see table 3).

76See GAO/AIMD-00-21.3.1. 

7742 U.S.C. § 11432(g)(2)(A).

78NCHE has developed various resources which are available to assist state EHCY 

program coordinators ensure their monitoring efforts are effective, for example a state 

coordinator’s handbook for monitoring. 

Education Survey Data 

and GAO’s Review 

Showed that States 

Generally Focused Their 

Monitoring on Grantee 

Districts and Not NonGrantee Districts
 

Page 39 GAO-14-465 Education of Homeless Students

Table 3: Number of States Using Various Approaches to Monitor Districts, School 

Year 2010-11

Monitoring approaches

Grantee 

districts 

Non-grantee 

districts 

Efforts are monitored through visits to local school districts 43 26

Assurances of compliance with regulations are required 41 25

Efforts are monitored through phone calls or written 

correspondence (i.e., desk monitoring) 34 26

Efforts are monitored by integrated monitoring visits to school 

districts that address this and other federal or state programs 33 29

Progress reports are required 23 5 

Progress reports are requested 13 6 

Efforts are not monitored 0 2 

Source: GAO analysis of Education’s survey of states. | GAO-14-465

Note: These results are based on a survey of 50 states.

The majority of states in Education’s survey also reported including the 

EHCY program in the state’s monitoring of other federal programs for 

both grantee districts (33 out of 50) and non-grantee districts (29 out of 

50).79

States focused their monitoring on districts that had received an EHCY 

grant from the state, resulting in limited oversight of many non-grantee 

districts. NCHE’s guidance indicates that states should monitor grantees 

at least once during the grant cycle—which can be up to 3 years—and 

non-grantees at least once every 3-to-5 years.

States that monitor compliance for the EHCY program in this way 

are able to reach additional districts without adding to the state EHCY 

program coordinator’s responsibilities, one of a few strategies that NCHE 

recommends to cover a large number of districts. For example, in one 

state we visited, a review team monitors about 100 school districts per 

year with a lengthy checklist for federal programs that includes the EHCY 

program.

80

 

79However, the survey data do not show whether this monitoring addresses all aspects of 

the EHCY program or if it just asks about financial elements related to the EHCY program, 

which is the case for two of the four states we reviewed. 

According to Education’s 

80U.S. Department of Education, National Center for Homeless Education, State 

Coordinator’s Handbook for LEA Monitoring (Fall 2006), State Coordinators’ Handbook

(December 2010), and A Guide to Meeting Compliance Requirements for the McKinneyVento Program (December 2011). 
 

Page 40 GAO-14-465 Education of Homeless Students

survey, most states (39 out of the 46 that responded to this question) said 

that they monitor grantees at least once every 2 years. Half (23 out of 46) 

of the states that responded to this question reported monitoring nongrantees at least once every 2 years and the other half reported 

monitoring them less frequently (see fig. 10). Additionally, 2 of 50 states 

reported that they did not monitor non-grantees at all (see table 3). 

Figure 10: Frequency of State Monitoring of Grantee and Non-grantee Districts, by 

Number of States, School Year 2010-11

Note: 46 out of the 50 states surveyed responded to this survey question.

