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 II—Transferability
Evaluation of Flexibility Under No Child Left Behind:

Volume II—Transferability 

Prepared by: 

Gayle S. Christensen 

Ary Amerikaner 

Daniel Klasik 

Devin Fernandes 

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: 

Evaluation of Flexibility Under No Child Left Behind: Volume II—Transferability, U.S. 

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

Program Studies Service, 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.
Contents 

List of Exhibits...............................................................................................................................v

Executive Summary.................................................................................................................... vii

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

Transferability................................................................................................................................. 1 

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

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

Who Uses Transferability: Characteristics of Users and Nonusers................................................ 7 

How Districts Use Transferability: Patterns of Exercising Flexibility ......................................... 12 

Administration of Transferability ......................................................................................... 12 

Patterns of Transferability Reallocation ............................................................................... 14 

Goals and Initiatives of Districts Using Transferability ....................................................... 16 

Progress Toward Goals Using Transferability...................................................................... 19 

The Decision to Use Transferability............................................................................................. 20 

Access to Information About Transferability ....................................................................... 20 

Reasons Districts Do Use Transferability............................................................................. 23 

Reasons Districts Do Not Use Transferability...................................................................... 24 

Increasing Interest in Transferability.................................................................................... 25 

4. Conclusion—Summary of Findings ...................................................................................27

Appendix A: Methodology ..........................................................................................................29

Survey Participants and Data Collection ...................................................................................... 29 

Case Study Participants................................................................................................................. 29 

Data Preparation............................................................................................................................ 30 

Analysis .................................................................................................................................. 31 

Appendix B: Data Tables with Standard Errors......................................................................33

Appendix C: District Survey.......................................................................................................39

Appendix D: Transferability Authority District Interview Protocols ....................................53

iii 
iv 
Exhibits 

Exhibit 1 Federal Programs Eligible for Transferability ........................................................... 2

Exhibit 2 State Education Agency and Local Education Agency Notification Checklist......... 3 

Exhibit 3 Usage Patterns of Transferability, Participants vs. Nonparticipants.......................... 8 

Exhibit 4 Comparison of Transferability, Participants vs. Nonparticipants, Based on 

Key Defining Variables ............................................................................................. 9 

Exhibit 5 Mean Revenue by Program, Transferability Participants vs. Nonparticipants........ 10 

Exhibit 6 Mean Priority Level of and Transferability Usage for Areas of 

Possible Need (1=Low Priority, 3=High Priority).................................................. 11 

Exhibit 7 Authority and Oversight of Transferability ............................................................. 12 

Exhibit 8 Difference in Use of Funds After Exercising Transferability.................................. 14 

Exhibit 9 Uses of Transferability............................................................................................. 17 

Exhibit 10 Familiarity With Federal Funding Flexibility Programs ......................................... 21 

Exhibit 11 Usefulness of Sources of Transferability Information............................................. 21 

Exhibit 12 Sources of Transferability Information Among Participants and 

Nonparticipants........................................................................................................ 22 

Exhibit 13 Percent of Respondents for Whom the Given Considerations Were a Major 

Influence on Their Decision Not to Use Transferability ......................................... 25 

Exhibit 14 Reaction to Potential Changes to the Terms of the Transferability Provision, Given 

as Percent of Respondents for Whom the Change Would Cause Their Interest in 

Transferability to Be Somewhat or Much Higher.................................................... 26

Exhibit A-1 Case Study Sample Selection: Number of Interviews by Category ........................ 30

Exhibit B-1 Usage Patterns of Transferability Participants vs. Nonparticipants......................... 33 

Exhibit B-2 Comparison of Transferability Participants vs. Nonparticipants Based on 

Key Defining Variables ........................................................................................... 33 

Exhibit B-3 Mean Revenue by Program, Transferability Participants vs. Nonparticipants........ 34 

Exhibit B-4 Mean Priority Level of and Transferability Usage for Areas of 

Possible Need (1=Low Priority, 3=High Priority)................................................. 35 

Exhibit B-5 Authority and Oversight of Transferability ............................................................. 36 

Exhibit B-6 Difference in Use of Funds After Exercising Transferability.................................. 36 

Exhibit B-7 Uses of Transferability............................................................................................. 37 

Exhibit B-8 Sources of Transferability Information, Participants and Nonparticipants ............. 37 

Exhibit B-9 Reaction to Potential Changes to the Terms of the Transferability Provision, Given 

as Percent of Respondents for Whom the Change Would Cause Their Interest in 

Transferability to Be Somewhat or Much Higher.................................................... 38

v 
vi 
Executive Summary 

Flexibility is a lever for change that occupies an increasingly prominent place in federal 

strategies for educational improvement. Although often implemented in complex ways, the basic 

logic underlying its approach can be summarized quite succinctly. Flexibility assumes that local 

actors are in the best position to identify the most serious problems facing schools and students 

and determine how to solve them. Consequently, these actors should be given greater decisionmaking authority to allocate resources, including federal funds, to the programs for which they 

will do the most good. 

The No Child Left Behind Act of 2001 (NCLB) provides additional flexibility to local school 

districts while simultaneously requiring increased accountability. This study focuses on the 

additional funding flexibility offered to all school districts via the Transferability provision of 

NCLB. Under Transferability, districts generally may transfer up to 50 percent of their initial 

formula allocations into and out of the following Elementary and Secondary Education Act 

(ESEA) programs: 

o Title II, Part A (Improving Teacher Quality State Grants) 

o Title II, Part D (Educational Technology State Grants) 

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

o Title V, Part A (State Grants for Innovative Programs). 

Furthermore, districts may move funds from the above-listed programs into, but not out of, 

Title I, Part A (Improving the Achievement of Disadvantaged Children). A district that has been 

identified for improvement may transfer no more than 30 percent of the formula funds allocated 

to it for a given fiscal year under each of the four programs listed above and the funds must be 

transferred either to its allocation under ESEA, Section 1003, or to one of the listed programs for 

improvement activities consistent with ESEA, Section 1116. Those districts identified for 

corrective action may not transfer any funds. 

The following five research questions guided the study: 

1) How many districts use Transferability? To what extent do districts make use of 

the various flexibility provisions in Transferability? What are the 

characteristics of school districts that exercise this authority? 

2) How are districts using Transferability and which programs are affected? 

3) What educational goals or objectives do districts choose to focus on with these 

funds? 

4) Do districts that exercise Transferability authority make progress in the areas or 

priorities toward which they targeted eligible funds? 

5) How well does Transferability meet the needs of school districts to effectively use 

federally derived educational funding? 

vii 
A nationally representative sample of school districts was surveyed in order to examine these 

questions, supplemented by case study interviews in a small subset of the districts. For questions 

4 and 5, the survey did not include outcome measures, so it is only possible to offer some 

preliminary findings related to these questions. A total of 372 districts responded to the survey, 

and 12 completed case study interviews. The data were collected between October 2005 and 

February 2006. There were five primary findings: 

1. Approximately 16 percent of all school districts reported using Transferability, but 

conflicts between district and state reports suggest there was considerable confusion 

about this option. 

2. Districts exercising Transferability and those not utilizing this type of flexibility were 

similar demographically. 

3. Under Transferability, Title I, Part A, and Title V, Part A, received the greatest influx of 

transferred funds while districts also moved more money out of Title II, Part A, than any 

other program. 

4. Districts reallocated funds under Transferability in order to make adequate yearly 

progress (AYP). 

5. Reduced funding and spending restrictions led many districts to use the Transferability 

provision, though not all. However, some districts did not participate in Transferability 

because of perceived adequate existing flexibility, the amount of eligible funds, and 

insufficient information about Transferability. 

There were conflicts in district and state reports about Transferability participation. 

Based on district reports, an estimated 16 percent of districts nationwide used the Transferability 

option, while state lists of Transferability participants indicate a slightly lower usage rate (12 

percent).1 District and state reports sometimes did not agree about whether a particular 

district was using Transferability. Among districts that reported using Transferability, about 10 

percent were not on the states’ lists of districts that had given notice of their intent to use the 

provision. Conversely, approximately 25 percent of districts on the states’ lists of Transferability 

users did not report actually using the provision. 

One might expect that these figures should not include REAP Flex eligible districts, because 

REAP Flex would give these rural districts even greater flexibility than Transferability. 

However, the state lists of Transferability participants indicated that 23 percent of districts 

reportedly participating in Transferability were also eligible for REAP Flex. As this makes up 

 

1

The standard error on the estimate for the rate of Transferability participation from the survey results was large, 

because there were a small number of districts that were not on the state lists but reported using Transferability and 

these districts ended up representing a large number of districts nationally. Weighted results from district surveys 

suggested that Transferability participation ranges between 12 percent and 21 percent of districts nationwide. 

viii 
such a large portion of Transferability participants, the Transferability survey was conducted in a 

sample that is representative of all school districts and not just those that were not eligible for 

REAP Flex. 

This suggests that states did not have accurate information about which districts were using 

Transferability. Some districts may have confused Transferability with other flexibility 

programs, did not know they needed to notify the state, or chose not to provide this notification. 

Also, states may not have asked for this information or kept accurate and up-to-date lists. 

Further, despite a statutory requirement that no more than half of funds allocated to any 

particular program can be moved, 21 percent of districts using Transferability reported that they 

moved more than 50 percent of funds out of at least one program. This may also indicate that 

some of the districts that indicated they were using Transferability were actually using REAP 

Flex. This is added confirmation of district confusion. 

While some districts did not have correct information about whether they were using 

Transferability and how they were allowed to use it, the information that they did have came 

primarily from the state. The vast majority of districts that used Transferability, 86 percent, 

looked to their state education agencies for guidance on the provision’s rules and regulations. 

Significantly fewer nonparticipants, 57 percent, obtained information from the state, implying 

that some states were not getting Transferability information out to the districts not already using 

the program, or that some states did not have a notification system in place. 

Transferability users and nonusers were similar demographically. 

There were no significant differences between users and non-users in terms of size, poverty 

level, percent federal funding, percent Transferability-eligible funding, or revenue per student. 

