U . S . D E P A R T M E N T O F E D U C A T I O N

Evaluation of Flexibility Under No Child Left Behind:

Volume IV—The Local Flex Demonstration 

Program in Seattle Public Schools
Evaluation of No Child Left Behind Flexibility Provisions: 

Volume IV—The Local Flex Demonstration Program in 

Seattle Public Schools 

Prepared by: 

Gayle S. Christensen 

Kathleen Feehan 

Daniel Loss 

The Urban Institute 

Washington, D.C. 

Prepared for: 

U.S. Department of Education 

Office of Planning, Evaluation and Policy Development 

Policy and Program Studies Service 

2007
This report was prepared for the U.S. Department of Education under Contract Number 

ED01CO0080002 with the Urban Institute. Margery Yeager served as the contracting officer’s 

representative. The views expressed herein do not necessarily represent the positions or policies 

of the Department of Education. No official endorsement by the U.S. Department of Education 

is intended or should be inferred. 

U.S. Department of Education 

Margaret Spellings 

Secretary 

Office of Planning, Evaluation and Policy Development 

Doug Mesecar 

Acting Assistant Secretary

Policy and Program Studies Service 

Alan Ginsburg 

Director 

Program and Analytic Studies Division 

David Goodwin 

Director 

July 2007 

This report is in the public domain. Authorization to reproduce it in whole or in part is granted. 

While permission to reprint this publication is not necessary, the suggested citation is: U.S. 

Department of Education, Office of Planning, Evaluation and Policy Development, Policy and 

Program Studies Service, Evaluation of No Child Left Behind Flexibility Provisions: Volume 

IV—The Local Flex Demonstration Program in Seattle Public Schools, Washington, D.C., 2007. 

This report is available on the Department’s Web site: 

http://www.ed.gov/about/offices/list/opepd/ppss/index.html 

On request, this publication is available in alternate formats, such as Braille, large print, or 

computer diskette. For more information, please contact the Department’s Alternate Format 

Center at (202) 260-0852 or (202) 260-0818.
iii

Contents 

Exhibits ......................................................................................................................................... iv 

Executive Summary...................................................................................................................... v 

1. Introduction.......................................................................................................................... 1 

The State Flex and Local Flex Demonstrations.............................................................................. 1 

Challenges to Participation ............................................................................................................. 2 

2. Methodological Design ........................................................................................................ 5 

Sampling Procedures ...................................................................................................................... 5 

Interview Protocol........................................................................................................................... 5 

3. Results................................................................................................................................... 7 

Background on Seattle Public Schools’ Participation in Local Flex .............................................. 7 

Application Process for Local Flex........................................................................................ 8 

Plans for Local Flex............................................................................................................... 9 

Targeting Federal Funds to Meet Students’ Needs Through the Use of Local Flex .................... 12 

New Possibilities for Planning............................................................................................. 13 

Tracking Progress and Accountability................................................................................. 15 

New Initiatives and Actions.......................................................................................................... 16 

District Management and Relationships with Schools Since Local Flex ..................................... 18 

Changes in Leadership Roles and Responsibilities ............................................................. 18 

Changes in Accounting........................................................................................................ 19

District’s Relationship with Public Schools ........................................................................ 20 

District’s Relationship with Private Schools ....................................................................... 22 

District’s Relationship with the State .................................................................................. 23 

Balancing Flexibility With the Intent of Federal Programs.......................................................... 25 

4. Conclusions......................................................................................................................... 27 

Summary of Findings.................................................................................................................... 27 

Benefits and Challenges for Seattle Public Schools ..................................................................... 27 

Benefits ................................................................................................................................ 27 

Challenges and Untapped Potential of Local Flex............................................................... 29 

Concluding Thoughts.................................................................................................................... 30 

Appendix A: Interview Instruments ......................................................................................... 31 
iv

Exhibits 

Exhibit 1 Overview of Seattle Public School District: 2005–06 School Year .......................... 7 

Exhibit 2 Seattle School District: Federal Allocations by Program and School Year............... 9 

Exhibit 3 Seattle School District: Local Flexibility Plan Overview 2004, 2005, and 2006.... 11 
v

Executive Summary 

Flexibility and accountability are two levers for change that occupy an increasingly prominent 

place among federal strategies for educational improvement. In return for introducing higher 

academic standards and performance-based accountability systems, states and districts have been 

granted increasing flexibility over how they may use the funding they receive from federal 

sources. The basic premise underlying this exchange of flexibility for accountability is that local 

educators and administrators are in the best position to identify student needs and that these 

needs can best be met if local actors are given greater flexibility over the use of federal 

resources, while meeting high standards for academic performance. Although flexibility has 

been an important element of educational policy for at least the past decade, the 2001 

reauthorization of the Elementary and Secondary Education Act (ESEA), also known as the No 

Child Left Behind Act of 2001 (NCLB), marks an important milestone in the evolution of this 

improvement strategy. 

All states and districts may now avail themselves of a variety of mechanisms for exercising 

flexibility over the use of certain federal dollars. Flexibility options that are either new under 

NCLB or extended from previous authorizations of ESEA include: State Flex, Local Flex, 

Transferability, Title I Schoolwide Programs, Waivers, Ed Flex, Consolidated Applications, 

Consolidation of Administrative Funds, and an initiative designed for rural school districts. In 

many ways, the most ambitious example of the way in which flexibility and accountability are 

brought together can be found in the State Flex and Local Flex demonstration programs included 

in NCLB. These competitive programs grant a selected group of participating states and districts 

enhanced flexibility authority to consolidate a potentially large pool of funds from a set of 

eligible federal programs. These consolidated funds may be employed for a variety of different 

educational objectives consistent with the broadly defined purposes of ESEA in order to help 

these participants meet specified goals under the state’s definition for adequate yearly progress 

(AYP). Both State Flex and Local Flex require the identification of educational priorities and the 

development of strategies to address these needs in a formal five-year educational improvement 

plan. Districts that fail to make AYP in two consecutive years become ineligible for Local Flex. 

The number of agencies entering into the initial round of State Flex and Local Flex competitions 

was quite small. Though the statute authorized up to seven states to receive State Flex authority, 

only Florida initially applied for and was approved to participate in State Flex but has since 

withdrawn from the demonstration program. Similarly, up to 80 local education agencies could 

qualify for Local Flex authority, but only the Seattle Public Schools submitted a full application 

for the Local Flex competition. In order to inform and assist other districts that might consider 

participating in the Local Flex program, the U.S. Department of Education commissioned this 

case study of the Seattle experience to examine benefits, challenges, and implementation 

strategies. 

This report is based on interviews conducted with various stakeholders involved in Seattle Public 

Schools’ implementation of Local Flex, including representatives from the Seattle Public 

Schools and the Washington State Office of Superintendent of Public Instruction. In addition, 

administrators from both public and private schools in the Seattle Public School District were 

interviewed. The interviews were conducted on Nov. 30 and Dec. 1, 2005. 
vi

The study examines the following research questions: 

• Did Local Flex allow the district to better target federal funds to meet students’ needs? 

 

• Did Local Flex facilitate initiatives or programs that the district has specified in its 

five-year plan? 

• Since implementing Local Flex, what changes have occurred in district accounting, 

management roles and responsibilities, and the district’s relationships with private and 

public schools? 

• How has the district balanced the needs and requirements of flexibility while ensuring 

that the intent of federal programs included in the agreement is met? 

Key Findings 

While the Seattle Public School District is still in the process of fully implementing Local Flex, 

the initiative has already changed the way the district focused on strategic planning, helped to 

deploy resources to the schools and students most in need through expanded programs, and 

ushered in greater collaboration in the district office and with private schools. 

By focusing on five major themes through Local Flex, Seattle Public Schools better targeted 

federal funds to meet students’ needs. 

Local Flex created new possibilities for effectively reaching the district’s goals and allowing 

Seattle Public Schools to think strategically about student needs through the lens of its 

preexisting five-year plan. As part of the agreement, Seattle Public Schools committed to using 

consolidated funds to address five specific areas for improvement: 

• Teacher knowledge, rigor and skill in the application of research-based practices and 

strategies for mathematics, literacy content and pedagogy. 

• Teacher knowledge and skill in standards-based, culturally responsive teaching and 

learning, differentiation of instruction, and the use of data to inform instruction. 

• Beginning teacher quality and preparation for service to underserved students of diverse 

backgrounds. 

• Integration of technology in the classroom for teacher productivity and teaching and 

learning programs. 

• Intervention and support services for academic achievement, reentry and substance abuse 

issues for targeted student populations. 
vii

Local Flex facilitated these efforts by allowing Seattle Public Schools to reallocate funds and 

rapidly respond to changing district needs while continuing to provide funds to issues related to 

each of the eligible programs. Seattle Public Schools used Local Flex to meet students’ needs 

through planning and accountability measures, tracking progress, and employing new 

initiatives. 

• District representatives noted that Local Flex gave Seattle Public Schools the opportunity 

to think about federal dollars differently, which aided planning for both the district’s 

long-term and short-term goals. New accountability measures, along with required 

tracking of progress in the Local Flex agreements, meant that the district could carefully 

target students and provide them with additional services. 

• Local Flex encouraged collaboration across federal program areas and departments, and 

allowed the district to address student needs despite changes in the state’s accountability 

system by enlisting teacher coaching and mentoring. 

• Consolidated funding and identification of need by planning through Local Flex provided 

for targeted programs: The district focused Local Flex funds on new school-based 

literacy and mathematics coaches and expanding roles for teacher mentors.

While Local Flex ushered in improved collaboration within the district office and reduced 

administrative burdens, district representatives recognized that the district had not yet been 

able to take full advantage of the potential benefits the program offered. 

• Seattle Public Schools was the first district in the country to implement Local Flex, 

providing an important example of this demonstration program. The district has also 

undergone substantial staff changes and had only fully implemented the program for a 

year and a half at the time of the case study. This meant that the implementation of Local 

Flex was still a work in progress. District representatives indicated that they would be 

able to take advantage more fully of the new opportunities the program offered in the 

coming year by extending current programs made possible by Local Flex. 

• District representatives indicated that Local Flex, combined with a tight district budget, 

led to greater coordination among those responsible for federal funds and various 

departments. Representatives noted that it was difficult for the district to overcome the 

tradition of categorical programs but suggested that more coordination would be in place 

in the coming year. In addition, the district had not yet taken full advantage of the 

opportunity presented by Local Flex to integrate and streamline staffing responsibilities. 

• Some district officials reported that the consolidation of funds through Local Flex 

decreased administrative time and costs and allowed the district to focus on providing 

services. Overall, the district had a higher degree of freedom both in terms of planning 

and budgeting than it had prior to the implementation of Local Flex. 

• While Local Flex provided Seattle Public Schools with more flexibility than other 

flexibility options such as Transferability, some respondents felt that Local Flex left most 
viii

federal dollars locked into more restrictive programs and did not allow more meaningful 

flexibility because it did not allow for consolidation of Title I funds. 

Seattle Public Schools’ relationship with the state had remained similar while the district’s 

interaction with public and private schools improved since implementing the program. 

• In general, the state maintained a strong relationship with Seattle Public Schools and the 

district’s competent grants management team that required little technical assistance from 

the state. 

• Representatives from public schools indicated that they found Local Flex made a positive 

difference in the relationship between schools and the district by increasing the level of 

communication and improving services to students in need. Because Local Flex funding 

and programs were targeted to the most at-risk schools, schools identified as making 

adequate yearly progress experienced fewer of the benefits of Local Flex. 