Similarly, state EHCY program coordinators in three of the four states we 

reviewed focused on monitoring grantees and employed a variety of 

approaches, according to our interviews with the coordinators. One state 

coordinator reported monitoring all grantee school districts on-site 

annually. Two state coordinators reported monitoring grantees annually 

using a combination of on-site visits and desk reviews, in which grantees 

are monitored via phone and email and must send data to the state for 

review. The fourth state coordinator we interviewed reported conducting 
 

Page 41 GAO-14-465 Education of Homeless Students

quarterly fiscal and program reviews in lieu of formal on-site or desk 

monitoring for all of the grantees since school year 2008-09.81

The four states we reviewed also varied with regard to how often they 

monitor non-grantees. State coordinators in two of the four states we 

reviewed regularly monitor all non-grantee districts within the 3 to 5 year 

timeframe NCHE suggests. One state coordinator reported monitoring 

non-grantees on a 3-year rotational basis. Another state coordinator uses 

desk monitoring for all non-grantees annually and also uses a risk-based 

approach to select non-grantees for on-site monitoring.82

States may not focus monitoring efforts on non-grantee districts because 

they lack tools to enforce compliance. One state coordinator explained 

that the state can record a finding of noncompliance, but because there is 

no direct fiscal action or penalty attached to it, the district may disregard 

it. Another state coordinator said she has to accept a district’s report of 

zero homeless students, even if she suspects that the district may be 

under-identifying them. In contrast, state coordinators we spoke with said 

that states can hold districts with EHCY grant funding more accountable 

because they have more direct leverage over them, in the form of the 

grant. According to Education’s survey of states, 3 of 39 states that 

responded to this question reported that they withheld funds from 

grantees that were out of compliance.

The other two 

state coordinators we interviewed do not regularly monitor non-grantees 

within the suggested timeframe; however, one of these states annually 

ensures that all districts have identified a homeless liaison.

Monitoring is a key management tool for states to ensure districts’ 

compliance with the McKinney-Vento Act and statewide accountability for 

administration of the federal grant. In the state that had not monitored its 

grantee districts on-site since school year 2008-09, we found that not all 

 

81According to the state coordinator in the state that had not monitored grantee districts 

on-site since school year 2008-09, the state educational agency will start to monitor 

grantee districts on-site at least once every 2 years, starting in April 2014.

82This state’s EHCY program coordinator reported annually reviewing each district’s data 

on homeless students and visiting those non-grantees with the highest risk of 

noncompliance based on several risk factors, such as fewer than expected homeless 

students identified given a district’s poverty rates; trends in under-identification; a high 

number of disputes with neighboring districts and/or complaints from parents; and the size 

of the district, with larger districts assumed to have a higher risk of noncompliance. 
 

Page 42 GAO-14-465 Education of Homeless Students

districts were aware of the availability of services through the regional 

structure adopted by the state. This state uses a regional approach for its 

grantee districts, whereby the grants are distributed to lead entities that 

are in turn responsible for ensuring that all homeless students within the 

region receive appropriate services. To do this, the grantee district may 

provide funds and/or services, such as training, to other districts in its 

region. While we met with two lead grantee school districts that provided 

services to other districts in the region, we also met with two other nongrantee districts whose officials were unaware that the district was eligible 

for funds or services from their respective lead grantee districts, indicating 

that the state’s regional model was not being implemented effectively. 

Such problems suggest inadequate state-level monitoring of school 

districts, reinforcing the importance of effective federal monitoring of 

states.

Education relies on annual state performance data collected from school 

districts to determine the extent to which states are meeting the 

program’s intended goal of ensuring that homeless students have access 

to a free appropriate public education (see table 4).83

Table 4: Required Data Elements from Grantee and Non-grantee School Districts

Grantee 

districts 

Non-grantee 

districts 

Number of homeless students enrolleda √ √ 

Number of homeless students servedb √ 

Subgroups of homeless students enrolled (unaccompanied 

youth, migratory children and youth, children with disabilities, 

and Limited English Proficient students)

√ √ 

Subgroups of homeless students served √ 

 

83The McKinney-Vento Act requires Education to collect and disseminate certain 

information regarding homeless children and youth. 42 U.S.C. § 11434(h). Education is 

required to determine, based on information it collects and information provided by states, 

the extent to which state educational agencies are ensuring that each homeless child and 

homeless youth has access to a free appropriate public education. 42 U.S.C. § 11434(f). 

According to Education, states report data through two methods—on an ongoing basis 

through its EDFacts database and through the Consolidated State Performance Report, 

which states must certify annually. The National Center for Homeless Education releases 

these data in a data collection summary for the EHCY program on an annual basis.