Given these financial similarities, it is not surprising that both Transferability users and nonusers 

justified their decision regarding participation in the program by saying that their districts were 

experiencing reductions in overall funding. The reduced revenue led some officials to employ 

Transferability in order to continue to fund high priority programs. For others, the reduced 

funding made the provision an implausible option because they did not have enough money to 

pay for current programs, much less enough to move money out of any NCLB programs. 

Under Transferability, Title I, Part A, and Title V, Part A, received the greatest influx of funds 

while districts moved more money out of Title II, Part A, than any other program. 

 

Per student funding of Title V, Part A, increased by an average of 134 percent under 

Transferability, while the somewhat larger dollar per student shift to Title I, Part A, represented 

only a 3 percent increase from the overall initial allocation. The program with the greatest 

reduction of funds was Title II, Part A, Improving Teacher Quality. After exercising 

Transferability, this program saw an average 21 percent decrease in per student funding. 

Money moved under Transferability was focused on initiatives aimed at making AYP. 

Most districts using Transferability (87 percent) reallocated money so that high priority 

programs, such as those focused on the goals listed above, would receive more funding. In a free 

ix 
response section on the survey, researchers found that improving teacher quality was the most 

common goal associated with the reallocated funds (43 percent of respondents). Other common 

goals included increased focus on Title I students, technology, math, and literacy. These pieces 

were often all part of the same districts’ responses—in other words, even though each goal is 

important alone, they are not to be thought of as separate from one another. Together, they make 

up one larger goal for survey respondents—making AYP. 

District officials believed that Transferability was helpful in working toward those goals, 

although they hesitated to draw strong causal relationships between the program and student 

achievement. This is understandable. Not enough time has accrued to gather sufficient data, 

and, even then, it would be difficult to separate the effects of the program from other factors. 

Many interviewees pointed out that while the added flexibility does help, most of the goals and 

activities would be the same with or without Transferability.

Reduced funding and spending restrictions led many districts to use the provision. However, 

existing adequate flexibility, the amount of eligible funds, and inadequate information were 

the three primary reasons districts did not participate in Transferability.

Another common reason for utilizing Transferability was that some federal education programs 

place more restrictions on how money can be spent than others. Some districts saw 

Transferability as an option to move funding from a more restrictive program like Title IV, 

Part A, to a less restrictive one like Title I. 

The top three responses for why districts did not use Transferability were: 

• 44 percent of districts believed they already had enough flexibility over use of funds 

without Transferability. 

• 35 percent of districts believed that the amount of funds in applicable categories would 

have been too small to carry out desired activities effectively even after exercising the 

Transferability option. 

• 29 percent of districts did not have enough information or were not aware of 

Transferability. 

Beyond providing additional funds via Transferability, which is outside the scope of flexibility 

programs, the most popular change posed on the survey was to remove the stipulation that 

transferred funds be subject to all of the rules and requirements of the recipient program. 

Combined, these findings suggest that the Transferability provision was generally liked by those 

districts that both understand and use it, but that many districts who might benefit from the 

program did not use it because of a lack of information and a belief that the amount of eligible 

funds is too small to make a real difference. 

x 
1. Introduction

Transferability 

One of the broadest forms of flexibility introduced in NCLB is the Transferability authority. 

Transferability allows state education agencies to transfer up to 50 percent of a fiscal year’s 

nonadministrative funds allocated for state-level activities under certain programs. Similarly, the 

Transferability authority allows local education agencies generally to transfer up to 50 percent of 

the formula funds allocated to certain federal programs in order to address local priorities. (The 

amount available for transfer decreases to 30 percent of formula allocated funds for districts 

designated for improvement (and the transferred funds must be used for LEA improvement 

activities), while districts identified for corrective action may not exercise Transferability.) The 

Transferability authority also improves upon earlier flexibility initiatives by imposing fewer 

participation barriers on states and districts. Although no additional resources are made available 

to states and districts using the authority, the enhanced flexibility under the Transferability 

authority enables them to redirect a potentially large sum of existing federal funds to different 

programs with the assumption that reallocation of funds to high priority areas will help 

participants make adequate yearly progress (AYP). 

A list of federal program funds eligible under the Transferability provisions appears in Exhibit 1. 

There are certain limitations placed on this authority. Funds can be transferred into but not out 

of Title I, Part A, programs. State education agencies (SEAs) may transfer only 

nonadministrative funds associated with state-level activities (although flexibility over 

administrative funds is authorized under Title IX of ESEA), while local education agencies 

(LEAs) may transfer only federal funds allocated on a formula basis (and, as noted above, there 

are further restrictions for districts identified for improvement or corrective action). 

1 
Exhibit 1 

Federal Programs Eligible for Transferability 

SEA 

Transferability

LEA 

Transferability

Funding Category From To From To 

Title I, Part A 

Improving the Achievement of Disadvantaged 

Children 

X X

Title II, Part A 

Improving Teacher Quality State Grants X X X X

Title II, Part D 

Educational Technology State Grants X X X X

Title IV, Part A 

Safe and Drug-Free Schools and Communities X X X X

Title IV, Part B 

21st-Century Community Learning Centers X X

Title V, Part A 

State Grants for Innovative Programs X X X X

Exhibit reads: Both states and districts may transfer funds into but not out of Title I, Part A. 

Source: http://www.ed.gov/programs/transferability/finalsummary04.doc. June 2006. 

Transferred funds are subject to the rules and requirements (including set-asides) of the programs 

to which they have been redirected. Many of the federal programs require local districts to setaside a certain percentage of allocated funds for special uses and transferred funds are not 

exempt from the calculations. For example, 25 percent of the formula funds a district receives 

under Title II, Part D, must be set-aside for professional development activities. Therefore, 25 

percent of incoming funds under Transferability authority must also go to professional 

development activities. At the same time, districts reduce the base for determining set-asides 

when transferring funds out of a particular program. 

While there are limitations on the use of Transferability authority, participation is relatively 

simple. There is no application process that might discourage potential users. District eligibility 

is automatic and can only be affected by consistent failures to make AYP. For example, districts 

that have not made AYP for two consecutive years and are identified as in need of improvement 

cannot transfer more than 30 percent of formula funds from eligible programs. Furthermore, 

they must use this money to support district improvement efforts. School districts that have been 

identified for corrective action may not exercise the Transferability option. As with districts, 

states also enjoy automatic eligibility but are not subject to the 30 percent rule nor are they 

prohibited from using the program if they do not meet accountability requirements for a certain 

amount of time. 

Additionally, there are only minor administrative requirements for states and districts that wish 

to use the Transferability authority. First, districts must consult with area private school officials 

in order to satisfy equitable participation provisions specified under Section 9501 of ESEA. The 

equitable participation provisions require that districts receiving federal funds provide equitable 

services and benefits to eligible students and teachers at private schools. Because changes in the 

2 
use of federal funds under Transferability may have an impact on current services and benefits 

offered within the district, private school officials must be consulted before any decision on 

transfers are made. Second, states and districts are required to notify the appropriate agencies of 

their transfer decisions at least 30 days in advance with a detailed plan of the amounts to be 

transferred, the programs involved, and the dates for transfer. For states, the appropriate agency 

to notify is the U.S. Department of Education. Districts, on the other hand, report to their state 

education agency (see Exhibit 2). Any and all changes with regard to the transfer notices require 

their resubmission 30 days before any new transfers are to be made. If decisions to transfer 

funds (including any subsequent changes to those decisions) impact state or local education 

plans, the revised transfer notices must include updated versions of these documents as well. 

Exhibit 2 

State Education Agency and Local Education Agency Notification Checklist 

Source: “Guidance on Transferability Authority,” U.S. Department of Education, June 8, 2004. Available 

online at: http://www.ed.gov/programs/transferability/finalsummary04.doc. Accessed March 2006. 

An SEA must notify the U.S. Department of Education of: 

 The program(s) from which funds are to be transferred; 

 The amount, and federal fiscal year, of funds to be transferred; 

 The program(s) to which the funds will be transferred; 

 The effective date for the transfer; and 

 A point of contact for the transferability authority. 

An LEA must notify its SEA of: 

 The program(s) from which funds are to be transferred and to which funds 

will be transferred; 

 The amount, and federal fiscal year, of funds to be transferred (subject to 

the 50 percent or 30 percent limitation); 

 The program(s) to which the funds will be transferred; and 

 The effective date for the transfer. 

The Transferability authority offers extensive flexibility to local education systems. Moreover, it 

also has the potential to engender widespread participation across districts and states by forgoing 

applications and imposing few administrative burdens on users. However, according to 

information gathered from all 50 states and the District of Columbia, 12 percent of districts 

(1,834 districts) had notified their state of plans to take advantage of Transferability. This 

number would be similar if REAP Flex eligible districts were not included in the estimate (see 

below). 

As part of a larger study of federal flexibility programs, the U.S. Department of Education 

commissioned the Urban Institute to conduct a study of Transferability authority at the district 

level. This included collecting nationally representative survey data and conducting a series of 

3 
case studies of districts eligible to use Transferability. Five research questions guided the larger 

study of flexibility, as well as this report, which focuses on Transferability: 

• Question 1: Use of Transferability and Characteristics of Users 

How many districts use Transferability? To what extent do districts make use of the 

various flexibility provisions in Transferability? What are the characteristics of school 

districts that exercise this authority? 

• Question 2: Patterns of Exercising Transferability 

How are districts using Transferability exercising this flexibility and which programs are 

affected? 

• Question 3: Strategic Planning for Flexibility 

What educational goals or objectives do districts choose to focus on with these funds? 

• Question 4: Transferability Progress 

Do districts that exercise Transferability authority make progress in the areas or priorities 

toward which they targeted eligible funds? 

• Question 5: Flexibility Needs 

How well does Transferability meet the needs of school districts to effectively use federal 

educational funding? 