• Because Local Flex agreements also benefit private school students and teachers by 

allowing the LEA to use the funds for any purpose under NCLB for benefits and services 

for private school students and teachers, private school representatives commented 

extensively on the improved communication with the district and other benefits 

associated with the district’s use of Local Flex including: 

o Increased ability to target funds to directly meet specific needs 

o Expedited distribution of funds for services and limited bureaucratic delays 

o Improved communication through simplified reporting procedures and a primary 

contact at the district office 

Respondents indicated that the district had been able to balance flexibility with the intent of 

federal programs. 

• The district took steps to guarantee that the intent of the federal programs continued to be 

met after the implementation of Local Flex. The funds made available for consolidation 

through Local Flex remained earmarked for particular programs although the district still 

retained the right to use them for other purposes. 

• While Local Flex required that the goals associated with the four programs still be met, 

there was potential for Seattle to use Local Flex money to fund other educational 

strategies beyond “Title boundaries” by pooling eligible funds, increasing collaboration, 

or creating new programs rather than simply extending current ones. Seattle Public 

Schools did not cross these boundaries and in turn, implementation of Local Flex never 

threatened the intent of the eligible programs. 
1

1. Introduction 

The State Flex and Local Flex Demonstrations1

Perhaps the most ambitious example of the way in which flexibility and accountability have been 

brought together can be found in the State Flex and Local Flex demonstration programs. 

Although no additional resources are provided to participating states and districts, the enhanced 

flexibility granted under State Flex and Local Flex allows participating agencies to consolidate a 

potentially large body of existing federal funds and to use those funds for any educational 

purpose authorized by the ESEA. In particular, these consolidated funds are intended to support 

activities that help districts and schools to make adequate yearly progress (AYP). Participants in 

the State Flex and Local Flex programs are afforded the opportunity to exercise even more 

extensive flexibility than offered in other NCLB flexibility programs over a set of funding 

categories similar to those eligible under Transferability. This report focuses specifically on 

Local Flex—100 percent of formula funds from the following four federal programs may be 

consolidated: Title II, Part A (Improving Teacher Quality State Grants); Title II, Part D 

(Educational Technology State Grants); Title IV, Part A (Safe and Drug-Free Schools and 

Communities); and Title V, Part A (State Grants for Innovative Programs). 

Several distinct forms of flexibility authority are incorporated into these demonstration programs 

as levers to address local educational needs. The State Flexibility Authority (Sections 6141 

through 6144 of NCLB) offers flexibility authority to state education agencies with each agency 

able to enter into Local Flex agreements with and between districts. However, no states are 

currently utilizing State Flex. The Local Flexibility Demonstration Program (Sections 6151 

through 6156 of NCLB) authorizes the secretary of education to enter into flexibility 

demonstration agreements with up to 80 districts in states that are not exercising State Flex. 

Local Flex permits participating districts to consolidate funds from four eligible federal programs 

and use those funds for any educational purpose authorized under ESEA. The flexibility 

associated with Local Flex applies to both public and nonpublic schools in participating districts. 

The degree to which State and Local Flex link flexibility and accountability as elements of an 

integrated strategy for promoting educational improvement distinguish them from some of the 

more widely accessible forms of flexibility available under NCLB. State and Local Flex 

applicants are required to develop a clear, detailed five-year plan of action that articulates their 

rationale for seeking enhanced flexibility authority, delineates a concrete strategy for the 

consolidation and utilization of affected federal resources, and presents a convincing case that 

these actions will serve to facilitate the attainment of educational goals. Districts must develop a 

clear linkage between exercising flexibility authority and carefully defined local and state 

educational priorities. Districts must submit an annual performance report for each year of the 

Local Flex implementation. In addition, if the district fails to make AYP for two consecutive 

years, the Department must terminate the Local Flex agreement. 

 

1

 This section and the following one of this report are based heavily on U.S. Department of Education, Office of the 

Under Secretary, Factors Affecting Initial Application Rates for the State Flex and Local Flex, Programs, 

Washington, D.C., 2003. 
2

Challenges to Participation 

The first round of State Flex and Local Flex competitions, conducted in late 2002 and early 

2003, resulted in one State Flex application and only one complete Local Flex application. As a 

result of the small number of applications, the U.S. Department of Education commissioned the 

Urban Institute in 2003 to conduct a series of interviews examining the low application rate for 

these demonstration programs. That study identified a number of factors that led to the relatively 

low participation rates in State and Local Flex competitions. These factors included: 

• Competing Priorities and Organizational Capacity. State and district education 

agencies viewed the implementation of other No Child Left Behind provisions, 

particularly those related to accountability, as a higher priority than exploring the 

possibilities of the State and Local Flex programs. As the application deadlines for these 

provisions preceded key NCLB deadlines, state and district education administrators felt 

unable to formulate the kinds of long-term improvement strategies the applications 

required. Thinly stretched organizational resources and agency staff also made agencies 

less likely to pursue discretionary opportunities, unless they were thought to be 

particularly attractive. The combination of limited organizational capacity and higher 

priorities effectively limited interest in the State and Local Flex programs. 

• Information about the State and Local Flex Programs. Administrators at the state and 

district level often displayed only a modest familiarity with the program provisions. 

While all administrators were familiar with NCLB-related flexibility in general, few had 

detailed knowledge of the nuances of the State or Local Flex provisions or what 

distinguished them from the Transferability authority. This knowledge gap is partially 

attributable to the distance between information sources and the administrators charged 

with examining and applying for the programs; state-level administrators were more 

familiar with State Flex than their district-level counterparts were with Local Flex. 

Unable to distinguish State or Local Flex provisions from other flexibility options, many 

officials chose not to pursue the program. 

• Benefits and Costs of State and Local Flex. State and district administrators generally 

agreed that greater flexibility in the administration of federal funds would be beneficial. 

Few respondents, however, could provide specific examples of specific ways in which 

the demonstration programs could uniquely help them to achieve their educational goals. 

In short, many administrators saw no clear benefits in implementing State or Local Flex. 

As the implementation of the provisions would involve additional costs and 

responsibilities (e.g., a time-intensive application process, new accounting procedures, 

and new expenses associated with administering the program), a rough cost-benefit 

analysis led some administrators to decide that participating in the demonstrations was 

not worthwhile, especially because these programs provided no additional funds. 

Two of these factors (competing priorities and limited information about the programs) can be 

seen as largely external to the State and Local Flex provisions themselves. It is plausible that, 

given more time and more detailed information about the programs, state and district agencies 

would choose to pursue State and Local Flex. 
3

There are no specific application deadlines for Local Flex and State Flex; the Department of 

Education accepts applications for the two demonstration programs on a rolling basis. Currently, 

the number of participating states and districts remains small. The only state that submitted a 

State Flex application, Florida, withdrew from the program before the state or its districts began 

to implement State Flex activities. Seattle Public Schools is the only district participating in 

Local Flex. 

The low levels of participation in these federally sponsored demonstration programs raise 

questions about the potential benefits and challenges for districts or states participating in these 

programs. 

The U.S. Department of Education commissioned the Urban Institute to conduct a series of 

interviews with district officials from Seattle Public Schools, the sole district exercising Local 

Flex. The purpose of these interviews was to investigate Seattle’s experiences with Local Flex in 

order to provide information to other districts considering the option of Local Flex and also to 

examine the benefits and challenges of the program. Representatives from the state as well as 

from public and private schools in the district were interviewed. Four central questions guide 

this study of Seattle Public Schools’ use of Local Flex: 

• Did Local Flex allow the district to better target federal funds to meet students’ needs? 

 

• Did Local Flex facilitate initiatives or programs that the district has specified in its 

five-year plan2

? 

• Since implementing Local Flex, what changes have occurred in district accounting, 

management roles and responsibilities, and the district’s relationships with private and 

public schools? 

• How did the district balance the needs and requirements of flexibility while ensuring that 

the intent of federal programs included in the agreement is met?

 

2 Seattle Public Schools five-year plan is a district initiated long-term strategy document formulated as part of the 

district’s application for Local Flex. It is updated each year by the district and available at 

http://www.seattleschools.org/area/fiveyearplan/Fiveyearplan-mastercopy.pdf. The most recent five-year plan 

addresses "academic achievement and the 'gap,' barriers to learning, leadership, and resource management issues."
4
5

2. Methodological Design 

The aim of the interviews conducted for this study was to obtain information regarding Seattle’s 

experience implementing the Local Flex demonstration program from a small set of respondents 

from the state Office of the Superintendent of Public Instruction, private and public schools, and 

Seattle Public Schools district. We identified 16 key respondents about the Seattle experience 

drawn from categories that capture the diverse experiences and viewpoints of different 

stakeholders and agencies impacted by Seattle’s implementation of Local Flex. Interviews were 

conducted on Nov. 30, and Dec.1, 2005. 

Sampling Procedures 

The Case Study Participants 

A district contact identified all case study participants to represent their respondent categories. 

For the district interviews, respondents were classified into two categories. The first consisted of 

four program representatives: these district leaders managed program areas that directly affect 

students, such as instructional services. The second consisted of five nonprogram 

representatives: nonprogram representatives addressed issues involving accounting, fiscal 

management, and grants. Group interviews were completed, one for program representatives 

and another for nonprogram representatives. Throughout the report, both groups are referred to 

as district representatives. 

The district representatives all had specialized management duties. These personnel were 

typically heads of departments overseeing one or more federal program for Seattle Public 

Schools. The scope of their responsibilities ranged from directing Title I operations to 

overseeing all NCLB implementation activities, including federal grant programs. Our 

respondents were in positions to make recommendations to Seattle’s superintendent or board of 

education regarding the Local Flex program. 

The case study participants for the nondistrict interviews were divided into three major 

categories. The private school representatives consisted of two principals from nonpublic 

Seattle schools, as well as a district representative who serves as their contact at Seattle Public 

Schools. The state representative was a federal funds manager from Washington’s State Office 

of the Superintendent of Public Instruction (OSPI). The public school representatives were two 

public school principals. The district selected these individuals to participate and thus, we are 

unable to generalize their views as those of all departments and people affected by Local Flex. 

For instance, one of the public school principals had worked at the district office and may have a 

unique understanding of the district and federal programs compared to principals who have not 

worked at the central office. 

Interview Protocol 

Similar semi-structured interview protocols were employed for all representatives. Question 

wording was specific to the particular program at issue (i.e., communication with Seattle Public 

Schools, State Office of Public Instruction, private schools, etc.) and portions of the interviews 
6

were further tailored for the particular respondent categories. All respondents with whom 

interviews were conducted possessed some level of familiarity with Local Flex and other forms 

of flexibility under No Child Left Behind.

3

 Copies of the interview protocols are included in 

Appendix A. Interviews ranged from 40 minutes to two hours. 

 

3

 All informants were provided with detailed explanations about the interviews before interviews took place. This 

ensured that respondents possessed some level of knowledge about the Local Flex demonstration program and 

reasons for the researchers’ visit. 
7

3. Results 

Background on Seattle Public Schools’ Participation in Local Flex 

Seattle Public Schools is Washington state’s largest school district, serving approximately 

46,000 students in 100 schools. Its stated mission is, “To provide every student with effective, 

high quality teaching and learning experiences, relevant curriculum and support services, in a 

safe and healthy environment.” A summary of district characteristics appears in Exhibit 1. 

Seattle Public Schools adheres to a highly decentralized paradigm in which authority for 

budgeting, staffing and instructional program decisions resides at the building level. Schools are 

expected to be accountable to the district and to reach student performance standards but are 

given leeway over budget, staffing, instruction, and curriculum in order to reach district goals 

through site-based decision making. 