Education Collects 

Performance Data but 

Faces Limitations in Using 

Them to Assess Program 

Results
 

Page 43 GAO-14-465 Education of Homeless Students

Grantee 

districts 

Non-grantee 

districts 

Primary nighttime residence by category (sheltered, 

unsheltered, hotels/motels, and doubled up)

√ √ 

Academic achievement of homeless students enrolled 

(reading, mathematics, science)c √ √ 

Source: Education’s Consolidated State Performance Report Federal Data Collection Guide for State Coordinators of Homeless 

Education School Year 2012-2013. | GAO-14-465

a

Under the McKinney-Vento Act, students are enrolled if they are “attending classes and participating 

fully in school activities.” 42 U.S.C. § 11434a(1). According to Education, for data collection purposes, 

an enrolled student includes any child for whom a current enrollment record exists. Children aged 3 

through 5 (not kindergarten) includes any preschool-aged (3 through 5) homeless child who is 

enrolled in a school district-administered preschool program. Children to be included may be 

attending at a specific location or participating in a home-based program.

b

For data collection purposes, the definition of served includes homeless children who have been 

served in any way through McKinney-Vento grant-funded staff or activities. This definition includes 

children aged birth through 5 years old who are served by the grant program, regardless of whether 

or not they are enrolled in a preschool program operated by a school district, or in a preschool 

program where the school district is a partner administratively or financially, or has any accountability 

in serving the children. It is possible for a child to be served in a district, but not enrolled in that 

district.

c

Academic achievement refers to the number of students taking assessment exams and the 

percentage of students taking the exam that met or exceeded state proficiency standards.

Education has increased the number of data elements it requires school 

districts, particularly non-grantee districts, to report in the Consolidated 

State Performance Report. For example, in school year 2010-11, 

Education began requiring states to report information on the academic

achievement of homeless students in reading and mathematics from nongrantee school districts, data that had been required from grantee districts 

since at least the 2004-05 school year.84 In school year 2011-12, 

Education added corresponding data elements in science for all districts

to the Consolidated State Performance Report. In school year 2012-13, 

Education began requiring states to report information on the number of 

homeless students enrolled in each district, by certain subcategories.85

 

84These data included the number and percentage of homeless students who were 

enrolled in school and assessed in reading and math and the percent of these students 

who achieved proficiency levels. 

Previously, Education had only required states to report this information 

by subcategory for grantee districts; for non-grantee districts, states were 

85The subcategories of homeless children and youth are (1) unaccompanied homeless 

youth, (2) migratory children and youth, (3) children with disabilities, and (4) Limited 

English Proficient students.
 

Page 44 GAO-14-465 Education of Homeless Students

only required to report the total number of homeless students enrolled 

and their primary nighttime residence.

Education presents trends in data on homeless students over time in its 

Consolidated State Performance Report;86

 

86As of March 2014, Education was not able to calculate percentage changes in 

enrollment and nighttime residence data from year to year due to a recent change in how 

it produced these data, but anticipated being able to do so in future years. Beginning in 

school year 2011‐12, Education required states to identify which districts received grants 

and which did not. As a result, Education was able to report enrollment and primary 

nighttime residence data by grantees and non-grantees using school district-level data, 

instead of state-level data. However, because homeless students frequently move from 

district to district, it is possible that the same student would be reported by multiple 

districts in a state in the school district-level data. Consequently, increases in enrollment 

data from year to year may be a result of this duplication as well as to an actual increase 

in the number of homeless students. See U.S. Department of Education, National Center 

for Homeless Education, Education for Homeless Children and Youths Program Data 

Collection Summary (March 2014).