4 
2. Methodological Design 

Survey and interview data2 provided a description of Transferability program participants, 

nonparticipants, and uses of Transferability. The data were collected between October 2005 and 

February 2006. Surveys sent to districts nationwide generated the quantitative data (see 

Appendix C for the survey instrument). The survey response rate was 86 percent, with 320 of 

372 districts completing the survey. Interviews with survey respondents, eight Transferability 

users and four nonusers, supplied the qualitative data (see Appendix D for interview protocols). 

The sample of districts surveyed was selected from lists provided by states. The state lists 

indicated that 23 percent of Transferability participants were REAP Flex eligible. This was 

surprising, because REAP Flex offers rural districts even greater flexibility. As a result, these 

districts were included in the sample, in order to have a representative sample of Transferability 

participants.3 Each state identified the districts that had notified the state of intent to use 

Transferability. These lists were used to draw an equal number of users and nonusers of 

Transferability to participate in the study. 

Based on the state lists and district survey responses, most districts could be assigned to one of 

two groups: districts that the states listed as Transferability users and that reported using 

Transferability on the survey; and districts that the states did not list as intending to use 

Transferability and did not report using Transferability. That is, these districts provided data that 

agreed with state identification of Transferability status. 

There were 50 respondents from our sample of 372 districts that did not fall clearly into either 

the user or nonuser category because the state lists and district survey responses did not coincide. 

There were 12 districts that reported they were users, but the state lists did not include them. The 

other 38 were included in the state list of users, but claimed to be nonusers. 

The 12 districts that were listed as nonusers by their state but reported themselves to be users in 

their surveys, posed a potential significant analytic problem. The sample was selected on the 

basis of the state lists.4

 Because nonusers far outnumbered users (13,931 vs. 1,834), nonusers 

were selected with a much lower probability. Thus, the 12 districts, presumed to be nonusers at 

the time of sampling, were selected with a low probability. If the original probability of 

selection is used to determine the weight for these districts, they would account for a large share 

of the total weight in the analysis. As a consequence, this relatively small part of the sample 

would have a disproportionately large influence on the final estimates. However, a disadvantage 

of excluding districts that did not correspond to state lists would be that the results presented 

would not be nationally representative. 

 

2

 Full description of methodological design can be found in Appendix A and exhibits with standard errors may be 

found in Appendix B. 

3

 Initially, it was expected that REAP Flex eligible districts would not use Transferability and could be excluded 

from the sample, because REAP Flex offers these districts an even higher level of flexibility. 4

 These twelve districts were drawn from a sampling frame of 13,931 districts. The other 116 users were drawn 

from a sampling frame of 1,834 districts. 

5 
As a result, the quantitative analysis used adjusted weights to allow for a representative sample 

while limiting the variance that would be introduced by using a full sample weight. In this 

method of weighting, the proportion of the total weight assigned to districts incorrectly identified 

as nonusers was adjusted to reduce the mean squared error of the results.5

 The proportion of the 

weight that minimized the mean squared error varied by survey question. The median of the 

proportions that minimized the mean squared error across key survey items was 28.75 percent of 

the weight.6

 These results are also presented in Appendix B. When fully or adjusted weighted 

results differed from those reported in the body, it is noted. Additional analysis using full 

weights and only the districts that corresponded to state lists did not lead to substantive changes 

in the results. 

 

5

 This term reflects a tradeoff between the bias created by assigning any weight other than the full weight to the data 

and the increase in variance caused by assigning a sample weight. 

6

 See Appendix A for a full discussion of the derivation of this proportion. 

6 
3. Results 

Who Uses Transferability: Characteristics of Users and Nonusers 

States did not always have accurate information about the districts using Transferability, and 

some districts were confused about the names of different flexibility programs. 

As reported above, there was substantial discrepancy between the state lists of districts using 

Transferability and district survey responses. Of the 154 district respondents that states indicated 

were users, only 116 reported using Transferability. Similarly, 12 of the 162 state identified 

nonusers appeared to actually use Transferability. This indicated that states did not have 

accurate information about which districts would be using Transferability. There was confusion 

on the part of both the districts and the states. Districts’ status may not have corresponded with 

state lists because districts did not realize they were using a different flexibility program, did not 

know they needed to notify the state, or because districts knowingly chose not to notify the state. 

This widespread confusion is perhaps the most salient finding of the report. Districts often did 

not know what the provision was, how they could use it, or even whether they were currently 

using it. States provided inaccurate lists of which districts were using the provision, despite the 

finding that states were the most useful source of information for districts about the program. 

One implication of discovering this confusion is that while state lists indicated that only 12 

percent of all districts were participating in Transferability, there is a possibility that substantially 

more districts are using the provision. Roughly 10 percent of districts that indicated they 

participated in Transferability were not on the states’ lists of identified users. Conversely, 

approximately 25 percent of district respondents that were on states’ lists as “users” indicated 

that they did not participate in the program. Weighted results suggested that 1,683 to 2,949 

districts, or between 12 percent and 21 percent of all districts nationwide, used Transferability. 

This was slightly more than state data predicted, but it is important to note that this range is 

influenced by the 12 heavily weighted districts originally identified as nonusers by their states 

and was based on a small sample size. 

One might expect that these figures should not include REAP Flex eligible districts, because 

REAP Flex would give these districts even greater flexibility than Transferability. REAP Flex is 

a program for rural school districts, which allows 100 percent of funding in applicable programs 

to be used for any activity authorized in one or more of the applicable ESEA programs, without 

regard to statutory set-asides. As result, it would make sense for eligible districts to take 

advantage of this program, however, state lists of Transferability participants indicated that 23 

percent of districts participating in Transferability were eligible for REAP Flex. If these districts 

had not been included, the state lists indicated that 11 percent of districts nationwide used 

Transferability. If REAP Flex districts had also been omitted from the survey results, weighted 

results would suggest that between 13 percent and 21 percent of non-REAP Flex eligible districts 

used Transferability. This again heavily weighted by districts originally identified as 

nonparticipants by their states. 

7 
Transferability participants planned to use the program for multiple years, and a large 

percentage of nonparticipants indicated plans to exercise Transferability in the future. 

The group of Transferability users was relatively stable: of the Transferability participants in the 

study, 83 percent had used Transferability prior to 2004–05 and 74 percent of them planned to 

use it again in 2005–06 (see Exhibit 3). In contrast, only 11 percent of nonusers had previously 

taken advantage of Transferability provisions. This is significantly less than the 84 percent of 

users that had previously participated in the program (standard errors for all results can be found 

in appendix tables). Past use of Transferability was a good indicator of future use, although this 

was not the case for all districts. A substantial group of nonusers, 59 percent, reported that they 

were planning on using Transferability in 2005–06. This large number of potential future users 

could be interpreted in many ways. It is possible that these districts were anticipating changes in 

their budgets and felt that they would need to use Transferability to compensate. It is also 

possible that participation in the survey made them more aware of the program, and thus 

increased their interest in Transferability. 

Exhibit 3 

Usage Patterns of Transferability, Participants vs. Nonparticipants 

Transferability 

Participants

Transferability

Nonparticipants

Used Transferability Prior to 2004–05 83%* 11%*

Planned to use Transferability in 2005–06 74%* 59%*

Exhibit reads: Among current Transferability users, 83 percent participated in Transferability

in previous school years and 74 percent planned on using it in 2005–06. 

Note: Statistically significant differences indicated with asterisks (p<.01). See Exhibit B-1 for

standard errors. 

Source: District Administrator Survey # 8, 9, 22, and 23.

There are not significant differences between users and nonusers in terms of poverty or the 

amount of federal program funds received. 

In order to better understand what differentiates districts that took advantage of Transferability 

from those that did not, districts were compared to each other using basic descriptive variables 

(see Exhibit 4). The percentage of students living in poverty in Transferability districts was, on 

average, higher than that in non-Transferability districts; however, the difference was not 

statistically significant. In addition, the average daily attendance was 285 students higher among 

Transferability participants, but this difference was not statistically significant. The differences 

between participants and nonparticipants in the percentage of federal funds and Transferabilityeligible funds were very small and also did not reach statistical significance. Districts that used 

Transferability had, on average, 0.2 percent more Transferability-eligible funds (from Title II, 

Part A, Title II, Part D, Title IV, Part A, and Title V, Part A) than districts that did not use 

Transferability. Interestingly, even though Transferability participants seemed to have more 

Transferability-eligible funding, non-Transferability districts appeared to have slightly more total 

federal funding as a percentage of their total revenue, although the difference was less than 1 

percent of districts’ total revenue. 

8 
Exhibit 4 

Comparison of Transferability, Participants vs. Nonparticipants, Based on Key Defining 

Variables 

b

 Percent total revenue from federal, state, and local sources (based on 2003 Common Core of Data).

d

 Based on 2003 CCD data.

Difference Between 

Participants and

Nonparticipants

Transferability 

Participants

Transferability 

Nonparticipants

a

 Based on the percent of school age children in the district living below the poverty line (2000 Census data).

c

 Percent total revenue from federal, state, and local sources (not counting Title I, Part A).

Percent Povertya

Percent Federal Fundingb

Percent Eligible Fundingc

Average Daily Attendanced

 15.0% 14.5% 0.5%

3,461 3,176 285

 8.0% 9.8% -1.8%

 1.1% 0.9% 0.3%*

Exhibit reads: Participants had 0.3 percent more Transferability-eligible funding on average than nonparticipants. 

Note: Statistically significant differences indicated with asterisks (p<.05). Differences between participants and 

nonparticipants reflect rounding. 

Source: District Administrator Survey #10, 11, 12, 18, 19, 20 and data sources cited above. 

Financial information provided by districts regarding the per-pupil funding amounts in 

Transferability-eligible programs yielded differences between Transferability users and 

nonusers. Once again, these differences were not statistically significant for any programs, 

except Title IV, Part A, in which participants had significantly higher per pupil funding. Overall, 

Transferability participants received slightly more money per student in all of the eligible 

programs, however, participating districts had less per student total revenue than nonparticipants 

(see Exhibit 5). Total revenue per student included funds from federal, state, and local sources. 