Exhibit 1 

Overview of Seattle Public School District: 2005–06 School Year 

 

Students 

 Elementary 21,962 African-American 22% Free and Reduced Price Lunches 41% 

 Middle 9,849 American Indian 2% Special Education 9% 

 High 14,204 Asian 23% Served Through ESL 12% 

 White 41% Number of Languages Spoken 100%

 Total 46,105 Hispanic 12%

Staff 

 Teachers 3,105

 School Administrators 140

 Student Support Staff 3,813

 Office staff 861

 Total Full Time 4,989

 Total 7,919

Schools 

 Elementary 59 

 Middle 11 

 High 12 

 K–8 8 

 Alternative 10 

 Total 100 

Exhibit reads: Seattle Public Schools had 46,105 students in 2005. Forty-one percent of students 

were Caucasian, 22 percent Asian, 22 percent African-American, 12 percent Latino, and 2 percent 

American Indian. 

Source: Seattle Public Schools, Office of Grant Services, 2006.

To prepare for the Local Flex application process, Seattle developed a five-year plan, which 

focused on strategies aimed at improving the quality and rigor of instruction, accelerating student 

achievement, and closing achievement gaps. This included identifying the highest need schools 

and targeting additional services to them, such as teacher coaches. In addition, all schools 

received additional support for new teachers through a new teacher mentor program. Through 

the development of the five-year plan for the Local Flex application, Seattle Public Schools 

underwent strategic planning, created new initiatives that directly influenced student learning, 

and increased collaboration within the district office and with private schools. 
8

Application Process for Local Flex 

Seattle Public Schools had a long history of advocating for additional flexibility and wanted to 

take advantage of new flexibility provisions provided in NCLB. Three major factors led to the 

district’s interest in applying: 1) the district had experienced difficulty in meeting student’s needs 

due to Title I funding limitations, 2) the district’s goals closely corresponded with the NCLB

legislation, and 3) the district had advocated for additional flexibility to meet its goals. Even 

prior to the 2001 legislation, the district’s administrators sought block grant federal funding 

because the district had challenges meeting the needs of all students while dealing with the limits 

of Title I funding and other categorical federal programs. One district representative described 

the district’s difficulties: 

Because Title I was restricted in terms of eligible attendance areas, it also did not 

allow [the district] sufficient federal funds to meet the needs of students outside of 

those areas. [The district] found that [it] had to distribute Title I funds only to 

elementary grade levels because there were not sufficient funds, in terms of scope, 

to meet the needs of our middle schools and high schools. 

In addition, the district priorities and improvement plans closely corresponded with the 

objectives of the NCLB legislation. One district respondent described the district’s goals: 

[The district] had goals that talked about meeting the academic achievement of 

all students and reducing disproportionality. So when No Child Left Behind

came on, it was very similar to our tenets, and when Local Flexibility came on, it 

was very clear .... [T]here seemed to be a marriage for us [the district] to move 

in that direction. ... We felt at that time we had decision-making through school 

improvement plans that had a readiness for us to accept more flexibility for 

decision-making than maybe other districts that were more centrally-controlled. 

 

The district’s match with NCLB’s goals had been pre-dated by advocacy for additional flexibility 

to reach the goals of closing achievement gaps: 

Because [the district] took such a heavy stance with our [U.S.] senators ... [the 

Department] built in [NCLB] a demonstration program to see [if] what was being 

proposed in Seattle and other school districts would in fact drive higher levels of 

performance academically if they had more flexibility. ... So, given the fact that we were 

such an advocate politically across the nation and we were known for our stance ...we 

were encouraged to be partnered in applying for a Local Flex demonstration program to 

make sure at least there was one district in the nation that was willing to take on the 

effort. 

After Washington’s State Office for the Superintendent of Public Instruction (OSPI) declined to 

apply for State Flex, the district applied for Local Flex. The application process was a 

collaborative effort involving Seattle Public Schools, OSPI, and the U.S. Department of 

Education. The state representative explained that the district consulted extensively with the 

OSPI prior to applying for the demonstration program and throughout the application process. In 

fact, the state representative indicated that the district and the state were partners in the grant 
9

application. Seattle Public Schools initially submitted its Local Flex application in September 

2002. After comments from a Department of Education peer-review panel, the proposal was 

revised and resubmitted in July 2003. At this point, Seattle Public Schools was the only district 

to submit a full proposal for the program. In November 2003, the U.S. Department of Education 

announced that the district had received Local Flex authority. When Seattle Public Schools was 

granted Local Flex at the end of 2003, the district was not able to actively utilize Local Flex 

during the 2003–04 school year because the budgeting process had already occurred and the 

school year was already underway. In addition, 2004–05 was the first year where the 

accountability requirements associated with Local Flex were in effect. Thus, the 2004–05 school 

year was the first official year of Local Flex implementation. 

Plans for Local Flex 

Seattle’s extensive efforts formulating a five-year plan resulted in U.S. Department of Education 

approval to exercise Local Flex authority enabling the district to consolidate funds from the four 

eligible program areas: 

Title II, Part A (Teacher and Principal Training and Recruiting) 

Title II, Part D (Enhancing Education Through Technology formula-based funds) 

Title IV, Part A (Safe and Drug-Free Schools and Communities) 

Title V, Part A (Innovative Programs) 

These funds represent approximately 1 percent of the district’s $420 million annual budget. 

Since the district began participation in the Local Flex demonstration program, the amount of 

available funds for consolidation has decreased each year. This was a result of both decreases in 

federal dollars allocated to the programs and declines in the student population in the district. 

Exhibit 3 shows the amount of funds available for consolidation each year beginning with the 

two school years prior to the district’s official participation in Local Flex (2002–03 and 2003–

04). 

Exhibit 2 

Seattle School District: Federal Allocations by Program and School Year 

 

Prior to Local 

Flex 

Transition to 

Local Flex During Local Flex Projected Difference 

Program 2002–03 2003–04 2004–05 2005–06 2006–07 2002–07 

Title II, Part A $3,400,435 $3,272,700 $3,234,878 $3,273,362 $3,273,362 -$127,073 

Title II, Part D $393,515 $338,514 $324,144 $233,104 $130,538 -$262,977 

Title IV, Part A $438,676 $397,880 $395,680 $358,759 $287,007 -$151,669 

Title V, Part A $368,078 $347,782 $253,988 $163,153 $86,149 -$281,929 

Total Initial Allocation $4,600,704 $4,356,876 $4,208,690 $4,028,378 $3,777,056 -$823,648 

Total Carryover From 

Previous Year 

(when available) $1,110,772 $1,124,893 

Final Total Available $4,600,704 $5,467,648 $5,333,583 $4,028,378 $3,777,056 -$823,648 

Exhibit reads: Total funding for all of these programs has decreased from $4.6 million in 2002–03 to $4 million in 

2005–06 and is projected to fall to $3.7 million in 2006–07. 

Note: Projections calculated by Seattle Public Schools. 

Source: Seattle Public Schools, Office of Grant Services, 2006. 
10

 

As part of the agreement, the Seattle Public Schools District committed to using consolidated 

funds to address five specific areas, which the district developed as part of its five-year plan: 

• Improve teacher knowledge, rigor and skill in the application of research-based practices 

and strategies for mathematics, literacy content and pedagogy. 

• Improve teacher knowledge and skill in standards-based, culturally responsive teaching 

and learning, differentiation of instruction, and the use of data to inform instruction. 

• Improve beginning teacher quality and preparation for service to underserved students of 

diverse backgrounds. 

• Enhance the integration of technology in the classroom for teacher productivity and the 

teaching and learning program. 

• Provide intervention and support services for academic achievement, reentry and 

substance abuse issues for targeted student populations. 

Exhibit 3 shows a detailed summary of the five strategies and the funds allocated to the strategies 

in each of the year’s the district has participated in Local Flex. District officials developed these 

targeted areas as part of the five-year plan in consultation with Washington’s Office of the 

Superintendent of Public Instruction. Changes in district leadership, the district’s organization 

based on categorical programs, and a restricted time frame constrained the district in its 

development of these goals. In addition, substantial reductions in federal program allocations to 

Local Flex eligible funds meant that the district had to make difficult funding decisions and 

could not fully fund all five strategies (see Exhibit 3). The decline in funds posed serious 

challenges to implementation. For example, the district was able to hire a director of equity and 

relations using district funds. In turn, the district reduced funds for teacher training in culturally 

responsive teaching and learning because they were able to cover this in a different way. In 

addition, the district incorporated a cultural component into the teacher coaching program. 

To allocate available Local Flex funds, Seattle constructed a system that uses tiers to identify 

schools that should be targeted using the strategies funded by Local Flex. Tier 1 schools were 

selected based upon “urgency of need.” These are schools in which all students need assistance 

to meet or exceed state standards in reading and mathematics and have generally not met AYP 

for at least one or more years. At the time of application 17 of Seattle’s 100 schools were 

identified as Tier 1. Tier 2 schools are other schools with student populations that need support 

to bring them up to state standards and did not meet AYP for the previous year. At the time of 

application 26 of Seattle’s school were identified as Tier 2. In addition, the Local Flex 

agreement required that each subgroup of students would meet or exceed their annual 

performance targets for each year of the five-year agreement. 

 
11

Exhibit 3 

Seattle School District: Local Flexibility Plan Overview 2004, 2005, and 2006 

 

 

Consolidated 

2004 

Consolidated 

2005 

Consolidated 

2006 

 

Strategies/Activities 

Revised Plan 

2003–04 by 

strategy 

Initial Plan 

2004–05 by 

strategy 

Initial Plan 

2005–06 by 

strategy 

1. Improve teacher knowledge, rigor and skill in application of 

research-based practices and strategies for mathematics, 

literacy content and pedagogy. $ 1,848,448 $ 1,767,266 $ 1,213,092 

 1.1 Expert coaching in reading and mathematics. 

 1.2 Comprehensive professional development in brain-based 

literacy instruction. 

2. Improve teacher knowledge and skills in standards-based, 

culturally responsive teaching and learning, differentiation 

of instruction, and the use of data to inform instruction. $ 423,349 $ 262,500 $ 39,920 

 2.1 Professional development for culturally responsive teaching and 

learning. 

3. Improve beginning teacher quality and preparation for 

service to underserved students of diverse backgrounds. $ 1,102,843 $ 1,112,432 $ 876,603 

 3.1 Mentors for beginning teacher of higher-need students and 

schools. 

 3.2 Human resources for recruitment of quality teachers. 

4. Enhance the integration of technology in the classroom for 

teacher productivity and for the teaching and learning 

program. $ 360,052 $ 311,578 $ 267,437 

 4.1 Deployment of Instruction Technology Master Teachers. 

 4.2 Provision of professional development for school-based 

technology teacher leaders. 

5. Provide intervention and support services for academic 

achievement, reentry and substance abuse issues for 

targeted students. $ 1,016,418 $ 1,011,800 $ 883,067 

 5.1 Hire intervention specialists. 

 5.2 Support student reentry programs. 

 5.3 Target support for bilingual students. 

 5.4 Conduct a bilingual program review. 

 5.5 Provide professional development for teachers of advanced 

learners. 

 

 Funds for services for private school students and teachers $ 441,339 $ 702,626 $ 648,232 

 

 Total Direct Costs $ 5,192,449 $ 5,168,202 $ 3,928,351 

 Total Indirect Costs $ 275,200 $ 165,382 $ 100,027 

 Total Funds $ 5,467,649 $ 5,333,584 $ 4,028,378 

Exhibit reads: Funding for all Local Flex programs has decreased over the past three years. Activities to improve 

reading and math teaching received the largest amount of funding ($1.8 million in 2003–04 and $1.2 million in 

2005–06). 

Source: Seattle Public Schools Annual Performance Report Year II, 2006. 
12

Seattle Public Schools also set long-term, strategic goals to be achieved by 2013–14. Setting 

these goals was not required under the Local Flex agreement but was mandated by Washington 

Office of Superintendent of Public Instruction. They included the following goals: 

• All students enrolled in Seattle Public Schools will reach or exceed state and district 

standards in reading and mathematics. 

• Gaps in student achievement in reading and mathematics will be eliminated. 