however, there are limitations 

to the use of state-reported data to assess the program’s results. For 

example, the state data on the number of homeless students are likely 

incomplete or unreliable due in part to the under-identification of eligible 

students. In Education’s survey of states, 13 of the 25 states that 

responded to this question had found that at least one grantee was not in 

compliance with the statutory requirement to identify homeless children 

and youth. In one of the four states we reviewed, Education found the 

data on the number of homeless students to be unreliable, which the 

state EHCY program coordinator attributed to a 2009-10 transition to a 

new, state-wide database system that led to undercounting homeless 

students. Both Education and the state educational agency are taking 

steps to address the state’s data quality issues, according to officials from 

both agencies. Education officials told us that the under-representation of 

the number of homeless students in the data generally is an area of 

concern, which they are addressing in multiple ways. In addition to 

questioning states about this issue, an Education official said the agency 

has worked with a contractor who analyzed school district-level data in 

every state to help identify school districts that may have been underidentifying homeless students by comparing their rate of homeless 

student identification to the percentage of students receiving free or 

reduced-price lunch. The contractor has made presentations on the 

results of this analysis to state EHCY program coordinators, and 

Education plans to provide state EHCY program coordinators with 

additional technical assistance on outreach and identification.
 

Page 45 GAO-14-465 Education of Homeless Students

Another limitation to the use of state-reported data is that, by design, the 

data are difficult to compare across states. As GAO has previously 

reported, states vary in how they measure student academic 

achievement, as permitted by ESEA, to allow states to address their 

unique circumstances.87 Education has acknowledged this inherent 

limitation, as well as challenges in comparing data within states over time, 

as many states have made changes to their state assessments that can 

impact comparability.

88 According to the Common Core State Standards 

Initiative, a voluntary state-led initiative, 43 states and the District of 

Columbia have chosen to adopt the Common Core State Standards—

designed to define the knowledge and skills students should gain 

throughout their K-12 education in order to graduate high school prepared 

to succeed in entry-level careers, introductory academic college courses, 

and workforce training programs. Most states have chosen to participate 

in one of two state-led consortia working to develop assessments based 

on these standards, expected to be available in school year 2014-15, 

which may lead to greater comparability across states. Similarly, 

according to agency officials, Education collects dropout and graduation 

rate data, including disaggregated data for homeless students, but these 

data are calculated differently in different states—making comparisons 

across states problematic.

89

 

87GAO, No Child Left Behind Act: Improvements Needed in Education’s Process for 

Tracking States’ Implementation of Key Provisions, 

GAO has previously reported on the use of 

different state graduation rates, and recommended that Education provide 

information to all states on ways to account for different types of students 

GAO-04-734 (Washington, D.C.: Sept. 

30, 2004).

88Academic achievement data may be particularly unreliable for homeless students, who 

tend to move frequently and often have erratic school attendance, increasing the 

likelihood that they will miss taking the academic achievement exams, which are typically 

given only once during high school. 

89In addition, school districts have difficulty tracking students who leave school because 

they do not know whether a student has dropped out of school or is enrolled in another 

school district, undermining the reliability of the dropout data. Our previous work found 

that student mobility was the primary factor affecting the accuracy of graduation rates; 

students who come and go make it difficult to keep accurate records. See GAO, No Child 

Left Behind Act: Education Could Do More to Help States Better Define Graduation Rates 

and Improve Knowledge About Intervention Strategies, GAO-05-879 (Washington, D.C.: 

Sept. 20, 2005).
 

Page 46 GAO-14-465 Education of Homeless Students

in graduation rate calculations and assess the reliability of state data used 

to calculate interim rates, which it did.90

Aside from its annual data collection efforts, Education’s latest study 

(forthcoming in 2014), which covers school year 2010-11, will provide 

some valuable information on program implementation, according to 

agency officials. The study collects information from surveys of state 

EHCY program coordinators and grantee school district homeless liaisons 

on topics such as their EHCY-related responsibilities; data collection and 

use; collaboration with other programs and service providers; barriers 

homeless students face to enrolling, attending, and succeeding in 

schools; and state monitoring of districts’ compliance with the McKinneyVento Act, among other topics.91