9 
Exhibit 5 

Mean Revenue by Program, Transferability Participants vs. Nonparticipants 

Funding Category

Transferability Participants Transferability 

Nonparticipants

Title I, Part A

Improving the Achievement of Disadvantaged Children

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

Title V, Part A

State Grants for Innovative Programs

Total Revenue

From All Sources

$ 8.85

$ 312.77

$ 71.37

$ 12.76

 $ 10.16*

(in dollars)

Mean Allocation Per Student for 2004–05 

$ 9,983.29

$ 248.57

$ 59.63

$ 9.21

 $ 6.53*

$ 6.04

$ 10,460.38

Exhibit reads: Transferability participants received an average of $312.77 per student in Title I, Part A 

funds. 

Note: Statistically significant differences are indicated by asterisks (p<.05). 

Source: District Administrator Survey #10, 11, 19, and 20. 

One area where users and nonusers showed significant differences was in the relative priority 

level they assigned to various areas of potential need (see Exhibit 6). Specifically, users 

assigned a significantly higher priority on English and language arts outcomes, as well as on the 

outcomes of both elementary and middle school students. While districts participating in 

Transferability indicated placing higher priority on these areas, nonparticipating districts also 

indicated that these were relatively important. On a three point priority scale with three 

indicating high priority, the average priority level for districts not using Transferability was 

above two in all three areas. However, participating districts still reported a greater need to 

improve in these areas than nonparticipating districts. While there were also areas (such as 

summer programs) where it appeared Transferability users gave lower priority than nonusers, 

these results were not statistically significant. 

10 
Exhibit 6 

Mean Priority Level of and Transferability Usage for Areas of Possible Need 

 (1=Low Priority, 3=High Priority) 

Transferability 

Participants

Transferability 

Nonparticipants

Participants 

Who Used 

Transferability 

to Address Need

Instruction

Support for Special Programs and Services

Performance on Specific Academic Outcomes

Performance of Specific Student Groups

Highly qualified teachers 2.2 2.1 30%

Highly qualified paraprofessionals 2.0 2.0 18%

Curriculum and instructional materials 2.4 2.5 39%

Educational technology 2.5 2.6 45%

Extended-time programs 2.1 2.2 22%

Summer Programs 2.0 2.2 16%

Supplemental educational services (SES) provided under 

Title I 1.7 1.9 17%

Transportation for Title I school choice participants 1.2 1.3 4%

English/Language Arts 2.7* 2.6* 64%

Mathematics 2.7 2.6 45%

Science 2.2 2.4 17%

Attendance rates 1.8 1.9 9%

Graduation rates 1.9 1.9 15%

Other 0.3 0.3 11%

Racial and ethnic minorities 2.0 2.1 34%

Low-income students 2.6 2.5 62%

Students with disabilities 2.4 2.6 35%

Limited English Proficient (LEP) students 1.8 1.9 24%

Students in low-performing schools 1.8 1.8 30%

Kindergarten and pre-K students 2.1 2.2 25%

Elementary students 2.6* 2.3* 69%

Middle school students 2.5* 2.2* 53%

High school students 2.3 2.1 39%

Exhibit reads: Participants gave performance on English or language arts outcomes an average priority rating of 2.7 

while nonparticipants gave the same area an average priority rating of 2.6. 

Note: Asterisked text indicates statistically significant differences between participants and nonparticipants (p<.05). 

Source: District Administrator Survey #14 and 21. 

These priorities corresponded with the spending patterns of districts participating in 

Transferability. A high proportion of districts reported using Transferability to address the needs 

of elementary students (69 percent). The second and fourth greatest percentages of districts used 

11 
Transferability to target English and language arts outcomes (64 percent) and middle school 

students (53 percent) respectively.

7

How Districts Use Transferability: Patterns of Exercising Flexibility 

Administration of Transferability 

Superintendents and federal program administrators were most likely to decide which funds to 

transfer under Transferability, but the process was generally one of collaboration with many 

people. 

Seventy-one percent of districts cited superintendents as primary actors in the decision-making 

process, and nearly as many districts (73 percent) identified general federal program 

administrators (districts could select multiple responses). There was more variety in which actor 

managed and oversaw the use of Transferability than in the decision-making process. 

Superintendents reportedly handled this in 57 percent of districts, while 57 percent of financial 

officers and 75 percent of federal program officers in participating districts did so (see 

Exhibit 7). 

Exhibit 7 

Authority and Oversight of Transferability 

13% 14%

28%

71%

41%

14%

73% 80.4%

8.9%

57%

16%

26%

4%

57%

0%

10%

20%

30%

40%

50%

60%

70%

80%

Superintendent School Board Financial officer General

administrator for

all federal

programs

Administrators

for individual

federal programs

Administrator

assigned

specifically to

manage

Transferability

Other

District Entity

Percent of Districts

Decides which funds to use Management or Oversight

Exhibit reads: In 71 percent of districts that use Transferability, superintendents decide which funds to use with 

the program. In 57 percent of districts, superintendents carry out management or oversight of the Transferability 

program. 

Note: Percentages do not sum to 100 because districts could mark multiple responses. 

Source: District Administrator Survey #15 

 

7

 The third most common area for districts to use their Transferability money was for low-income students. 

Transferability districts gave a higher average priority to this area than non-Transferability districts, but this 

difference was not significant. 

12 
Such high rates of involvement among various district officials suggest that the administration of 

Transferability is a largely collaborative process. Several follow-up interviews with district 

officials illustrated this point. When asked who decided where to direct funds under 

Transferability, one federal programs administrator explained: 

It was the administration team: superintendent, the ... Title I director, federal 

projects director (myself), curriculum, principals. ... We go through a school 

planning process in this district and... we use that as sort of our guideline to how 

the funds are going to be allocated. 

This was not a unique response. District officials frequently noted how Transferability decisions 

were made during budget planning meetings with several other officials present. This way, 

officials could talk through budgetary needs together and then figure out the most effective way 

to redirect funds. In addition, some officials noted how the complexity of budget rules made 

collaboration necessary. Those in leadership positions needed administrators with technical 

knowledge of rules and regulations, including those that govern Transferability, to help explain 

budgeting options. At the same time, one administrator noted how budget reporting software 

programs have made Transferability much easier to manage. The E-Grant system, which 

districts used to report their finances to the state, provided a Transferability worksheet page that 

walks users through their transfer options: 

[The E-Grant system] will let you know program-by-program how much you can 

transfer and into which programs you could transfer if you chose to do it. So, it 

even helps you by making all those calculations for you in advance, letting you 

know what really you have available to transfer from one program to the other. 

Even with the assistance of sophisticated software, districts typically made Transferability 

decisions through collaborative processes. 

Federal programs administrators and superintendents shared the primary management and 

oversight duties associated with Transferability. 

The pattern of joint decision-making carried over to management and oversight duties related to 

Transferability. As noted above, financial officers played a larger role in this aspect of 

Transferability. However, interviews suggested that superintendents and federal program 

coordinators maintained major roles in the process. They still filed reports and oversaw budgets 

to ensure that finances were in order, including those related to Transferability. “As we do our 

quarterly reports and such, we make sure that the reports are matching what we anticipated for 

Transferability,” one federal programs coordinator explained. Thus, while financial officers and 

business managers played an increasing management role (filling out and maintaining paperwork 

including the E-Grant forms and communicating with state officials), they still reported 

collaboration with other entities. 

Although the complexity of the Transferability provision led to a high level of collaboration, it 

was not a process that added a large amount of time or energy to the budget preparation process. 

A federal programs coordinator tried to put oversight responsibilities into some perspective: “To 

13 
give you an idea, I’m working on my seventh revision of my budget for Title I, so, you know, 

Transferability is just minor.” 

Overall, superintendents guided the administration of Transferability, but included many other 

people in the process. While technically complicated, district officials do not report spending 

substantially more time or resources on the program than they would spend on budgeting without 

Transferability. 

Patterns of Transferability Reallocation 

Over half of districts using Transferability moved at least 80 percent of the amount available for 

transfer out of one or more programs. On the other hand, only 9 percent of districts using the 

program transferred less than 20 percent of eligible funds out of a program. These findings 

indicated that many districts used the provision to provide substantive changes in funding 

allocations, as opposed to simply taking a small amount of money from one program to cover an 

unexpected expense in another program. 

Exhibit 8 

Difference in Use of Funds After Exercising Transferability 

Funding Category

Title I, Part A

Improving the Achievement of Disadvantaged Children

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

Title V, Part A

State Grants for Innovative Programs

 $ 8.44 134%

 $ 0.06 12%

-$ 2.42 -25%

 $ 10.80 3%

-$ 17.13 -21%

Mean Movement of 

Funds 

(in dollars per student)

Percent Difference 

from Initial 

Allocation

Exhibit reads: Districts moved an average of $10.80 per student into Title I, Part A. 

Note: Negative numbers indicate that, on average, more money was moved out of a program than moved into that 

program. Five districts reported using Transferability incorrectly by removing 100 percent of their funds out of Title 

1, Part A, and were therefore excluded from the above calculations. 

Source: District Administrator Survey #18.

Under Transferability, Title I, Part A, and Title V, Part A, received the greatest influx of 

shifted funds with an average increase of more than $8 per student.8

 

Per student funding for Title V, Part A, increased by an average of 134 percent under 

Transferability, while the somewhat larger dollar per student shift to Title I, Part A, represented 

 

8

 All calculations in this section are calculated in terms of funds per student. This was done in order to facilitate 

comparison across districts of varied sizes. 

14 
only a 3 percent increase from the overall initial allocation. The program with the greatest 

reduction of funds was Title II, Part A, Improving Teacher Quality. After exercising 

Transferability, this program saw an average decrease of $17 per student, representing a 

21 percent decrease in per student funding. Title IV, Part A, Safe and Drug Free Schools also 

realized a decrease in funds, while Title I, Part A, and Title II, Part D, had average increases. (It 

is important to note that funds may not be transferred out of Title I, Part A. See Exhibit 8 for a 

complete list of average monetary changes after using Transferability.) 