• The four-year cohort graduation rate for high school students will meet or exceed 85 

percent. 

• The unexcused absence rates for elementary and middle schools students will decrease to 

1 percent. 

Seattle’s Local Flex goals and initiatives were one part of reaching overall district goals, which 

were focused on helping the district make AYP. After not making AYP in the 2004–05 school 

year, Seattle was required by the state to develop and implement a District Improvement Plan 

(DIP).4 Seattle used the already existing five-year plan (created as part of the Local Flex 

agreement) as the platform for the DIP. In other words, Local Flex served as a framework for 

the DIP. The DIP expanded plans for the district to make AYP by targeting resources to students 

most in need at schools that had failed AYP. 

Seattle’s use of Local Flex might be discontinued if the district fails to make AYP for the second 

consecutive year (as mandated in the Local Flex provision). Even with this possibility, however, 

the district remains confident that it would be able to continue to implement the current strategies 

(albeit with less flexibility), as Local Flex has served as an impetus for effective planning and 

coordination in Seattle Public Schools and these changes have become institutionalized. For 

example, the district anticipates maintaining coaches and mentors at some schools even in the 

absence of Local Flex authority. In addition, the fact that Local Flex funds represent only a 

small percentage of Seattle Public School’s overall budget means that the elimination of Local 

Flex authority would not have a drastic impact on the district’s activities. 

Targeting Federal Funds to Meet Students’ Needs Through the Use of Local Flex 

The main limitation of categorical funding from a district’s perspective is that funds cannot 

necessarily be allocated to programs and initiatives based on students’ needs. Local Flex allows 

the district to think strategically about student needs by working to achieve goals set by district 

leadership rather than just applying categorical funding as mandated. It also allows districts to 

rapidly respond to changing demands by reallocating funds as needs arise and to most effectively 

target services to schools and students with the highest needs. 

The sections that follow explore the district’s new opportunities for planning that have arisen as 

a result of the district’s participation in Local Flex. They also examine how the district is 

 

4

 Adequate yearly progress (AYP) among school districts is determined by the academic performance among each 

student subgroup and the student population as whole in the district, as well as by the attendance and graduation 

rates at the district level. Seattle Public Schools did not meet adequate yearly progress in 13 of 71 target areas in the 

2004–05 school year. 
13

tracking progress toward the goals set out in its Local Flex application and the relationship 

between Local Flex and federal and state accountability. The case study took place when the 

district had been officially using Local Flex for just over a year and representatives indicated that 

the district was just beginning to fully utilize the program. However, the program appeared to 

have a substantial influence on district planning and coordination for a set of initiatives aimed at 

targeting students and schools with high levels of need. 

New Possibilities for Planning 

As described above, the original Local Flex agreement focused on five strategies Seattle Public 

Schools developed to better meet its students’ needs. These strategic initiatives were developed 

as part of the application process for Local Flex through the district’s five-year plan. One district 

representative explained that the district based the overarching initiatives and academic actions 

on what was needed to serve the district’s students: 

We developed the initiatives without looking at specific dollars. Once the 

initiatives were developed, then when the team was able to look at the dollars, 

they would say, “Okay, with this kind of flexibility, we can expand this, we can do 

this, we can do that.” So, I think the ... implementation would have looked 

different without Local Flex; the initiatives themselves I don’t think would have 

been different had we been categorical versus flexibility. 

The district leaders were able to take advantage of the flexibility offered by the Local Flex 

program to better target eligible funds to the identified strategies. Increased flexibility meant 

they could focus eligible funds on the highest priority strategies identified in the five-year plan 

rather than being tied to the requirements of the categorical programs. This allowed district 

leaders to use funds in ways that were aimed at making a “better, bigger difference” for students. 

The district’s efforts to fully utilize Local Flex are still a work in progress, as the district only 

had one full year of implementation and experienced “huge transitions of leadership” during that 

time. One district representative explained that there have been significant personnel shifts and 

it had taken about a year to understand the possibilities that Local Flex presents. Furthermore, 

district staff indicated that implementing any kind of substantial change in process and strategy 

takes time and that only having a short period to show results was unrealistic given the 

complexities of a large, urban school district. As noted above, Seattle Public Schools did not 

make AYP in 2004–05 after not meeting 13 of 71 districtwide student performance targets, and 

there was concern among district officials that they might not make AYP in 2005–06 and thus 

lose their Local Flex authority. Overall, district officials indicated that they were disappointed 

that they may only have a relatively short period of time to implement the program because they 

believed it would take more time to experience the full benefits of the program. 

While the district indicated that they had only begun to take advantage of Seattle Public Schools’ 

participation in Local Flex demonstration program, they were confident that they would be able 

to better utilize it in the coming year. One district representative explained that district staff had 

been “siloed” into different departments (which were generally defined by different federal 

programs) prior to Local Flex. A more integrated approach to using funds was beginning to take 
14

place with the introduction of Local Flex, although at the time of the case studies, “Title 

boundaries” had yet to be crossed (i.e., funding had not explicitly been moved from one Title 

program to another). 

In addition, collaboration was occurring not just with programs that were a part of Local Flex but 

other federal programs as well. It appeared that Local Flex acted as an impetus for more 

collaborative efforts at targeting funds based on the initiatives set forth in the five-year plan. 

One district representative explained this need for collaboration by discussing gaps between 

groups of advantaged and less advantaged students: 

We realize we can’t do it in isolation. Local Flex can’t close that gap and Title I 

can’t close that alone, it has to be a concerted effort, across the board; maybe 

blending some funding from instructional services, student services, and school 

services.

Not only was funding consolidation needed, but staff collaboration was also essential to fully 

implement Local Flex. The district’s traditional organizational structure around categorical 

programs and the high level of turnover meant that while funding consolidation was now 

available through Local Flex, the district was still working on the interpersonal collaboration 

necessary to fully implement the program. This process was explained in practical terms by 

another district representative, who explained that it had taken time to get know the other district 

management staff and learn to make difficult decisions together about limited resources: 

So, it took me a year to sort of figure out what that would mean ... and getting to 

know each other and saying, ‘Okay, these are the outcomes we’re hoping for and 

these are the strategies that we’ve all agreed upon,’ which has been very recent. 

And so, how do we then look at resources and use them in flexible ways? And are 

there some things we won’t do anymore? And move those, that money from 

technology to [instruction], just because that’s what we need to focus on right 

now. 

These views from different district representative staff indicated that they expected to see an 

even stronger collaborative effort around targeting funds based on students’ needs (and aligned 

with the Five-year plan) in the coming year. While staff believed the ability to coordinate 

planning would be more fully utilized in the coming year, many activities identified in the Local 

Flex agreement were already underway (see section below on specific initiatives and actions). 

One example was that through the Local Flex agreement, district leaders had identified Tier 1 

and Tier 2 schools and this was used as criteria for providing additional services, most notably 

literacy coaches, to these schools. 

Participation in Local Flex also proved advantageous for planning for the district’s changing 

short-term needs. Using data to guide planning, adjustments were quickly made to target funds 

to the highest needs areas: 

 

• The district had not hired many new teachers, so the district reduced the number of 

mentors and maintained the same number of literacy and mathematics coaches (which 

would have otherwise decreased because of reductions in funds available). 
15

• The district shifted services based on data that indicated that some schools had changed 

from Tier 1 to Tier 2. 

• Finally, the district was able to include a science focus because the state had collected 

data on students’ needs in science. 

District officials also suggested that flexibility would be useful for addressing larger or 

unexpected fluctuations in student needs. One district administrator used the example of 

receiving a sudden influx of immigrant students and suggested that they would be able to quickly 

reshuffle plans to better serve those students. Thus from the district’s perspective, flexibility 

allowed for quicker and better reactions to small or large changes in district needs. 

Finally, the district found increased flexibility very useful in a time of diminishing resources. 

The district was experiencing enormous financial challenges along with substantial decreases in 

funding allocations for the federal programs that are a part of Local Flex (see Exhibits 3 and 4). 

One district representative clarified the district’s need for flexibility in challenging budget 

circumstances: 

One of the reasons why we have such a great need for additional flexibility is the 

continued reduction in the amount of funds that we’ve received from federal, from 

state, from other grants, things like that. In a perfect world, it wouldn’t matter if 

you were completely categorical or completely flexible because you’d have 

enough dollars. ... Because we don’t have enough dollars in any pot to 

accomplish what our students need and to provide them the services that they 

really do require, the flexibility, the benefit of the flexibility is that it allows us to 

say, “All right, you’re going to get nine [academic] coaches, ’cause I need two 

drug-alcohol people.” I mean, so I think it’s important to remember that the 

flexibility is great, but one of the reasons why we need it right now is we don’t 

have enough funds to cover all the activities that we need to cover. 

Flexibility allowed district officials to continue to fund initiatives that they viewed as most 

important in a time of limited resources. While Local Flex was very useful in a difficult budget 

period, district representatives indicated that even with more resources, Local Flex would still 

allow the district to better plan and develop initiatives to more fully meet students’ needs. One 

district representative explained that having flexibility and having stable or increased funding 

would be the ideal. 

Tracking Progress and Accountability 

The Local Flex application process required Seattle to both develop and evaluate its progress 

toward long-term goals. Seattle used the Local Flex application process as a catalyst to assess 

district goals and address areas for improvement. At the same time, new accountability measures 

required additional tracking of student progress. Prior to the planning process that resulted in the 

Five-year plan and Local Flex application, the district had not yet developed means for assessing 

progress toward reaching district goals. Through the Local Flex application and planning 

process (in combination with other accountability requirements), Seattle developed a series of 

benchmarks to track progress toward the districts goals. One district representative explained 

this effort: 
16

We’re tracking our goals. We have benchmarks for a Five-year plan and we are 

tracking those. And we have data that shows whether or not we’re making 

progress ... we did focus groups in schools, and we chose 25 schools where our 

instructional coaches were and we had three or four focus questions ... it really 

helped inform our work for this year. 

This district respondent summarized Seattle’s approach toward tracking progress in a 

“triangulated way” that involved reaching out to teachers using surveys and professional 

development offerings, as well as reviewing each school’s transformation plan. In addition, the 

district collects student assessment data at the beginning and end of the year along with other 

student data related to student attitudes and behaviors and school climate. One district 

representative noted that new software allowed assessments to automatically appear on district 

forms. Collecting data from multiple sources along with new technology enabled the district to 

use data-driven methods in allocating Local Flex money in order to reach the needs of students 

that need additional support but are not in the Tier 1 or Tier 2 schools. 

District respondents indicated that shifts in the state’s accountability system did lead to some 

changes in the designation of schools as Tier 1 or Tier 2 but did not influence the district’s 

implementation of Local Flex. While recent changes only led to minor changes in the allocation 

of Local Flex funds, district respondents indicated that new testing in the state of Washington 

and other potential changes to accountability measures could have a substantial influence on the 

future implementation of Local Flex. 

Our kids change every year ... so, if we went to a continuous growth model, I think that 

could drastically affect our implementation of Local Flex because then we’re going to be 

looking at trends. ... The other thing that makes me think about is that now we’ll be 

testing at every grade level. The question of whether that will also affect where we see 

the need because it is true [that] cohorts of kids kind of move through, and you think, 

“Oh, whoops, we need to make sure this school has additional resources.” 

District respondents suggested that even in the face of major changes to accountability, Local 

Flex would be very useful, as it would allow the district to more easily respond to new 

requirements. With Local Flex, the district could immediately refocus resources based on 

student needs revealed by changes in the accountability system without having to inform the 

state or fill out additional paperwork. Similarly, if a particular school experienced an influx of 

students who needed additional academic support, the district could quickly provide additional 

resources to this school. 