The EHCY program, funded at about $65 million for fiscal year 2014, is 

intended to remove barriers to educational achievement for homeless 

students and provide them with access to critical services—such as 

transportation to school and referrals for health care. Such services are 

important to help mitigate the range of negative effects experienced by 

homeless children and youth across an array of measures, including 

academic achievement and school graduation rates. The program 

identified more than 1.1 million homeless students in school year 2011-

12—students who, had they not been identified, might have faced greater 

difficulties succeeding in school and preparing to graduate. To increase 

the program’s effectiveness, school districts, states, and the federal 

government leverage existing resources to ensure that homeless 

students are identified and their various academic and non-academic 

needs are met. The EHCY program promotes efforts to leverage 

resources, in part, by requiring coordination and collaboration among 

various programs and service providers that also serve homeless 

students. Collaboration can be particularly important for districts and 

communities addressing significant increases in homelessness following 

natural disasters.

 

90See GAO-05-879. According to agency officials, Education requires states and school 

districts to report a standard 4-year adjusted cohort graduation rate for all students. This 

rate is comparable across states, but it is not disaggregated for homeless students. 

91Education had initially intended to survey both grantee and non-grantee school districts 

but found that the variation in how states implement the program prevented doing so.

Conclusions
 

Page 47 GAO-14-465 Education of Homeless Students

Appropriately identifying eligible students, in collaboration with other 

providers, is key to ensuring that districts provide homeless students with 

the services they need. However, challenges districts face in identifying 

students coupled with potential financial disincentives to identify them due 

to the cost of providing them with services such as transportation, can 

lead to under-identification, which has several consequences. First, it can 

result in barriers to homeless students’ educational stability and 

achievement. Homeless children and youth who are not identified may 

have difficulty getting to and from their school as their nighttime residence 

changes and may therefore be derailed in their attempts to obtain an 

education without the assistance available through the EHCY program. 

Second, under-identification complicates Education’s ability to fully 

assess program results due to concerns about the accuracy and 

completeness of the data, which it has taken some steps to address. 

Similarly, under-identification complicates the ability of the U.S. 

Interagency Council on Homelessness to accurately assess progress 

toward its goal of ending homelessness for families, youth, and children 

by 2020.

While it may not be possible to accurately determine the extent to which 

districts may be under-identifying students—and the extent to which these 

children and youth may not succeed academically— monitoring states 

and school districts is imperative to ensure compliance with the 

requirements of the McKinney-Vento Act, particularly in light of the fact 

that some states are implementing the program differently than described 

in their state plans. Without monitoring states through regular reviews of 

state programs and implementation plans, Education will not have the 

information it needs to determine whether states are meeting 

requirements that help provide eligible students with the resources 

needed to pursue an education.

To help ensure state compliance with the McKinney-Vento Act, Education 

should develop a monitoring plan to ensure adequate oversight of the 

EHCY program. This plan could, for example, determine a schedule of 

states to be monitored and incorporate procedures to assess whether 

states need to update their state plans.

We provided a draft of this report to the Departments of Education, HHS, 

and HUD and to USICH for review and comment. Education and USICH 

provided formal comments that are reproduced in appendices III and IV.

Recommendation for 

Agency Action

Agency Comments 

and Our Evaluation
 

Page 48 GAO-14-465 Education of Homeless Students

Education, HHS, HUD, and USICH also provided technical comments, 

which we incorporated as appropriate. 

Education agreed that sufficient oversight of EHCY program requirements 

at the federal, state, and local levels is necessary and that both interagency and cross-program collaboration is essential to ensure that the 

needs of homeless children and youth are addressed. Education noted 

that although not all state EHCY programs have been monitored in recent 

years, the department has continued to conduct risk assessments for all 

states and to provide technical assistance to states and school districts 

through the EHCY program office and NCHE. 

Education concurred with our recommendation that, in order to ensure 

compliance with the McKinney-Vento Act, the department should develop 

a monitoring plan to ensure adequate oversight of the EHCY program. 