The case studies helped to elucidate district’s reasoning behind their choices about monetary 

shifts using Transferability. Many of the district officials interviewed indicated that their 

districts followed the trend in the survey and allocated funds to Title V, Part A, for Innovative 

Programs. Because this program has the most internal flexibility of the Title programs, district 

officials chose to put funds there to target their district’s needs through the flexible options of 

Title V, Part A. When explaining the decision to increase funds in Innovative Programs, one 

district official said, “There was more room for what you could use [funding] for in Title V.” 

Another district official indicated that more funding in Title V helped to create programs that 

would have been impossible to fund without using Transferability. In that district, increased 

funding in Innovative Programs was used to hire “classroom literacy aides for a particular school 

to go in and work with children that are struggling in their regular classroom instruction in 

reading and in language arts.” 

Districts using Transferability moved more money out of Title II, Part A, than any other 

program. 

The interviewed district officials illustrated the reasoning behind districts’ choice to reallocate 

funds away from Title II, Part A, Improving Teacher Quality. Several of the case study 

participants supported the survey findings. One district official explained that there had been 

carryover funding in past years from Title II, Part A, and because the district did not always use 

all of the Teacher Quality funds, the district chose to shift those funds into Title I. This district 

official did not see any decrease in the amount of professional development under Title II, but 

indicated that the district was more careful when approving external staff development. Another 

district made a transfer from Title II, Part A, to Title II, Part D, to improve technology and also 

indicated that the district was able to maintain staff development. 

Many districts also chose to transfer funds into Title I, Part A. 

Because this program is typically the largest federal allocation to a school, percentage increase in 

the program was fairly low at 3.43 percent. But the per-pupil mean increase of $10.80 was the 

highest per pupil increase, and, given the size of a median district, represented an approximately 

$12,150 shift in terms of this example district. Free response data from the surveys suggested 

that transfers were made in order to smooth funding, with several districts indicating that a 

decrease in Title I funds led to the choice to reallocate funds back to this program. These 

districts often indicated that their highest priority was to reach or maintain AYP and to do so 

they transferred money into Title I in order to help schools with large numbers of students who 

15 
were not reaching proficiency. One district official explained: 

Our priority goals are to improve math and literacy test scores. We transfer to 

Title I, Part A, from programs that have very few dollars allocated. This 

concentrates enough funds to hire highly qualified paraprofessionals and specific 

instructional materials. We target the male population and economically 

disadvantaged students because of their lower test scores.

Other districts also used language like “targeted assistance” and “increase reading scores” when 

describing their shift of funds to Title I in order to increase the number of students reaching 

proficiency. This focus on increasing student achievement will be elaborated on in the following 

section. 

Goals and Initiatives of Districts Using Transferability 

Eighty-seven percent of district officials reallocated funds under Transferability in order to 

increase the amount of federal funds available for high priority programs. 

The most frequently cited use of Transferability was to bolster high priority programs. Other 

frequent uses were for targeting particular student groups or outcomes and maintaining stable 

funding for activities that would be affected by budget constraints. Approximately 82 percent of 

district users indicated using Transferability for assisting particular student groups or improving 

certain outcomes while 70 percent of district officials indicated using the program to maintain 

stable funding levels (districts could select multiple responses). About half of the districts used 

Transferability to initiate new activities, and 28 percent of the districts used Transferability to 

concentrate resources (see Exhibit 9). 

16 
Exhibit 9 

Uses of Transferability 

Percent of Respondents

Increase the amount of federal funds available for 

high-priority programs

Concentrate federal resources for a smaller number 

of programs

Initiate new activities that would not have been 

possible without exercising Transferability

Maintain a stable level of effort for ongoing 

activities that have been affected by budgetary 

constraints

Target particular student groups or outcomes

28%

53%

70%

82%

87%

0% 20% 40% 60% 80% 100%

Exhibit reads: Roughly 87 percent of Transferability participants used the program to increase the amount of federal 

funding in high-priority programs. 

Note: Percentages may not sum to 100 because districts could mark multiple responses. 

Source: District Administrator Survey #17. 

Respondents identified five top priorities for Transferability: teacher quality (44 percent), 

Title I (30 percent), technology (30 percent), literacy (28 percent), and math (17 percent). 

Districts were asked to identify the top priorities for Transferability in a free response section of 

the survey and identified five main priorities. As became evident in the case studies, all five of 

these priorities were closely connected to each other and to districts’ efforts to help schools make 

AYP. 

Many districts used teacher quality initiatives to reach the goal of increasing math and reading 

test scores by “reducing the student/teacher ratio,” hiring more teachers, paying for professional 

development, and increasing Title I personnel. One district official indicated that in a time of 

budget constraints, Transferability allowed the district to maintain teacher quality: 

Being able to ... transfer funds around has allowed our small rural school to 

provide direct instruction in reading and preschool experience by allowing us to 

help cover salaries of those teachers. We were also able to cover substitute 

teachers so that our teachers could do professional development activities to 

improve their learning and teaching. 

This finding may at first glance appear contradictory because, as noted above, many 

districts transferred funds out of Title II, Part A. However, districts moved money to other 

federal programs that allowed them to use funds more flexibly to target particular teacher 

quality issues. For example, districts indicated that they transferred money into Title I, 

17 
because they could then use funds to recruit and retain high quality teaching staff in their 

district. 

Districts also put a strong priority on Title I, Part A. Many districts shifted funds into Title I and 

saw maintaining or increasing funds for this program as an integral way to boost student 

achievement for at-risk students and help schools reach AYP. Many districts responded to a 

decrease in Title I, Part A, funding by using Transferability to augment current Title I programs. 

One district official connects Title I funding through Transferability with increasing student 

achievement: 

To increase the amount of federal funds available for high priority programs, funds 

were transferred to our Title I program. Our goal was for all subgroups to 

demonstrate a 5 percent increase in their reading [scores]. Specific programs 

were to hire two reading specialists, four reading teachers to co-teach reading, one 

teacher to teach math and reading for students who are at risk for failure, [and two 

more teachers]. 

In addition to Title I, another top priority was technology. Again, district officials connected 

their priorities for Transferability funds to helping schools reach AYP. One district official 

explicitly stated, “Our goal was to increase student achievement through the use of technology,” 

and another went further in describing the district’s process: 

Well, we certainly hope to improve the scores on our statewide testing through 

use of technology for some of our students who seem to respond better to that type 

of instruction than they may do to the old-time, just stand-and-deliver type. So, it 

really is to improve our testing goals to meet the AYP. ... It’s the delivery of the 

instruction into areas where we’ve had some remedial situations, and we’re using 

laptops and online curriculum that has been written by our own folks, our own 

staff here, as well as some of the textbooks are now going online with a lot of 

features where you can actually get some more hands-on activities. And that 

certainly seems to increase enthusiasm, if nothing else, for the students. 

Technology initiatives across districts included the purchase of computers and software, hiring 

technology instructors, and increasing teacher training in technology in order to “assist [schools] 

as [they] work to improve test scores and retention of content for all students in every subgroup 

as required by NCLB.”

Because NCLB focuses on reading and math tests for AYP, it was no surprise that districts used 

Transferability to focus on reading and math. One district official stated, “Literacy is our top 

priority,” and another said, “Our priority goals are to improve math and literacy test scores.” 

Sometimes districts targeted literacy and math even when directing resources into the other three 

top-identified priority areas: teacher quality, Title I, and technology. For example, districts 

reported increasing personnel for literacy-specific programs or purchasing software programs for 

math and reading using technology funds. Districts also purchased books and supported tutoring 

programs. 

18 
Districts themselves did not view these funding areas (teacher quality, Title I, technology, 

literacy, and math) as necessarily separate from each other. They were all pieces in many 

districts’ use of Transferability, which in turn is just one aspect of NCLB and districts’ goals 

under that law. A district official explains these connections: 

It comes together as a whole package. So we don’t look at it as an isolated ... 

You know, it’s sort of how does it fit into the whole complex underpinnings that 

make a school district run? ... We have a district action plan; we have school 

improvement plans; we’re also a district in need of improvement in mathematics. 

We were able to, by transferring the money, free up some resources ... so that 

they’re now able to work with the math because we failed the AYP in math. 

Districts did target specific populations for these initiatives. One district “provided additional 

tutoring time in reading to those students in the lowest 25 percent as determined by our reading 

assessments.” Another focused on the early grades of kindergarten through third grade. This 

way, districts could use their limited resources on the populations they felt were most in need. 

Based on the articulated goals and initiatives of districts using Transferability, the next section 

explores districts’ progress toward reaching their priorities and the efficacy of the program. 

Progress Toward Goals Using Transferability9

District officials reported that Transferability helped them reach their goals. 

Respondents in the case studies indicated that Transferability has, to some degree, helped their 

districts reach the goals discussed above. However, since Transferability is only one part of 

NCLB and the initiatives schools and districts use to make AYP, the direct effect of 

Transferability was hard to isolate based on the survey findings. One district official felt that 

Transferability made possible a program that increased parental involvement of English language 

learners. Another district official saw Transferability create the opportunity for initiatives that 

would have been impossible before: 

Transferability really did help the district when we were in the process of 

integrating our new technology under state guidelines that were out at the time. 

And that probably would not have happened, at least the professional 

development side wouldn’t have had the support it had during that time. 

Several districts saw Transferability aiding their efforts to make AYP, though they 

acknowledged a lack of specific evidence showing its role and pointed out the difficulty of 

isolating Transferability’s effects. A district official described how Transferability helped the 

district’s AYP efforts through “being able to focus more attention, more resources, and more 

 

9

 This section is based solely on the case study results. Thus, conclusions related to progress through the use of 

Transferability is based on the reports of a small number of district officials. 

19 
bodies at the early intervention areas, early years, K–3.” However, another respondent 

recognized the difficulty in assigning district success to Transferability: 

Now, I guess we probably have not done an exclusive study where we’ve ruled out 

all of the variables [other than Transferability], because there’s a lot that affects 

what a child does on a particular assessment, and that’s the main way we 

measure anymore because we have to. I think it’s helped, I mean, but to say that I 

can provide data that actually shows that, there would really have to be a much 

broader study. 