New Initiatives and Actions 

District representatives reported that the implementation of Local Flex facilitated the 

identification of initiatives and actions that would help the district to reach its goals. Through 

the planning process that took place in conjunction with Local Flex, district respondents 

developed programs for the use of eligible funds that 1) targeted assistance to those students who 

need it most (Tier 1 and Tier 2 schools), 2) focused on improving reading and math skills, and 3) 

worked to build and maintain an effective, professional teaching corps. 
17

Throughout the case study interviews, district, school and state respondents frequently identified 

two changes under the Local Flex initiatives: new on-site coaching and revamped teacher 

mentoring. These two initiatives received significant attention under the program as a result of 

the district’s increased ability to strategically use its funds. While other initiatives were 

mentioned in the interviews (e.g., substance abuse intervention specialists), these two initiatives 

appeared to be the district programs most closely associated with Local Flex. 

As a result of Local Flex, on-site coaches in specific content areas (literacy and mathematics) 

were introduced in district public schools. These coaches “support[ed] schools in content areas” 

and worked on curriculum alignment. Principals identified on-site coaches as the most visible 

manifestation of the Local Flex program. The coaches worked directly with teachers on reading 

and mathematics curriculum, instruction and assessment. In Tier 1 schools, the coaches helped 

to develop and deliver a schoolwide plan for ongoing professional development, including 

training, demonstration lessons, peer observation, and review of student work. In Tier 2 schools, 

coaches provided training to teachers to deliver targeted interventions for particular 

subpopulations. In addition to the direct benefit these coaches provided to the schools, they also 

came to serve as liaisons between schools and the central office. 

A literacy coach in one public school was instrumental in improving that school’s reading 

program. The coach met regularly with teachers to discuss assessment tools, data analysis and 

teaching strategies. In addition, the coach helped to produce personalized reading plans for 

students struggling with reading. School leaders that did not have on-site coaches in their 

schools receive support indirectly through trainings conducted by coaches: 

We, the principals and the assistant principals, had special meetings to learn 

about the direct reading assessment, so we actually learned how to take the test, 

not to give the test, so that when our teachers did give the test, we would be able 

to talk to them about the data that they collect, or we would be able to help them 

if they were having difficulty with it. Well, we were trained how to do the direct 

reading assessment by one of the literacy coaches, so, again, that’s an indirect 

service that we get because if there were no literacy coaches, who else would do 

the training? 

These trainings provided teachers in all of the district’s public schools with improved 

understanding of conducting classroom assessments and using data to better target teaching to 

improve students’ learning in reading and mathematics. 

In addition to literacy and mathematics coaching, the other program most closely associated with 

Local Flex was Staff Training Assistance Review (STAR), a mentoring program for new 

teachers. This program was given a new focus since the implementation of Local Flex. The 

district incorporated more formative assessment tools for mentors to use and increased training 

in such areas as equity issues. A district administrator identified this program as especially 

important for Seattle Public Schools due to the urban nature of the district: 

That is important in terms of meeting student needs because, like many urban 

districts, it’s also true that our beginning teachers are most likely to teach our 
18

highest needs students, that they’re more likely to be seen in schools with high 

numbers of kids of color, kids who are poor, and so on, and that what we’ve found 

is that Seattle actually does a really good job of retaining our beginning teachers. 

In addition to one-on-one mentoring, STAR was meant to create “a strong professional learning 

community” that would decrease the likelihood of new teachers feeling isolated and, therefore, 

less likely to continue teaching in Seattle Public Schools. District and school leaders both 

indicated that they viewed the program as very effective with first-year teachers both in terms of 

improving their performance and retention. 

District Management and Relationships with Schools Since Local Flex 

One of the perceived challenges to participation found in the previous study of Local Flex 

centered on concerns related to the organizational capacity of districts and accounting burdens of 

program participation. This section focuses on how Seattle Public Schools addressed these 

potential difficulties by examining changes in management staff responsibilities and accounting 

since implementing Local Flex. In addition, it explores the district’s relationship with schools 

and the state before and since participation in Local Flex. None of these potential stumbling 

blocks or perceived concerns appeared to present much of an obstacle to the district. 

Furthermore, Seattle Public Schools’ relationship with schools and the state was generally 

positive and in many cases even stronger than it was prior to the use of Local Flex. 

Changes in Leadership Roles and Responsibilities 

Large districts are often organized around specific federal programs and Seattle Public Schools 

organizational structure follows this pattern. In turn, it would seem likely that implementing an 

authority allowing federal funds for a group of programs to be more flexibly allocated would 

lead to changes in the district staff’s roles and responsibilities. Interviews with the majority of 

district representatives, however, did not suggest that Local Flex had substantially changed their 

responsibilities for district-level activities. This may be attributable to the high level of turnover 

in management level positions in the district in the past few years. As few relevant employees 

remain from the pre–Local Flex period, it is difficult to gauge the possible changes in roles and 

responsibilities that have resulted from participation in Local Flex. However, most district staff 

did not indicate that their roles had changed substantially. 

District representatives indicated that Local Flex (combined with a tighter budget situation) led 

to greater coordination among those responsible for federal funds. Furthermore, the district 

representatives expected that the level of coordination would continue to increase as the new 

management staff became increasingly familiar with the Local Flex program and how it could be 

used to meet district goals. One district respondent who had been in the same position prior to 

the district’s participation in Local Flex suggested that the consolidation of funds through Local 

Flex decreased administrative time and costs and allowed the district to focus on service delivery 

to schools, staff and students. 
19

Changes in Accounting 

In considering whether or not to participate in Local Flex, districts (and states) reported 

numerous concerns related to the perceived increases in accounting and reporting burdens 

associated with the flexibility demonstration programs. The district representatives responsible 

for accounting at Seattle Public Schools indicated that there was very little increased accounting 

burden as a result of participation in Local Flex. They attributed this fact to a new, fully 

integrated software suite the district began implementing in 2000 which had been modified to 

district specifications. The system includes a project module which holds data on every grant, a 

business to business module which integrates the Internet for ordering online supplies, materials, 

and equipment, along with all other business functions linked to financial transactions. Officials 

also had plans to transfer their human resources and payroll system from their old system to the 

new software package by 2007. 

The new software has reportedly kept the challenge of tracking a mix of consolidated and 

categorical funds to a minimum. The system’s ability to track financial transactions reduced 

potential accounting burdens related to Local Flex. Program managers and anyone else with 

online access to the data information could obtain updated balances on all grants individually. 

Officials reported being able to track the following information through the new program: 

• All individual grants 

• The award period 

• The fiscal year 

• The award amount 

• The individual responsible for the grant 

• The organization within the district where the grant is budgeted 

• The current budget, past budget, encumbrances, expenditures, and available balance 

• Allowable costs and special conditions 

• The funding source (i.e., federal, local, state, etc.) 

• The number of staff, as well as complete costs for each of the employees 

The new system also enabled the district to label each of their grants with sub-codes, which was 

useful for financial reporting. Federal funds all have Catalog and Federal Domestic Assistance

(CFDA) numbers, which are equal to reference numbers. The catalog is a database of all federal 

programs available from the federal government. The district was required to track all federal 

funds for purposes of financial accountability using this number along with a cross reference to 

the state of Washington accounting manual. Each of the grants that were part of the Local Flex 

funds that have been integrated into one program, has a separate CFDA number that has to be 

used when processing claims for reimbursement of district expenditures. The district explained 

that even though the Department of Education authorized an integrated program, fiscally they 

still have to be able to account for the funds separately. 

One example of the advantage of the district’s accounting system occurred in providing 

accounting information to the state. When Local Flex was implemented, the state and Seattle 

Public Schools held discussions regarding how to track the use of Local Flex funds. Each of the 

four programs involved has a separate CFDA number. The state is required to track each of 
20

these programs individually. To ease the burden on Seattle Public Schools, the state offered to 

distribute the money for all four programs and allow Seattle Public Schools to submit invoices 

and requisitions as a percentage of the total of all four programs, rather than tracking each CFDA 

separately. Seattle Public Schools declined to take this option, because their financial tracking 

system allowed them to sub-code each grant and keep the tracking system as if it were still 

categorical. One district representative indicated that while accounting did not present a problem 

for Seattle Public Schools, it could represent a burden for other districts in Washington (and 

likely in many other states), because these districts do not have such a sophisticated accounting 

system in place. However, the software manufacturer does serve other public school districts 

and has services and software available to public sector organizations. Cost would vary 

depending on the size of the district. 

District’s Relationship with Public Schools 

Views on whether Local Flex has affected the relationship between public schools and the 

district vary somewhat between district and school representatives. One district representative 

reported that the implementation of Local Flex has had little effect on the school-district 

relationship, because Local Flex is not a major aspect of the district’s interactions with individual 

schools. The representative doubted that an individual teacher would be aware of the program. 

Public school administrators interviewed for this case study, however, indicated that they found 

Local Flex made a noticeable and generally positive difference in the relationship between their 

school and the district. One principal only saw limited changes in his school’s relationship with 

the district but imagined that “in some schools it’s probably dramatically changed, where they 

have a coach there nearly full-time or two days a week. ... That would make a huge difference in 

the relationship.” This speculation was borne out by another public school principal, who 

reported that the implementation of Local Flex has strengthened the school’s relationship with 

the district. Having worked in the central office, this principal was aware of limited 

communication between the district and the schools. The school administrator identified the 

presence of academic coaches as improving the relationship between the school and the district: 

“[W]e kind of have a liaison that can go back and communicate our needs and can speak in 

central office. ... And the more people you have that are going back and forth, so to speak, it 

helps bridge that gap.” Thus, while district administrators have not observed any major changes 

to the district-school relationship, school principals feel that the addition of coaches (who are 

viewed as part of a specific initiative resulting from Local Flex) strengthened the relationship by 

improving communication between the district and the schools. 

As noted above, it is likely that those schools receiving specific services as a result of Local 

Flex–related initiatives experienced changes in their relationship with the district. Schools that 

did not receive funds may not fully appreciate the district’s efforts. One public school principal 

in a more affluent part of Seattle pointed out that principals of schools in this area might not fully 

understand the distribution and value of Local Flex funds because these schools do not generally 

receive as much federal funding as schools serving more disadvantaged students. This principal 

understood and accepted the current distribution of funds but suggested that some other 

principals might not have the same level of understanding or acceptance. 
21

Public school administrators had varying views on whether the implementation of Local Flex has 

changed their responsibilities in their school. While one principal indicated that there had been 

no change in roles or responsibilities since the implementation of Local Flex, another indicated 

substantive changes in perspective and improvements in mentoring new teachers. This public 

school principal believed that Local Flex dramatically changed perceptions of school principals’ 

roles as leaders through working with literacy coaches, which were one of the focal initiatives for 

demonstration program funds. Prior to Local Flex, the principal envisioned an administrator’s 

role that was “based on ... management, keeping the school running, providing opportunities for 

teachers if they wanted to take them, and working with teachers who were problematic teachers.” 

After working with academic coaches, this principal came to the conclusion that an administrator 

role should be more of a teacher of other teachers than a manager. The principal explained, 

“[J]ust as good teachers change adolescent behavior, good coaches change adult behavior.” This 

principal was training two other administrators as coaches (this principal’s school did not receive 

additional coaches because it had not been designated a Tier 1 or Tier 2 school). This may have 

been a unique perspective as this principal worked closely with the academic coaches prior to 

returning to a principal position. 

The same principal also found the new-teacher mentoring program very useful. Previous 

discussions with new teachers had been a two-person discussion between principal and teacher. 

The introduction of a mentor for new teachers provided additional observations of new teachers, 

increased contact time with more experienced teachers, and more fruitful three-way discussions. 

In addition to these benefits, the principal was no longer solely responsible for ensuring that new 

teachers were “learning things they needed to know in order to be successful.” This school 

administrator noted that the new teacher-mentoring program was available to all schools, not just 

those designated as Tier 1 or Tier 2 schools. 