Education said that it is currently developing a plan for monitoring for 

fiscal year 2015 and will increase monitoring for the EHCY program, 

ensuring that all states identified as “higher risk” in its next round of risk 

assessments are monitored through document reviews, on-site and 

remote interviews with state and local educational agency personnel. We 

encourage Education to continue to consider the length of time since a 

state was last monitored in its determination of risk and to consider 

developing a monitoring schedule to help ensure that it has the 

information it needs to determine whether all states are meeting EHCY 

program requirements. Education also said that it is making changes to 

its monitoring protocol, adding questions related to student academic 

achievement and potential under-identification of homeless students. We 

support Education’s decision to increase its EHCY program monitoring 

and believe focusing additional attention on the issue of underidentification is particularly important. Without a fuller sense of the extent 

of under-identification, it is difficult for Education to gauge program 

results. Lastly, Education indicated that it plans to include the 

development of a secure website through which states can update their 

state plans in its next technical assistance contract. Since states may 

have changed the way they implement the EHCY program since their 

state plans were originally developed, we encourage Education to take 

steps to ensure that states that need to update their plans do so. 

USICH agreed that monitoring EHCY grantees is important to ensure 

homeless children and youth are identified. USICH also noted the 

important role that Education can play in fostering best practices, 

strategic partnerships, and innovation to address the needs of homeless 

students. USICH stated that it considers Education and the EHCY 
 

Page 49 GAO-14-465 Education of Homeless Students

program to be critical partners in developing and advancing the work of 

USICH’s goal of ending homelessness among families, children, and 

youth by 2020.

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

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

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

Secretaries of Education, HHS, and HUD, the Executive Director of 

USICH, relevant congressional committees, and other interested parties. 

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

Web site at http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512- 7215 or Brownke@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix V.

Kay E. Brown, Director

Education, Workforce, and Income Security Issues
Appendix I: Scope and Methodology

Page 50 GAO-14-465 Education of Homeless Students

We used several approaches to obtain information on how school 

districts, states, and the Department of Education (Education) implement 

and oversee the Education for Homeless Children and Youth (EHCY) 

program. To gather information on how the EHCY program is 

implemented at the local level, we visited three states—Colorado, New 

Jersey, and Washington State—and conducted interviews with a fourth 

state, Texas, by phone. We selected states that represent geographic 

diversity and were identified by experts, including the National 

Association for the Education of Homeless Children and Youth 

(NAEHCY) and other national organizations working on issues related to 

homelessness, for their experiences in providing education to homeless 

students. We identified these organizations during the course of our 

background research. We also considered the number of homeless 

students states identified in recent years, including any trends, the level of 

program funding states received, and the delivery structure of early 

childhood education programs in the state. In addition, we selected states 

that experienced surges in homelessness due to recent natural 

disasters—including wildfires, flooding, and a hurricane. Together, these 

states included about 13 percent of identified homeless students 

nationwide in school year 2011-12. In each state, we interviewed state 

officials to obtain information on how they collaborate with other agencies, 

service providers, and school districts, as well as their monitoring 

practices. We also met with school district officials. In all, we spoke with 

representatives from 20 school districts in the four states. We selected 

school districts, with assistance from state EHCY program coordinators, 

to represent a mix of urban, suburban, and rural districts, as well as 

districts that received EHCY program funds (grantees) and those that did 

not (non-grantees). In one state, we also met with representatives of two 

regional educational entities that are responsible for providing EHCYrelated services to several school districts within their respective regions 

and receive EHCY program funds to do so. In the states we visited, we 

also met with school officials at the elementary, middle, and high school 

levels, and youth that have experienced homelessness, or their families, 

about their educational experiences (12 youth and three families). 