A final district official summed up how Transferability, by making a specific program possible, 

is part of the district’s set of tools in making AYP: 

Language scores have gone up. ... I do think that the effects of it have been 

positive. ... And I think that without [Transferability] and without these literacy 

aides in the classroom, that the teachers would be far more stressed and 

struggling to meet the needs of the individual learners. ... Having that flexibility 

to move the money into this pot that we can then use for hiring additional literacy 

aides helps us to differentiate the instruction.

This official continued to connect the literacy aide program to AYP and explained that the intent 

and hope of the literacy program was to increase student scores and make AYP. For these 

district officials, Transferability appeared to be a useful tool for targeting funds to help schools 

reach AYP. So while no direct connection can be drawn between Transferability and increased 

student achievement, some district officials see Transferability as an important part of meeting 

this goal. 

The Decision to Use Transferability 

Access to Information About Transferability 

A large majority of districts reported familiarity with Transferability. 

The survey results indicated that 81 percent of districts were familiar with the Transferability 

program. In comparison, districts’ familiarity with other flexibility programs ranged from 33 

percent for Waivers or Ed Flex to nearly 90 percent for Title I, Schoolwide Programs, (see 

Exhibit 10). 

20 
Exhibit 10 

Familiarity With Federal Funding Flexibility Programs 

Program

Not familiar/ 

Familiar in 

name only

Somewhat/ 

Very 

familiar

Title I, Schoolwide Programs 12% 88%

Transferability 19% 81%

Consolidation of Administrative Funds 45% 55%

REAP Flex 55% 45%

Local Flex 66% 34%

Waivers or Ed Flex 67% 33%

Exhibit reads: Eighty-one percent of districts were somewhat or very familiar with 

Transferability. 

Source: District Administrator Survey #1. 

Exhibit 11 

Usefulness of Sources of Transferability Information 

Information Source No Information 

From Source Not Useful Somewhat/ Very Useful

Information or technical assistance 

provided by the state 29% 2% 69%

Workshop or information session 33% 4% 63%

Regional providers of technical 

assistance 48% 5% 47%

U.S. Department of Education Web 

site or publications 48% 13% 39%

Professional organizations 58% 7% 35%

Direct communication with U.S. 

Department of Education 74% 10% 16%

Other 87% 2% 12%

Exhibit reads: Sixty-nine percent of respondents found information or technical assistance provided by the 

state somewhat or very useful.

Source: District Administrator Survey #4. 

The high level of familiarity with Transferability came from information provided by a variety of 

sources (see Exhibit 11). Sixty-nine percent of respondents found information or technical 

assistance provided by the state education agencies to be somewhat or very useful. Workshops 

and information sessions were also somewhat or very useful to a substantial number of districts 

(62.7 percent). Thirty-eight percent of respondents reported finding the U.S. Department of 

Education Web site or publications, regional providers of technical assistance, and professional 

organizations to be somewhat or very useful. 

21 
There were large and significant differences between Transferability participants and 

nonparticipants in where they received information about the program. 

Approximately 86 percent of Transferability participants obtained information from the state (see 

Exhibit 12). In contrast, 57 percent of nonparticipants received information about the program 

from the state (districts could select multiple responses). This is perhaps not surprising, because 

much of the interaction between the district and the state could have been for technical 

assistance, which would not be as applicable for districts not exercising Transferability. 

However, similar results emerged for other sources of information. Eighty-one percent of 

Transferability users received information from a workshop or information session, while only 

55 percent of nonusers received information from this source. Furthermore, 30 percent of 

nonparticipating districts did not obtain information about Transferability from any source. This 

may have indicated that some districts simply did not have access to potential sources of 

information about the program. 

Exhibit 12 

Sources of Transferability Information Among Participants and Nonparticipants 

Information or technical assistance 

provided by the state

Workshop or information session

Regional providers of technical assistance

U.S. Department of Education Web site or 

publications 

Professional organizations

Direct communication with staff from 

U.S. Department of Education

Other

No Information

10%

28%*

4%

86%*

81%*

47%*

4%*

38%

57%*

55%*

31%*

33%

30%*

11%

3%

17%*

0% 20% 40% 60% 80% 100%

Percent of Districts

Transferability Participant Transferability Nonparticipant

Exhibit reads: Eighty-six percent of Transferability users received information or technical assistance regarding 

Transferability from the state, while 30 percent of nonusers received no information at all 

about the program. 

Note: Percentages may not total 100 percent because districts can receive information from multiple sources. 

Statistically significant differences are indicated by asterisks (p<.05). 

Source: District Administrator Survey #2.

22 
States were one of the most important sources of information on Transferability. 

Among Transferability users, states were the most common source of information. This may 

indicate that states with more active information dissemination activities have a larger number of 

Transferability participants. While it is not possible to draw a definitive conclusion using the 

available survey data, examination of states where at least ten districts responded to the survey 

provides tentative inferences. In two of the ten states where at least ten districts responded, more 

than 90 percent of districts sampled used Transferability. This is a substantially higher 

participation rate than would be expected based on the sample design. In these two states, 

Arkansas and Maine, 100 percent of districts received information on Transferability from the 

state. This may indicate that these states were particularly active in providing districts 

information and supporting districts participating in the program. In the other eight states, less 

than half of the respondent districts used Transferability. While more than 75 percent of users in 

these states obtained information from the state, less than half of nonparticipating districts 

received information from the state. Thus, in these states, a much smaller proportion of districts 

obtained Transferability information from the state. 

The majority of case study respondents mentioned state officials as their primary source of 

information and guidance. Districts using Transferability noted that the state provided 

information about both the uses and requirements of the program. This information was often 

disseminated at workshops and conferences. One superintendent explained that the state had a 

consultant available to the district to answer questions and provide technical assistance to 

districts exercising Transferability. 

Reasons Districts Do Use Transferability 

The most common reason that districts chose to utilize Transferability was a desire for greater 

flexibility in the use of federal funds. More specifically, district representatives identified 

mismatches between federal funding and district priorities, decreasing levels of federal funding, 

and a higher degree of flexibility associated with particular programs as driving forces in the 

decision to use Transferability. 

Differences in district priorities and federal program allocations led some districts to use 

Transferability. 

One federal programs coordinator (whose district had not used Transferability in prior years) 

eventually decided to use Transferability due to the differences in district priorities and initial 

federal program allocations. In particular, this programs coordinator identified a surplus of funds 

in Title II and a desire for greater funds for Title V. This district used Transferability to transfer 

funds to Title V to fund a parent involvement coordinator and a school nurse. Another district 

found its Title II, Part D, allocations too small to be of much use on their own and explained, 

“We only had about $9,000.” The district supplemented this money with funds from a different 

program to ensure that the initial allocation could be used effectively. Federal funding 

allocations that did not match a district’s priorities, as this example shows, acted as an incentive 

to use Transferability. 

23 
24

Decreased levels of federal funding contributed to mismatches between allocations and 

priorities.

In interviews, several district administrators specifically identified diminishing federal funds as a 

driving force in their districts’ decisions to implement Transferability. Users surveyed through 

phone interviews identified decreases in Title I, Part A, and Title V, Part A, as reasons for using 

Transferability. One district federal programs coordinator reported, “Title V ... funding is going 

down every year. ... We went from $65,000 down to $49,000, and we’ve been told at our last 

federal programs meeting that it’s going to go down another 25 percent.” An administrator from 

another district agreed, saying that Title V had been “cut tremendously in the last several years.” 

A different district had received less funding for Title I programs and used Transferability to 

help cover the salary of two reading specialists for Title I students. Because decreases in federal 

funding levels are generally due to formulas or decreasing appropriations and not aligned with 

declining district needs in associated areas, districts viewed diminished funds as an impetus for 

utilizing Transferability. It gave them the ability to compensate for funding losses by 

transferring what funds they did receive into areas with the most need. 

District representatives also found certain program guidelines more flexible than others.

“We had to stay within some pretty restrictive guidelines,” one official said, explaining the 

district’s decision to transfer funds out of a particular Title program. Another official noted that 

the district gained more discretion over funds by transferring them out of Title II and into 

Title V. Overall, districts used Transferability as a means of reallocating funds that granted them 

more discretion over the use of funds or ability to target specific priority areas. 

Reasons Districts Do Not Use Transferability 

Districts indicated that they did not participate in Transferability because of already adequate 

flexibility, the size of eligible funds, and lack of information. 

School districts that did not participate in Transferability identified satisfaction with current 

levels of flexibility as a major factor in the decision to not apply for Transferability (see Exhibit 

13). Over 40 percent of nonuser survey respondents believed that their district already had 

sufficient flexibility in their use of federal funds (districts could select multiple responses). 

Interviews with nonusers revealed similar feelings. One district administrator reported, “All of 

the grants have pretty well met the needs without transferring funds back and forth between the 

grants, so we just continued to do what we’ve done in the past.” Another administrator agreed, 

highlighting carry-over funds and adequate funding levels in Titles I and II: “We felt like we had 

enough funding available to make it work, so there was no need to mix the programs and have 

funds go from one to the other because we had enough to start with.” Put simply, many districts 

chose not to apply for Transferability because they felt there was no need to do so. The second 

most common reason given in surveys for not implementing Transferability was the amount of 

funds eligible to be transferred. Approximately 35 percent of nonuser survey respondents 

reported that, even after exercising Transferability, the funding levels in applicable categories 

would still have been too low to carry out the desired activities. 

Insufficient information about Transferability was another common factor cited in districts’ nonparticipation in Transferability. Twenty-nine percent of survey respondents reported having too 

little information about Transferability to make an informed decision, while 21 percent of 

nonusers reported being entirely unaware of the Transferability option. Between those that were 
entirely unaware of Transferability and those that did not have enough information, over onethird of nonusers cited insufficient information as a factor in their choice not to use 

Transferability. One superintendent interviewed over the phone admitted that, after hearing a 

description of the Transferability program, “Now that I know about it... I might consider it.” 