In the area of reporting to the district, school principals indicated that there was a small increase 

in accounting responsibilities since the implementation of Local Flex. It was somewhat difficult, 

however, for the school administrators to distinguish between additional accounting required 

because of Local Flex and increases in reporting required by more intensive accountability 

measures. For example, one of the principals described new steps the district has taken to 

increase achievement, such as the tracking of individual students. Schools had to document each 

student who was not meeting the standards in reading, writing, or math (based on state 

assessments given in grades 4, 7, and 10). The schools administered building, district, state, and 

national assessments to these students to track their progress. In addition, schools documented 

steps taken to assist struggling students. This new tracking system was not a direct consequence 

of Local Flex but is a result of a range of multiple factors (e.g., state and federal accountability) 

that led to Seattle Public Schools to focus on the goal of having all enrolled students at or 

exceeding state and district standards in reading and mathematics by 2013–14. 

Another public school administrator reported that there was a slight increase in accounting 

responsibility since the implementation of Local Flex. The district required that schools record 

their use of all federal dollars. The extra work associated with this task was estimated at one 

hour per week. At the same time, the district moved toward using a single comprehensive 

accounting form to cover funding from all initiatives, which eased the burden for school 

administrators. Some schools received funds related to four or more initiatives, each of which 
22

previously required separate documentation. Use of one form instead of many made the 

accounting task much easier for principals. Thus, it appears that the district tried to mitigate 

reporting burdens associated with federal funds. At the same time, school administrators 

indicated an overall increase in reporting requirements, although this was not necessarily a direct 

result of the district’s participation in Local Flex. 

District’s Relationship with Private Schools 

While Seattle Public Schools’ relationships with public schools remained about the same, its 

relationships with private schools appeared to have improved markedly since the district began 

participation in Local Flex. Private school leaders reported that prior to Local Flex, the 

relationships between Seattle Public Schools and private schools were not always smooth. 

Private school representatives indicated that they experienced four main problems in working 

with the district prior to Local Flex: 

• The district was often slow in responding to requests for services. As all requests for 

federal funding for services were required to be submitted through the district, there 

were occasions when funds for services did not come through on time. 

• High staff turnover in the district prevented the development of relationships that would 

facilitate effective communication between private schools and the district. 

• Each private school within a particular group (e.g., diocese) dealt with the district on an 

individual basis and often had a different contact for each federal program; as a result, 

coordination was limited. 

The private school representatives reported that because of these problems, there was a sizable 

amount of money each year set aside for services for private school students and teachers that 

went unused. 

Since Seattle Public Schools began participating in Local Flex, private schools’ relationships 

with the district appear to have improved substantially. The district used Local Flex funds to 

appoint a staff member to serve as a liaison between the private schools within the district’s 

attendance area and the district on matters related to federal programs. The district’s liaison 

facilitated communication through in-service meetings and a “private school coordination 

newsletter” that was published and distributed three or four times a year. Private school 

principals commented extensively on the improved communication between the district and 

private schools. One described meetings between the district and private schools as “very 

informative” and felt that district representatives “want to ... answer questions.” Another 

principal added that the written materials related to Local Flex provided by the district had been 

very helpful in explaining Local Flex. Another private school official agreed that 

communications with Seattle Public Schools had improved. Furthermore, respondents identified 

Local Flex as having made relationships with the district “less complex” and “more positive.” 

Private school representatives identified a number of additional benefits associated with Local 

Flex and the streamlining of funds. These include: 
23

• Increased ability to target funds to directly benefit students and meet particular goals 

combined with opportunity to use funds differently each year allowed the LEA in 

consultation with private schools to better direct available funds to meet their “true 

needs.” One private school administrator explained, “[W]hen we adopted One-Year 

Math as our goal ... funds [were used] for ... math; then, literacy was a goal and so we 

used one of the programs for literacy, more literacy books in the primary grades.” 

• More efficient distribution of funds for services across schools. 

All of these benefits point to the LEA being better able to direct the federal funds to meet the 

specific needs of private school students and teachers. 

Participation in the Local Flex demonstration further improved private schools’ relationship 

through simplified reporting procedures. The district crafted an umbrella form that tracks the 

combined dollar amount for all of the Local Flex eligible programs as opposed to separate 

documentation for each program. Private school representatives reported that the use of an 

umbrella form that tracks the combined dollar along with a single district contact person was 

easier than having “four different managers tracking [the funds].” According to private school 

leaders, these improvements expedited the distribution of funds and limited bureaucratic delays. 

As a result, the LEA was able to spend the funds available for services for private school 

students and teachers, unlike in years prior to the use of Local Flex. Private school leaders 

suggested that the district relationship would be even better if all federal programs, especially 

Title I, could be part of Local Flex. 

District’s Relationship with the State 

Seattle Public Schools and the state Office of Superintendent of Public Instruction (OSPI) 

maintained close ties and communicated regularly on many issues prior to the implementation of 

Local Flex. Representatives of Seattle Public Schools served on numerous committees on grant 

management. Through this cooperation, Seattle Public Schools received many federal grants, 

including Comprehensive School Reform, Enhancing Education Through Technology, Learn and 

Serve America, Education for Homeless Children and Youths, and School Improvement 

Assistance. In addition, state program managers regularly visited Seattle schools and worked 

with the district to support federally funded grant programs. OSPI worked on the behalf of 

districts, including Seattle, to resolve issues raised by the state auditor’s office regarding 

allowable use of federal funds. In short, OSPI coordinated with Seattle Public Schools on a 

range of planning, program, and financial activities. 

Before the introduction of Local Flex, the Seattle Public School District, like all districts in 

Washington state, was required to provide annually a “substantially approvable” application to 

OSPI that addressed Seattle’s use of funds from Title II, Part A; Title II, Part D; Title IV, Part A; 

and Title V, Part A. OSPI staff analyzed the information contained in that application to provide 

technical assistance to Seattle Public Schools and other districts. Now the district no longer has 

to provide an annual plan for the use of these funds because they have the five-year plan agreed 

on by the U.S. Department of Education under the auspices of Local Flex. 
24

While the state was aware that the frequency and detail of Seattle Public Schools’ reporting on 

the included federal programs would decrease with the implementation of Local Flex, the district 

continued to have a good working relationship with the state. As an OSPI representative 

reported, “I would not say there has been any significant change in the relationship between the 

state and Seattle” as a result of Local Flex. Several major federal programs, including Special 

Education and Title I, remained outside the Local Flex implementation. OSPI and Seattle Public 

Schools continued to coordinate effectively on those programs. In addition, the state and the 

district continued to collaborate on some of the federal programs that are part of Local Flex. For 

example, one district representative noted that OSPI officials regularly met with district 

representatives regarding Safe and Drug-Free Schools programs. Seattle Public Schools also 

participated in an OSPI evaluation project to measure the impact of these programs. 

While the state had no direct involvement or oversight in the use of Local Flex funds, OSPI 

required that Seattle Public Schools submit a comprehensive program review each year that 

described the district’s use of federal programs under the terms of No Child Left Behind. As a 

result, OSPI monitored Seattle Public Schools’ overall use of federal funds but did not delve into 

the details of program activities related to Local Flex. Overall, there have been no major 

changes in the workload for OSPI as a result of Local Flex. Two factors contributed to this. 

First, Seattle is just one of several hundred districts in Washington, so the removal of one district 

was only a marginal change. Second, Seattle’s grants management program was already well 

managed and required little technical assistance from the state. 

In terms of specific programs that are a part of Local Flex, a state representative explained, 

“Seattle’s Local Flex program has not changed this relationship or the manner in which the state 

supports district implementation of sound fiscal and accounting practices.” For the four 

programs associated with Local Flex, district representatives coordinated with state officials to 

receive and appropriately account for Local Flex program funds. After discussions with OSPI 

and Seattle Public Schools, the U.S. Department of Education concluded that audit responsibility 

for Local Flex rests with the state auditor’s office. Seattle Public Schools submitted financial 

requests to OSPI and received Local Flex funds through the state, but OSPI had no further 

oversight or responsibilities regarding Local Flex funds. A state representative explained that 

OSPI “now simply approve[d] anything they put on these budgets and trust that when we are 

monitored by our [state auditor’s office] and [the U.S. Department of Education], this will not 

cause any problems.” 

District respondents indicated that the district had gained increased budget authority vis a vis the 

state since implementing Local Flex. The district was able to implement budget changes prior to 

receiving formal approval from the state. From the perspective of one district respondent, this 

was another way in which the district could respond “more quickly, to be able to fill in holes, to 

go to the subpopulation groups that the others don’t allow us to go to because of too many 

restrictions.” Again, Local Flex appeared to provide the district with more ways to respond to 

changing district needs. 

While the relationship between the district and state remained strong, Seattle Public Schools’ 

implementation of Local Flex posed a reporting challenge for OSPI. The state respondent 

indicated, however, that Local Flex presented less of a challenge than the Transferability 
25

provision.5

 While Local Flex stopped the need for individual reporting by federal program from 

Seattle to the state, the U.S. Department of Education still required reports from the state of 

Washington and the state did not want to have its largest district absent from this reporting. As 

an OSPI official noted, “There’s kind of a mismatch in the data we are requested to report and 

the activities that they’re doing under those individual programs because they’re no longer 

individual programs.” Nevertheless, the district accommodated the state by continuing to file 

reports. As one district representative explained, “[W]e’ve had to work with them in terms of 

assuring that they have not only interim reports but the annual reports, and still [provide] them 

data, even though it’s not part of the evaluation from OSPI.” This allowed the state to continue 

to provide an accurate picture of the use of their four federal program funds included in Local 

Flex. 

Balancing Flexibility With the Intent of Federal Programs 

The district took steps to guarantee that the intent of the federal programs consolidated in the 

Local Flex agreement continued to be met after the implementation of Local Flex. Seattle’s 

Local Flex application addressed how funds would be used to meet the intended purposes of the 

four affected programs. There were extensive discussions between state and district officials 

and, according to a state representative, “The district paid special attention to ensuring that the 

intended purposes of the four affected programs would still be met in some way.” In addition, 

district representatives indicated that that use of Local Flex had not influenced how they used 

other federal program dollars (e.g., Title I or Title III). 

In practice, Seattle Public Schools successfully maintained focus on the four Local Flex 

programs by only shifting funds between those four programs; in other words, the funds made 

available through Local Flex did not go into a large pot used for general spending but rather 

remain earmarked for particular programs with the availability to use them in more flexible 

ways. As a district administrator described it, “Title II dollars are being spent on professional 

development, right, and we spend it on professional development. And Title V is about bilingual 

or innovative programs, and we do that. And I think because we haven’t really, totally broken 

down those containers to be one pot.” As noted earlier, the district’s initiatives did not cross 

eligible “Title boundaries.” Furthermore, the district’s effort to meet the intent of the Local Flex 

funds was supported by OSPI, which continued to provide technical assistance. 

The district’s ability to maintain focus on the intent of the four Local Flex programs was, 

however, dependent on the availability of nonfederal funds to finance other key programs. A 

district administrator described the situation as follows: “Once we keep losing resources and we 

pour everything into one pot, I don’t know whether or not we’ll be able to do everything that 

we’ve been doing, in terms of meeting the NCLB programs.” District leaders expressed concern 

that continued budget constraints and reduced allocations to Local Flex eligible programs would 

make it difficult for them to meet the intent of all of the NCLB programs. 