Information obtained from these states, school districts, youth, and 

families is non-generalizable. We also attended the 2012 NAEHCY 

Conference to obtain further insights into how school districts were 

implementing the EHCY program and met with five additional state 

coordinators at that conference to discuss how they collaborated with 

various stakeholders.

To obtain generalizable and national-level information from states and 

grantee school districts, we analyzed Education data from two surveys 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 51 GAO-14-465 Education of Homeless Students

covering school year 2010-11. Education’s surveys collected information 

on services school districts provided to homeless children and youth; 

state and local collaboration efforts with other Education programs; and 

how states monitored school districts, including any differences in 

monitoring among grantee and non-grantee districts. A total of 448 school 

districts were included in the district-level survey sample, including the 50 

largest school districts and a random sample of 401 other school districts 

(3 districts were removed from the sample after the survey was released 

because they had merged with other districts). The surveys were 

conducted electronically, however, in a small number of cases (7 or 8) 

districts that did not initially respond to the electronic survey were 

administered the survey over the phone or on paper. The school districtlevel survey had a weighted response rate of 86 percent (96 percent for 

the 50 largest districts and 85 percent for the remaining 398 districts).1

To obtain information on how Education administers the EHCY program, 

we interviewed Education officials about how the agency monitors states 

for compliance and collaborates with other federal programs. We also 

interviewed officials from other federal agencies, including the 

Departments of Health and Human Services (HHS) and Housing and 

Urban Development (HUD), as well as the U.S. Interagency Council on 

The state survey was sent to all 50 states, the District of Columbia, and 

the Bureau of Indian Affairs. The Bureau of Indian Affairs did not respond 

and was later removed from the scope of the survey. One additional state 

provided incomplete survey answers, leaving 49 states and the District of 

Columbia as the state survey population. We assessed the reliability of 

Education’s survey data by performing electronic testing of the data 

elements, reviewing relevant documentation, and interviewing agency 

officials knowledgeable about the data. We found that the data were 

sufficiently reliable for the purposes of this report. The responses of each 

eligible sample member who provided a useable questionnaire were 

weighted in the analyses to account statistically for all members of the 

population. We created weights for each survey respondent to account for 

unequal probabilities of selection and various unit response rates among 

the survey strata. All estimates obtained from the school district-level 

survey have margins of error of no greater than six percentage points.

 

1

To determine the weighted response rate, we used the response rate definition “RR3,” as 

defined by the American Association for Public Opinion Research in “Standard Definitions: 

Final Dispositions of Case Codes and Outcome Rates for Surveys,” (Revised 2011). RR3 

estimates the proportion of cases of unknown eligibility that are, in fact, eligible. 
Appendix I: Scope and Methodology

Page 52 GAO-14-465 Education of Homeless Students

Homelessness (USICH), to obtain their perspectives on collaborating with 

Education on programs that serve homeless children and youth. We also 

interviewed Education officials about the agency’s monitoring efforts. 

Additionally, we reviewed relevant documents—including federal laws 

and regulations, monitoring protocols, and policy memos—and examined 

Education’s findings on homeless education from state monitoring 

reports.

We conducted this performance audit from July 2012 through July 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Education for Homeless Children

and Youth Program Monitoring Indicators

Page 53 GAO-14-465 Education of Homeless Students

Federal monitoring indicator Selected examples of acceptable evidence that states provide

1.1: The state conducts monitoring and evaluation of school 

districts with and without subgrants, sufficient to ensure 

compliance with McKinney-Vento program requirements.

Written procedure for monitoring school districts with and without 

subgrants to include:

• Recent copy of monitoring policies and procedures, schedules for 

current and previous school years.

• Sample notification letters to school districts, preparation 

checklists, or other forms.

• A copy of the interview protocol for school district reviews.

• Most recent copies of reports, recommendations and follow-up to 

corrective actions.

2.1: The state implements procedures to address the 

identification, enrollment and retention of homeless students 

through coordinating and collaborating with other program 

offices and state agencies.