Interestingly, large districts were less likely to report insufficient information as a factor in not 

choosing to implement Transferability. This suggests that information about Transferability was 

less like to “slip through the cracks” at large school districts, or larger school districts were more 

likely to receive such information in the first place. 

Exhibit 13 

Percent of Respondents for Whom the Given Considerations Were a Major Influence on 

Their Decision Not to Use Transferability 

Top 5 Considerations

Percent of 

Transferability

Non-participants

District already had enough flexibility over use of funds without Transferability. 44%

Amount of funds in applicable categories would have been too small to effectively 

carry out desired activities even after exercising the Transferability option. 35%

Did not have enough information about Transferability to make an informed 

decision. 29%

Was not aware of Transferability option. 21%

Accounting requirements associated with Transferability would have been 

burdensome. 16%

Exhibit reads: Forty-four percent of nonparticipating districts responded that they already had enough flexibility 

over the use of funds without Transferability. 

Note: For all other considerations, the percent claiming them to be a major (or even minor) influence on their 

decision not to use Transferability was under 5 percent. Percentages do not sum to 100 because districts could give 

multiple reasons for not using Transferability. Adjusted weight data not presented because weights were not 

adjusted for nonusers. 

Source: District Administrator Survey #7. 

Phone interviews with nonusers identified another factor (not provided as an option on the 

survey) that may have led districts to not use Transferability. A district administrator pointed to 

declining funds as a reason to decline participation in Transferability: “I think that because we 

keep losing monies in some of the other Title programs, we can’t really afford to take more 

money out of that, and that’s the issue there.” This factor is related to the belief that the amounts 

associated with Transferability were too small to make the program worthwhile. While some 

participating districts viewed declining funds as a reason to use Transferability, some 

nonparticipating districts saw limited resources as a barrier to using the program. 

Increasing Interest in Transferability 

District respondents indicated that potential changes to the terms of the Transferability 

provision offered on the survey would increase their interest in the program. 

Almost three-quarters of Transferability participants and 70 percent of nonparticipants indicated 

that they would be more likely to enroll in Transferability if the transferred funds were not 

restricted by the rules and requirements of the receiving programs (see Exhibit 14). While most 

25
potential changes stimulated similar levels of increased interest in current users and nonusers, 

increasing the proportion of funds that can be transferred from eligible programs would enhance 

interest in current participants significantly more than in nonparticipants—77 percent and 64 

percent, respectively. Thus, making this change might increase satisfaction among current users 

of Transferability more than it would attract new districts to the program. 

Exhibit 14 

Reaction to Potential Changes to the Terms of the Transferability Provision, Given as 

Percent of Respondents for Whom the Change Would Cause Their Interest in 

Transferability to Be Somewhat or Much Higher 

A greater proportion of funds in eligible programs 

could be transferred

New funding provided to participating districts 

over and above existing allocations in eligible 

programs

Transferred funds not restricted by the rules and 

regulations of the receiving program

Accounting requirements were relaxed or 

assistance was offered to maintain necessary 

records

Funds could be transferred from a larger number 

of federal programs

Funds could be transferred to a larger number of

federal programs

The terms of participation were not affected by a 

district's Title I accountability status

Change in Transferability Provision

52%

63%

68%

72%

54%

77%

76%

77%*

52%

64%*

75%

66%

56%

47%

0% 20% 40% 60% 80% 100%

Percent of Respondents

Transferability Participant Transferability Non-participant

Exhibit reads: Seventy-seven percent of participating districts reported that their interest in Transferability would be 

somewhat or much higher if a greater proportion of funds in eligible programs could be transferred. 

Notes: Percentages do not sum to 100 because districts could mark multiple response. Asterisks 

indicate statistically significant differences (p<.05). 

Source: District Administrator Survey # 13 and 24. 

Finally, approximately 67 percent of both participants and nonparticipants indicated that relaxing 

accounting requirements or an increase in assistance for maintaining necessary records would 

pique their interest. One Transferability participant illustrated the desire for assistance in fiscal 

record-keeping. The district had “wanted to start it a year before, but there were no directions. 

... [We need] concrete directions from SEA or federal level that outlines how the funds should 

be managed from a fiscal standpoint.” 

26
27

4. Conclusion—Summary of Findings 

Confusion about Transferability was high among states and districts. 

Weighted results suggested that 1,683 to 2,949 districts, or between 12 percent and 21 percent of 

all districts nationwide, used Transferability. As noted above, this estimate is similar if REAP 

Flex eligible districts were not included. District-reported Transferability participation rates and 

state-reported Transferability notification were substantially different. Approximately 25 percent 

of districts that states identified as Transferability participants did not report using the program. 

Further, roughly 10 percent of districts that states did not identify as Transferability participants 

reported using it. This, combined with the large number of districts that claimed to have moved 

greater than 50 percent of initial allocation (21 percent)—a transfer that is not allowed under the 

Transferability requirements—indicated that districts do not clearly understand the rules of using 

and notifying of intent to use Transferability. It is also possible that some of these districts were 

actually exercising the REAP Flex authority, which allows a larger percent of funds to be used 

for other purposes. 

States were the most useful source of information about Transferability for districts. 

The vast majority of districts that use Transferability looked to their state education associations 

for guidance on the provision’s rules and regulations (86 percent). Significantly fewer 

nonparticipants received information from the state (57 percent), which implies that states were 

less successful in getting Transferability information out to the districts not already using it. 

Transferability participants and nonparticipants were similar demographically. 

Users and nonusers were not significantly different in terms of size, poverty level, percent 

federal funding, percent Transferability-eligible funding, or total per student revenue. 

Money moved under Transferability was most frequently transferred to Title I, Part A, and 

Title V, Part A, and focused on initiatives aimed at making AYP. 

The most commonly cited education goals associated with the reallocated funds included 

improving teacher quality, increased focus on Title I students, technology, math, and literacy. 

Together, they make up one larger goal for survey respondents: making AYP. District officials 

believed that Transferability was helpful in working toward those goals, although they hesitated 

to draw strong causal relationships between the program and student achievement. 

Reduced funding and spending restrictions led many districts to use the provision.

Most districts using Transferability reallocated money so that high priority programs (such as 

those that focused on the goals listed above) would receive more funding. Another common 

reason for utilizing Transferability was that some federal education programs place more 

restrictions on how money can be spent than others, so districts shifted funds into programs with 

fewer restrictions. 

Existing adequate flexibility, size of eligible funds, and inadequate information were the three 

primary reasons districts did not participate in Transferability. 

Nonparticipants also suggested changes to the program that would increase their interest. One of 

the most popular changes posed on the survey was to remove the stipulation that reallocated 

monies are subject to the rules and requirements of the recipient program. 
28

Because districts that used Transferability generally had the same goals—making AYP via 

higher math and reading scores—as districts that did not use Transferability, it appeared that 

Transferability was just one of many tools districts utilize to meet these objectives.

Districts that used Transferability found the additional flexibility helpful and the fact that many 

districts approached the 50 percent reallocation limit showed that they were eager for the 

program to provide more flexibility. Additionally, because nearly one third of districts that did 

not participate said they did not use the program because the eligible funds were too small to 

make a difference in their district, it is clear that districts would like to see more funding be 

deemed applicable for use under Transferability. 

The overarching finding of this report, however, is that districts in most parts of the country need 

to be provided with more information about Transferability. There appears to be widespread 

confusion about who uses Transferability and how to use it correctly. This has important 

implications for usage of the Transferability provision, as insufficient information is a 

determining factor in districts’ decisions to participate. 
29

Appendix A: Methodology 

Survey Participants and Data Collection 

The sample of districts used in the analysis was selected from lists of districts provided by states. 

Each state identified the districts they believed were using Transferability and the districts that 

were not using Transferability based upon district notification of the state of their intent to use 

the provision. The information that the states provided showed that 12 percent of districts use 

Transferability. 

To facilitate comparisons between districts using Transferability and districts not using 

Transferability, districts in the first group were over-sampled. Approximately equal numbers of 

state-identified users and nonusers were randomly chosen to participate in the study. Any 

district that had participated in the National Longitudinal Study of NCLB (NLS) was removed 

from consideration in order to minimize response burden. In addition, all districts that had been 

selected to participate in the concurrent study of REAP Flex were excluded. The survey was 

initially mailed to 372 school districts nationwide. This included 184 state-identified users and 

188 state identified nonusers. 

Districts were given the option to complete the survey using a paper survey form or using the 

Web-based survey online. Four types of follow up efforts were pursued: reminder letters, 

reminder phone calls, replacement packages, and offers to complete the survey via phone. The 

final response rate was 86 percent, with 320 districts participating in the survey. Districts 

identified by their states as Transferability users responded at a 75.5 percent rate, while the state 

identified nonuser response rate was 96.3 percent. Because the response rate was high and 

district size and poverty differences between respondents and nonrespondents were statistically 

insignificant, it was not necessary to adjust the weights to address nonresponse bias. 

Case Study Participants 

The second component of data collection consisted of phone interviews with district officials 

from 12 school districts selected from among the 320 districts that returned the survey. When 

possible, the interviews were conducted with the same person who filled out the survey. The 

majority of case study respondents were superintendents or assistant superintendents. Other 

respondents included principals, directors of ESEA, federal programs coordinators, Title I 

directors, and directors of instruction. 