 

5

 Seattle Public Schools used Transferability for one year prior to implementing Local Flex. District officials that 

had been in their positions during this period indicated that Local Flex was substantially better, as it offered the 

district substantially greater flexibility over eligible program funds. However, the majority did not remember 

district’s use of Transferability, because they were in different positions during the district’s use of the program. 
26
27

4. Conclusions 

Summary of Findings 

The district, school, and state representatives participating in the case study painted an 

overwhelmingly positive picture of the district’s participation in the Local Flex demonstration 

program. The relationships the Seattle Public School District office held with public and private 

schools remained similar or had improved since the implementation of Local Flex. The process 

of developing the Local Flex application and five-year plan appeared to set in motion strategic 

thinking around a set of goals for the district’s students and the creation of a set of strategies and 

initiatives to reach those goals. In addition, new accountability measures along with required 

progress-tracking in the Local Flex agreement meant that the district was able to carefully assess 

schools and students to determine and target those most in need of additional services. The 

results of Local Flex transcended simple flexibility for a group of federal programs that represent 

a small portion of the district’s overall budget. While the focus of Local Flex is the ability to use 

eligible funds more flexibly, the strategic planning and reporting associated with Local Flex 

encouraged programs targeted to student needs and collaboration among administrators. 

While Local Flex has played a significant role in Seattle Public School’s planning, the ability to 

fully utilize the flexibility offered by the demonstration program remained a work in progress in 

the district. The district had only implemented the program for one full academic year at the 

time of the case study and the district remained organized around the individual Title programs. 

District leaders, many of whom are new to their positions, were just beginning to fully 

understand the potential for the program and indicated that any change in a large organization 

takes time to enact. In addition, the district was the first in the country to participate in the 

program and thus there were no examples or best practices for district leaders to follow when 

implementing Local Flex. 

Benefits and Challenges for Seattle Public Schools 

The goal of this study was to examine Seattle’s experience implementing the Local Flex 

demonstration program. The case study revealed a series of benefits and challenges related to 

the district’s experience with Local Flex. The section below summarizes these findings, which 

address the questions developed to guide the study. 

Benefits 

Greater flexibility than other flexibility provisions. Not surprisingly, district officials found 

Local Flex preferable to Transferability. Under Transferability, only 50 percent of the funds 

associated with a given program were eligible for flexibility. The largest of the four programs, 

Title II, Part A, accounted for three-quarters of all funds eligible for Transferability. As a result, 

the amount of funds available to transfer into Title II, Part A, was rather limited. Under Local 

Flex, consolidation of all funds associated with the four programs was allowable, which, in turn, 

has enabled the district to use funds in the areas with greatest needs. 
28

Rapid responses to changing district needs. As a result of the flexibility granted by Local Flex 

the district was able to quickly respond to changing district needs. For example, the district 

could quickly shift services after changes in accountability measures led to new schools being 

identified as Tier 1 or Tier 2. In addition, Seattle Public Schools gained increased budgeting 

authority, because the district no longer had to receive formal approval from the state for each 

Title program. This allowed the district to move more quickly to fill funding gaps or serve subpopulations that might not be receiving adequate services. 

Increased ability to target funds to high needs schools and students. The initiatives in the fiveyear plan focused on initiatives and programs aimed at schools and students who need assistance 

the most. This was most frequently mentioned in terms of the teacher coach and new teacher 

mentor programs. While these initiatives would have been possible without Local Flex, state, 

school, and district officials all suggested that participation in the program allowed the district to 

more effectively develop plans and target funds toward reaching the district’s goals. This is 

especially useful in a time of tight budgets and declining program funds. 

Greater collaboration among district officials. Local Flex acted as an impetus to increased staff 

collaboration and cooperation at the district level. Prior to Local Flex, district administrators 

rarely communicated, because each administrator managed a specific set of funds and programs. 

Through participation in Local Flex, all of the eligible funds were combined and district officials 

were forced to discuss the use of Local Flex funds together rather than simply managing their 

own portion of funds. A district administrator described the development of a “professional 

community focused on outcomes for kids” as a direct consequence of Local Flex. 

Decreased administrative burdens allowed more focus on services. District representatives 

indicated that the consolidation of funds through Local Flex decreased administrative burdens 

and costs and allowed the district to focus on providing services to schools and students. For 

example, the district no longer had to submit an annual plan to the state about the use of eligible 

program funds. Seattle Public Schools officials also identified a streamlined financial tracking 

system as one of the potential benefits of Local Flex. The district already had a sophisticated 

financial tracking system in place, so Local Flex caused little or no change to the district’s 

financial record-keeping. 

Improved services and communication with public schools. From the perspective of public 

school representatives, on-site coaches and the new teacher-mentoring program were the most 

visible benefit for public schools. Public school representatives indicated that schools with onsite coaches experienced improved communication between the schools and the district, because 

the coach acted as a liaison with the district office. Some schools in more affluent areas had less 

involvement with the district, because they did not have on-site coaches. One school 

representative indicated that these schools received services as a result of Local Flex funds 

indirectly through training programs and when applicable through new teacher mentoring. 

Improved relationships with private schools. The relationship between the district and private 

schools improved markedly as a result of the district’s participation in Local Flex. The district 

used Local Flex funds to hire a private school liaison on the joint recommendation of the private 

schools and senior district leadership, giving private schools a clear point of contact in the 

district and eliminating the frustrations of having to consult with four or more different federal 
29

program managers in the district. The district crafted an umbrella form that tracked the 

combined dollar amount for all of the Local Flex eligible programs as opposed to separate 

documentation for each program. Private school representatives indicated that simplified 

reporting requirements in combination with greater flexibility in the use of the federal funds set 

aside for services for private school students and teachers. 

 Challenges and Untapped Potential of Local Flex 

The findings indicated that Seattle Public Schools’ experience implementing Local Flex was 

generally beneficial; however, district representatives identified a number of remaining 

challenges associated with the Local Flex demonstration program. In addition, case study 

respondents indicated that the district’s efforts remained a work in progress and identified a 

number of areas in which the potential benefits of Local Flex were not fully exploited. District 

representatives suggested that these additional benefits could be derived through additional years 

of participation in the program. 

Decreasing program funds. Over the last few years, Seattle Public Schools experienced a 

continual decrease in the amount of federal funding received under eligible programs, from $4.6 

million in 2002–03 to $4.0 million in 2005–06. This was combined with decreases in the overall 

budget that made funding decisions especially difficult. Limited funds prevented full 

implementation of all best practice–based initiatives. While Local Flex allowed program 

administrators to focus on the highest priorities within the district, the flexing of dollars also 

meant that funds for some best practices would have to be reduced. As one district official 

described it, “If we’re going to do something more with limited resources, then we also have to 

say, ‘We’re going to do something less.’” Thus, while district administrators appreciated the 

ability to flex federal funds, their actions were still limited by the total amount of funds available. 

District officials indicated that the problem was exacerbated in recent years as the amount of 

Local Flex funds has diminished.

Limited number of eligible federal programs. District officials indicated that they would like 

flexibility extended to other federal education funds. District representatives highlighted what 

they viewed as a significant shortcoming in Local Flex: the relatively small amount of funds 

available for reallocation. One Seattle Public Schools official said he wished that the district 

could use a greater percentage of federal funds as it wished because he believed the current 

federal funds were not the most meaningful ones for the district (these programs only represented 

a small portion of federal funds allocated to the district). Specifically, the set of programs from 

which a district may consolidate funds under Local Flex does not currently include Title I. This 

provision was viewed as a significant limitation by district officials on the flexibility offered by 

Local Flex, as it effectively excludes the majority of federally derived funding from reallocation. 

Several district and private school representatives expressed a desire that Title I funds be 

included in Local Flex. 

Difficulties overcoming tradition of categorical programs. While the Local Flex provisions 

required that the goals associated with the four programs still be met (and Seattle was clearly 

continuing to meet the intent of these programs), there was potential for Seattle to use Local Flex 

money to fund other educational strategies. District officials indicated that they were not fully 

taking advantage of the unique features that distinguish Local Flex from other flexibility 
30

measures, such as Transferability. In addition, the district had yet to take full advantage of the 

opportunity presented by Local Flex to integrate and streamline its staffing responsibilities. 

After the implementation of Local Flex, there was no longer a need for a district-level director 

for each of the affected programs. A district representative identified the difficulty in changing 

established programs and job positions as a contributing factor in Seattle’s decision to use Local 

Flex funds only for the original four programs. District representatives described the situation as 

a work in progress in which the district hoped to take full advantage of opportunities for 

collaboration and initiative development in the coming year. For example, one administrator 

now oversees some collaborative projects that previously had individual directors, effectively 

“breaking down silos” and allowing for consolidated, integrated use of funds. 

Limited communication with the public about Local Flex’s opportunities. Seattle Public 

Schools did not fully create community understanding of Local Flex and the district’s efforts to 

use it to reach NCLB’s goals. A district official viewed Local Flex as “a tremendously positive 

public relations, communications tool” because it could make the community aware of the 

district’s work to reduce achievement gaps. Furthermore, this representative explained that 

participation in Local Flex tells the community that the district is proactive in its efforts, 

“because this was [a] choice; we didn’t have to do this. We’re doing it for the right reasons. 

And the reason we’re doing it is to improve academic achievement and the purposes of not only 

No Child Left Behind but the flexibility that allows us to do it.” But, aside from making its 

annual Local Flex report available to the public, the district did little to inform the community. 

District representatives indicated that this represented a potential powerful untapped benefit of 

participating in Local Flex.

Short time horizon for success. District representatives expressed concern that they may not 

have enough time to take advantage of all the benefits of the program because the district faced 

the risk of losing Local Flex if the district did not achieve adequate yearly progress for two 

consecutive years. The district failed to meet 13 of 71 student performance targets in 2004–05 

and would be in danger of failing AYP again by missing any of those targets in the 2005–06 

school year. High levels of turnover in district leadership made the potentially short time for 

implementation even more difficult. District officials indicated that two years would not be 

enough time to implement the types of substantive changes made by possible by Local Flex. 

Representatives indicated that such change was especially difficult for a large district. From 

their perspective, it made little sense for a demonstration program to not have time to show the 

full benefits that flexibility can offer. 

Concluding Thoughts 

Seattle Public School’s participation in the Local Flex appeared to be a positive experience that 

led to thoughtful planning and implementation of programs targeted toward goals laid out in the 

plan. However, the short implementation period combined with a difficult budget situation have 

made it difficult for the district to fully take advantage of the new opportunities Local Flex 

offers. Yet, since implementation of the program there were clear improvements in collaboration 

within the district office and between the district and schools both public and private. As it is 

very closely coordinated with the district’s larger accountability effort, it is difficult to evaluate 

outcomes specifically attributable to Local Flex, but district officials saw the program as a useful 

tool to help the district reach its academic goals. 
31

Appendix A: Interview Instruments 

While this protocol represents a general framework that was used to guide conversations, 

discussions and questions were tailored for the specific recipients being interviewed including 

state representatives, district representatives, public and private school officials, to highlight their 

particular areas of expertise. Each category of officials interviewed contained fewer than nine 

respondents. 

CASE STUDY

SEATTLE PUBLIC SCHOOLS’ USE OF LOCAL FLEX

INTERVIEW WITH DISTRICT REPRESENTATIVE
32

Statement of Purpose 

The Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind 

Act (NCLB) of 2001, provides states and school districts with new types of flexibility in their use 

of federal resources in return for greater accountability. This case study examines the use of the 

new “Local Flex” demonstration program, which authorizes the secretary of education to enter 

into local flexibility agreements with up to 80 school districts. These districts may consolidate 

funds from up to four eligible programs to use for any educational purpose authorized under 

ESEA. The four programs are: 

Title II, Part A (Teacher and Principal Training and Recruiting) 

Title II, Part D (Enhancing Education Through Technology) 

Title IV, Part A (Safe and Drug-Free Schools and Communities) 

Title V, Part A (Innovative Programs) 

Funds consolidated under Local Flex are no longer bound by specific program requirements and 

may be used for any purpose or activity consistent with ESEA. In exchange for this increased 

flexibility, participating districts must develop a clear, detailed five-year plan of action that 

articulates their rationale for seeking enhanced flexibility authority, delineates a concrete strategy 

for the consolidation and utilization of affected federal resources, and presents a convincing case 

that these actions will serve to facilitate the attainment of specific educational goals. 