Written communication to school districts updating state policies and 

procedures that address the problems homeless children and youth 

face in school enrollment and retention since the last Department of 

Education program review.

Updates to the state plan, including the completion of planned activities 

and proposals for new state-level activities.

2.2: The state provides, or provides for, technical assistance 

to school districts to ensure appropriate implementation of 

the statute.

Copies of written guidance to school districts and/or information 

dissemination materials distributed electronically or by other means.

The most recent liaison orientation, on-line trainings, conferences, and 

regional training agendas and technical assistant log.

3.1 The state ensures that school district subgrant plans for 

services to eligible homeless students meet all 

requirements.

Evidence that the state has an application and approval process to 

provide competitive subgrants to school districts.

3.2: The state complies with the statutory and other 

regulatory requirements governing the reservation of funds 

for state-level coordination activities.

State budget detail on reserved funds for state-level coordination 

activities for the current fiscal year and use of funds for the last fiscal 

year.

3.3: The state has a system for ensuring the prompt 

resolution of disputes.

Updated state dispute resolution policy and procedures including:

• procedures for tracking disputes

• documents indicating that dispute procedures have been 

implemented

• records indicating that disputes are addressed, investigated and 

resolved in a timely manner

Evidence that the state tracks if school districts have a dispute 

resolution policy in place.

Source: Department of Education. | GAO-14-465

Appendix II: Education for Homeless 

Children and Youth Program Monitoring 

Indicators
Appendix III: Comments from the Department 

of Education

Page 54 GAO-14-465 Education of Homeless Students

Appendix III: Comments from the 

Department of Education
Appendix III: Comments from the Department 

of Education

Page 55 GAO-14-465 Education of Homeless Students
Appendix IV: Comments from the U.S. 

Interagency Council on Homelessness

Page 56 GAO-14-465 Education of Homeless Students

Appendix IV: Comments from the U.S. 

Interagency Council on Homelessness
Appendix IV: Comments from the U.S. 

Interagency Council on Homelessness

Page 57 GAO-14-465 Education of Homeless Students
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 58 GAO-14-465 Education of Homeless Students

Kay E. Brown, (202) 512-7215 or brownke@gao.gov

In addition to the contact named above, Kathryn Larin (Assistant 

Director), Avani Locke (Analyst-in-Charge), David Barish, and Jennifer 

Cook made key contributions to this report. Also contributing to this report 

were Alicia Cackley, Sarah Cornetto, Keira Dembowski, Justin Fisher, 

Hedieh Fusfield, Jessica Gray, Thomas James, Jean McSween, Mimi 

Nguyen, Paul Schmidt, Almeta Spencer, Kathleen van Gelder, and Amber 

Yancey-Carroll.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 59 GAO-14-465 Education of Homeless Students

Managing for Results: Implementation Approaches Used to Enhance 

Collaboration in Interagency Groups. GAO-14-220. Washington, D.C.: 

February 14, 2014.

Homelessness: Fragmentation and Overlap in Programs Highlight the 

Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491. 

Washington, D.C.: May 10, 2012.

Homelessness: To Improve Data and Programs, Agencies Have Taken 

Steps to Develop a Common Vocabulary. GAO-12-302T. Washington, 

D.C.: December 15, 2011.

K-12 Education: Many Challenges Arise in Educating Students Who 

Change Schools Frequently. GAO-11-40. Washington, D.C.: November 

18, 2010.

Homelessness: A Common Vocabulary Could Help Agencies Collaborate 

and Collect More Consistent Data. GAO-10-702. Washington, D.C.: June 

30, 2010.

Runaway and Homeless Youth Grants: Improvements Needed in the 

Grant Award Process. GAO-10-335. Washington, D.C.: May 10, 2010.

Disconnected Youth: Federal Action Could Address Some of the 

Challenges Faced by Local Programs That Reconnect Youth to 

Education and Employment.GAO-08-313. Washington, D.C.: February 

28, 2008.

Related GAO Products

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