In November 2003, Seattle Public Schools was granted the Local Flex authority, the only district 

in the country to have that authority. A previous study identified a number of factors that 

contributed to low application rates6

 including competing priorities, limited organizational 

capacity, lack of information about Local Flex, an inability to distinguish the unique features of 

the various flexibility programs, and the perception that the costs of participation outweighed the 

benefits. However, these potential challenges did not prevent Seattle from successfully applying 

for this program. This case study examines Seattle’s experience with the Local Flex program, 

including both benefits and challenges that the district has experienced in implementing the 

program. 

Evaluation Questions 

1. Does Local Flex allow the district to better target federal funds to meet students’ needs? 

2. Does Local Flex facilitate initiatives or programs that the district has specified in its fiveyear plan? 

3. Since implementing Local Flex, what changes have occurred in district accounting, 

management roles and responsibilities, and the district’s relationships with private and 

public schools? 

4. How does the district balance the needs and requirements of flexibility while ensuring 

that the intent of federal programs included in the agreement is met? 

 

6

 In 2003, there was one applicant for State Flex and three applicants for Local Flex. 
33

 

Sample 

The majority of respondents will be district-level administrators or program officers involved in 

implementing the Local Flex program. We will also speak with representatives from public and 

private schools to explore how the relationship between schools and districts has evolved under 

Local Flex. Finally, we will speak with a state finance representative and the state federal 

programs coordinator. 

 
34

 Interview Protocol

Thank you for meeting with us today. I’m Gayle Christensen and this is Kathleen Feehan from 

the Urban Institute in Washington, D.C. We’re here on behalf of the U.S. Department of 

Education, which has commissioned the Urban Institute to conduct a case study of Seattle Public 

Schools’ experience implementing the Local Flex demonstration program, in order to provide 

other districts and states with information about the opportunities and challenges that have 

resulted from Seattle’s participation in Local Flex. 

Your responses provide extremely valuable information and we are pleased to have your 

participation. We would like to tape-record this interview to ensure that your responses are 

accurately recorded. We work very hard to keep all information you provide confidential and 

will not ever use your name in connection with your responses. To the greatest extent possible, 

we will not provide any individually identifying information in reporting your responses and 

avoid using specific titles when possible. While there is always a slight risk of participant 

identification in a case study of one, we will work hard to maintain strict confidentiality. We 

thank you in advance for providing the expertise and time needed for this case study. 

Respondent Background 

1. I would like to start by asking you about the work you do in your current position. Could 

you tell me about your roles and responsibilities in the district? 

 Probe if not offered: 

 ____ What is your current title? 

 ____ How long have you been in this position with Seattle Public Schools? 

 ____ What is your professional background? 

 ____ How long have you worked in the education field? 

 ____ What were your previous administrative or teaching positions? 

 ____ What is your specific role with Local Flex? 

2. Please think back to the time before Seattle Public Schools started using Local Flex. Did 

the district have certain constraints on the use of federal funds that prevented it from 

effectively addressing its educational priorities? Please describe. 

 

 Probe if not offered: 

 ____ Was the funding in particular programs inadequate for needs? 

 ____ Was the distribution of allocated funds across programs poorly aligned 

with educational needs? 

 ____ Did rules and regulations of particular federal programs impose 

significant restrictions that affected your district’s ability to meet its most 

important priorities? 
35

3. Could you describe the decision-making process that led to Seattle Public Schools adopting 

Local Flex? (NOTE: Only those who were at Seattle Public Schools when the process took 

place will be asked this question). 

 Probe if not offered: 

 ____ Who were the key actors and organizations involved in this process? 

 ____ As [respondent title], what was your role in this process? 

 ____ Did your district consult with local private schools when deciding whether 

and how to pursue Local Flex? 

 ____ How long did this deliberation process take? Was there sufficient time to 

investigate thoroughly before the deadline for notifying Washington’s 

SEA? 

Evaluation Question 1: Does Local Flex allow the district to better target 

federal funds to meet students’ needs? 

4. While the state does not have any oversight over Seattle Public Schools’ use of Local Flex, 

has your district had any communication about Local Flex with Washington’s state education 

agency (SEA), either at the time you were deciding whether to adopt Local Flex or after you 

decided to adopt Local Flex? Please describe. 

Probe if not offered: 

____ What was the nature of this dialogue? 

____ Would Seattle drawdown funds, how? 

____ Would Seattle report uses under the separate programs how? 

____ Would the state report uses of funds to ED? Please describe. 

____ While the state has (had) no authority to limit or restrict Seattle’s use of 

Local Flex, did the state raise issues or concerns about Seattle’s plan to 

use Local Flex? How did Seattle handle the state’s concerns? 

____ Did the state provide technical support or other assistance with preparing 

Seattle’s Local Flex application? 

5. Has Local Flex allowed Seattle Public Schools to better target federal funds to meet students’ 

needs? Please describe specific examples if possible. 

6. Are there challenges from Seattle Public Schools’ participation in Local Flex? Please 

describe. 

 Probe further if not offered: 

____ What are possible challenges from the district perspective? 

 ____ What might be challenges from the school perspective? 
36

____ What types of challenges (e.g. accounting or record keeping) has the 

district experienced? 

 ____ Were there challenges you did not anticipate? Please explain. 

 ____ Have there been challenges in terms of reporting activities that extend 

above and beyond those required under NCLB? 

7. How have you addressed these challenges and what were the results of these efforts? 

8. Are there benefits from Seattle Public Schools’ participation in Local Flex? Please describe. 

 

 Probe further if not offered: 

____ Information about the successes in initiating new districtwide programs or 

programs aimed at Tier I schools. 

 ____ Information on planning successes that may have allowed the district to 

better target funds to meet the needs of students. 

9. Is Local Flex meeting the district’s needs for additional flexibility in use of federal funds? 

 

 Probe further if not offered: 

 ____ If yes, how is Local Flex meeting the district’s needs? 

 ____ If no, what are the areas where the district would like additional 

flexibility? 

 

10. Have changes been made to the Local Flex Plan since the first year of implementation? 

 Probe further if not offered: 

____ What specific changes? 

11. Prior to using Local Flex, Seattle Public Schools used Transferability. Are there advantages 

or disadvantages for the district in comparing the two provisions? Please explain. 

 Probe further if not offered: 

____ Why was Local Flex chosen instead of just using Transferability? 

 ____ What are the benefits and costs for the district resulting from participation 

in Local Flex as compared to Transferability? 

 
37

Evaluation Question 2: Does Local Flex facilitate initiatives or programs that 

the district has specified in its five-year plan? 

12. Does Local Flex facilitate specific initiatives or programs that Seattle has specified in its 

five-year plan? Please explain. 

 Probe if not offered: 

____ What specific activities or programs are supported by the consolidated 

funding? 

13. Would these initiatives be possible without using Local Flex? Please explain. 

 Probe further if not offered: 

 ____ To what extent? 

 ____ Are there specific reforms (e.g. interventions, strategies) that Seattle 

Public Schools would not be able to carry out in the absence of Local 

Flex? Please describe. 

14. Does Local Flex aid or hinder Seattle in planning for its District Improvement Plan? 7 Please 

explain. 

 Probe further if not offered: 

 ____ Does your district find it easier to coordinate across programs because 

funds are not coming to the local education agency (LEA) in stovepipes? 

 ____ To what extent does Local Flex affect planning the district’s local 

improvement plan? 

15. How is Seattle tracking whether it is making progress toward meeting its long-term goals? 8 

Has the district achieved any interim progress indicators or benchmarks? 

 

7

 Goals for District Improvement as stated in Seattle Public Schools District Improvement Plan, 2005–07: 

1) Seattle Public School District will meet the AYP targets in reading and mathematics each year for all 

categories and grade levels that are assessed by the WASL. In the case where the AYP target is not met, the 

minimum goal is to achieve the “safe harbor” provisions (10 percent reduction in the number of students 

not meeting the standard). 

2) Seattle Public School District will continue to achieve AYP unexcused absence targets for schools with 

grades one to eight. 

3) Seattle Public School District will achieve AYP graduation rate targets for schools with grades 9 to 12. 
38

 Probe further if not offered: 

 ____ Can the district provide any data showing positive trends toward meeting 

these goals? 

16. Do changes in Washington’s state accountability system and the Congress’s No Child Left 

Behind requirements affect the district’s implementation of Local Flex? Please explain. 

 

 

Evaluation Question 3: Since implementing Local Flex, what changes have 

occurred in district accounting, management roles and responsibilities, and 

the district’s relationships with public and private schools? 

17. How does your district maintain financial records for documenting the way in which 

applicable funds are used under Local Flex? 

 Probe further if not offered: 

 ____ Are funds moved from one program account to another? 

 ____ Is a new separate account established for consolidated funds? 

 ____ Do consolidated funds remain in the original account but documentation 

is maintained to show how those funds have been reclassified? 

 ____ Other (please specify). 

18. What is your specific role with accounting and record keeping with respect to Local Flex? 

19. Are record keeping and reporting requirements different under Local Flex from what the 

district would be expected to do if it were not exercising Local Flex? If record keeping and 

reporting differ, did Seattle Public Schools encounter any challenges in meeting these 

requirements? Please describe. 

20. Has use of Local Flex changed public schools’ relationships with the district? Please 

describe. 

 8

 Seattle states its long-term goals for 2013-14 as follows: 

1) All students will reach or exceed state and district standards in reading and mathematics 

2) Elimination of gaps between groups in student achievement 

3) Decrease the unexcused absence rate to 1 percent 

4) Achieve a four-year graduation rate of 85 percent 
39

21. Has use of Local Flex changed private schools’ relationships with the district? Please 

describe. 

22. Has using Local Flex affected your work responsibilities?9 Please explain. 

 Probe if not offered: 

 ____ Has this allowed you extra flexibility in your specific program area?

Evaluation Question 4: How does the district balance the needs and 

requirements of flexibility while ensuring that the intent of federal programs 

included in the agreement is met? 

23. Has Seattle Public Schools been able to meet the intent of the NCLB programs included in the 

Local Flex agreement? Please explain. 

 Probe if not offered: 

 ____ What has the district done to ensure these program goals are met? 

24. Has using Local Flex affected your district’s use of other ESEA programs? Please describe. 

25. Has the district needed to balance competing priorities in choosing how to use Local Flex 

consolidated funds? Please describe. 

 Probe if not offered: 

 ____ Has Seattle Public Schools had to adapt to any new or more urgent 

priorities? Please describe. 

Conclusion 

26. From our understanding, previous district leadership advocated for educational flexibility. 

Have any changes in leadership affected district support for Local Flex? Please describe. 

27. Are there any other topics that we have not talked about that you think are important for 

understanding Seattle Public School’s experience using Local Flex? 

 

 

9

 This question is contingent on the person’s role and will be specific depending on whether we are speaking to a 

Title I representative, administrator, teacher, etc. 
40

 Probe if not offered: 

 ____ Are there unintended consequences—either positive or negative—as a 

result of using Local Flex (e.g., related to fund allocation, support for 

programmatic activities, or student, administration, and teacher 

outcomes)? 

Thank you very much for taking the time for this interview today. Your insights will be 

extremely helpful in our efforts to learn more about Local Flex. 
41
The Department of Education’s mission is to promote 

student achievement and preparation for global competitiveness 

by fostering educational excellence and ensuring equal access.

www.ed.gov