In order to get detailed information about decisions concerning the use of Transferability from a 

wide range of districts, survey responders were divided into eight categories based on size and 

Transferability participation (shown below) from which the case study districts were randomly 

selected. From the respondents in each size category, two users and one nonuser were randomly 

selected for the case studies (see Exhibit 1A). 
Exhibit A-1 

Case Study Sample Selection: Number of Interviews by Category 

Average Daily 

Attendance 

Transferability 

Participant 

Transferability 

Nonparticipant 

Less than 1,000 2 1 

1,001–3,000 2 1 

3,001–10,000 2 1 

More than 10,000 2 1 

30

 

 Total 8 4 

Data Preparation 

After completion of the survey and case studies, the data were examined for internal consistency 

and outliers. Internal inconsistencies were resolved by follow-up telephone calls to the districts, 

and outliers were examined for accuracy. For example, review of the data revealed particular 

confusion on the part of districts regarding districts’ total revenue. It was clear that some 

districts misinterpreted the questions about total revenue and reported the total amount of federal 

funding they had received. In other cases, the reported revenue amounts were implausibly low 

and difficult to explain. To account for reporting errors, total revenue reported in the survey was 

replaced with total revenue reported by the Common Core of Data (CCD) (2003) if the survey 

data met one of the following two conditions10: 

1. The sum of reported federal funds was greater than 20 percent of the total revenue 

reported. 

2. The total revenue reported was less than or equal to the sum of reported federal funds. 

Average daily attendance (ADA) data were also checked against the CCD for major 

discrepancies. In 47 cases, the ADA reported in the survey was at least 20 percent different than 

the ADA listed by the CCD. In these cases, additional research including Internet searches and 

phone calls was conducted to determine the appropriate ADA. Finally, the data were checked 

for potential nonresponse bias by examining potential differences between districts that 

responded and those that did not respond. This analysis indicated that there were no significant 

differences between respondents and nonrespondents for either of the two stratification variables: 

size and poverty level. 

10 Because CCD data was from 2003 and survey data from 2004–05, only observations that met the two categories 

above were replaced 
31

 

Finally, 23 districts that state education agencies had identified as nonusers of Transferability 

reported in the survey that they did use Transferability. Because these 23 districts were selected 

with a much lower probability than other districts that reported using Transferability, they 

account for a large share of the total weight in the analysis. Therefore, this relatively small share 

of the sample could have a large influence on the final estimates. As a result, follow-up calls 

were conducted to districts to resolve the discrepancies. These calls revealed that 12 of the 23 

districts were using Transferability. Most of the 11 other districts had confused REAP Flex with 

Transferability. 

Similarly, 38 districts identified by states as Transferability users reported in the survey that they 

did not use Transferability. Because these districts were selected with a much higher probability 

than other districts that reported not using Transferability, they account for a small proportion of 

the total weight in the analysis and therefore have a small influence on the final estimates. As a 

result, follow-up calls to these districts were not conducted. Instead, the districts’ survey 

responses were accepted. 

In the body of the report, analyses of results were conducted with adjusted weights so as to avoid 

having 12 districts drive the results and very large standard errors while still maintaining a 

representative sample. In this second method of weighting, the proportion of the total weight 

assigned to the districts incorrectly identified as nonusers was made smaller to reduce the mean 

squared error of the results. The mean squared error combines the square of the bias obtained 

when assigning a weight other than the full weight to the data and the square of the standard 

error given that weight. Attaching less than the full weight to the nonmatching cases typically 

increases the bias and lowers the squared standard error. The proportion of the weight attached 

to the nonmatching cases that minimizes the mean squared error varied by survey question. 

Nonmatching users were assigned 28.75 percent of the total weight, which is the average of the 

values that minimize the mean squared error across key survey measures.11 Analyses using full 

weights or only including the correctly identified districts did not yield substantively different 

results. 

Analysis 

Survey data were analyzed using descriptive statistics, mean differences tests, and regression 

analysis. Means and frequencies were calculated for each applicable survey question. 

Transferability participants were compared with nonparticipants. Linear regressions using 

poverty level, percent federal funding, average daily attendance, urban setting, and percent 

Transferability-eligible funding as predictors were conducted for survey questions with 

continuous outcomes. Logistic regressions using the same predictor variables were conducted 

11 This compares to the original 42.76 percent of the weight originally given to this group based on selection 

probability. The 28.75 percent proportion was determined by comparing weight proportions that minimized the 

mean squared error term for all relevant questions that compared users to nonusers. These proportions ranged from 

6.69 percent to 46.13 percent. We looked particularly at objective descriptive data (e.g., average daily attendance, 

revenue information, etc.) to determine the final proportion used. The median proportion of weights that minimized 

mean squared error for this group of data, and thus the proportion of weight given to nonmatching users in this 

interpretation of data, was 28.75 percent. Note that the proportion of weights assigned to nonusers was not adjusted, 

as incorrectly identified districts in this group carried only 3 percent of the weight of the total group of nonusers. 

Thus, it was not necessary to adjust the weights in this group, as the full weights had a minimal impact on the 

group’s results. 
32

for binary outcomes, such as the yes-or-no question asking whether the district participated in 

Transferability. 

In addition to the data gathered from the surveys, the interview transcripts from the case studies 

and the free response answers generated from the survey were coded and analyzed using the 

research questions as a guide. This qualitative information provided illustrations of many 

findings generated by the survey data, as well as insights into application of Transferability 

toward educational planning and goals. 
Appendix B: Data Tables with Standard Errors 

Presented below are data tables for all exhibits from the body of the report with standard errors 

where differences between participants and nonparticipants were reported. 

Exhibit B-1 

Usage Patterns of Transferability Participants vs. Nonparticipants 

Transferability 

Participants

Transferability 

Nonparticipants

83%* 11%*

 (0.05) (0.03)

74%* 59%*

 (0.05) (0.08)

Used Transferability Prior 

to 2004-05

Planned to use 

Transferability in 2005-06

Note: Statistically significant differences indicated with asterisks (p<.01). 

Source: District Administrator Survey #8, 9, 22, and 23. 

Exhibit B-2 

Comparison of Transferability Participants vs. Nonparticipants Based on Key Defining 

Variables 

Transferability 

Participants

Transferability 

Nonparticipants

 15.0% 14.5% 0.5%

 (0.99%) (0.78%) (1.35%)

 8.0% 9.8% -1.8%

 (0.49%) (0.55%) (1.16%)

 1.1% 0.9% 0.3%*

 (0.13%) (0.05%) (0.14%)

3461 3176 285

 (739) (727) (1,055)

b

 Percent total revenue from federal, state, and local sources (based on 2003 Common Core of Data).

d

 Based on 2003 CCD data.

a

 Based on the percent of school age children in the district living below the poverty line (2000 Census data).

c

 Percent total revenue from federal, state, and local sources (not counting Title I, Part A).

Percent Povertya

Percent Federal Fundingb

Percent Eligible Fundingc

Average Daily Attendanced

Difference Between 

Participants and 

X, (SE) Nonparticipants

Note: Statistically significant differences indicated with asterisks (p<.05). 

Source: District Administrator Survey #10, 11, 12, 18, 19, and 20. 

33
Exhibit B-3 

Mean Revenue by Program, Transferability Participants vs. Nonparticipants 

Funding Category

Transferability Participants

Transferability 

Nonparticipants

Title I, Part A $312.77 $248.57

Improving the Achievement of Disadvantaged Children ($41.89) ($45.37)

Title II, Part A $71.37 $59.63

Improving Teacher Quality State Grants ($7.16) ($5.78)

Title II, Part D $12.76 $9.21

Educational Technology State Grants ($2.28) ($2.53)

Title IV, Part A $10.16* $6.53*

Safe and Drug-Free Schools and Communities ($1.78) ($1.78)

Title V, Part A $8.85 $6.04

State Grants for Innovative Programs ($1.69) ($1.69)

Total Revenue $9,983.29 $10,460.38

From All Sources ($501.31) ($449.28)

(in dollars)

Mean Allocation Per Student for 2004-05 

Note: Statistically significant differences are indicated by asterisks (p<.05). 

Source: District Administrator Survey #10, 11, 19 and 20. 

34
Exhibit B-4 

Mean Priority Level of and Transferability Usage for Areas of Possible Need 

 (1=Low Priority, 3=High Priority) 

Transferability 

Participants

Transferability 

Nonparticipants

Participants 

who Used 

Transferability 

to Address 

Need

Instruction

2.2 2.1

 (0.10) (0.08)

2.0 2.0

 (0.09) (0.07)

2.4 2.5

 (0.09) (0.07)

2.5 2.6

 (0.10) (0.07)

Support for Special Programs and Services

2.1 2.2

 (0.10) (0.08)

2.0 2.2

 (0.10) (0.07)

1.7 1.9

 (0.11) (0.09)

1.2 1.3

 (0.07) (0.05)

Performance on Specific Academic Outcomes

 2.7* 2.6*

 (0.08) (0.05)

2.7 2.6

 (0.08) (0.06)

2.2 2.4

 (0.09) (0.07)

1.8 1.9

 (0.09) (0.10)

1.9 1.9

 (0.10) (0.10)

0.3 0.3

 (0.06) (0.06)

Performance of Specific Student Groups

2.0 2.1

 (0.11) (0.10)

2.6 2.5

 (0.09) (0.08)

2.4 2.6

 (0.09) (0.07)

1.8 1.9

 (0.10) (0.11)

1.8 1.8

 (0.11) (0.09)

2.1 2.2

 (0.10) (0.11)

 2.6* 2.3*

 (0.08) (0.07)

 2.5* 2.2*

 (0.09) (0.06)

2.3 2.1

 (0.10) (0.08)

Supplemental educational services (SES) 

provided under Title I

Highly qualified teachers

Highly qualified paraprofessionals

Curriculum and instructional materials

Educational technology

Extended-time programs

Summer Programs

Transportation for Title I school choice 

participants

English/Language Arts

Mathematics

Science

Attendance rates

Graduation rates

Other

Racial and ethnic minorities

Low-income students

Students with disabilities

Limited English Proficient (LEP) students

High school students

Students in low-performing schools

Kindergarten and pre-K students

Elementary students

Middle school students

39%

53%

69%

25%

30%

24%

35%

62%

34%

11%

15%

9%

17%

45%

64%

4%

39%

18%

30%

17%

16%

22%

45%

Note: Asterisked text indicates statistically significant differences between participants 

and non-participants (p<.05). 

Source: District Administrator Survey #14 and 21. 

35
Exhibit B-5 

Authority and Oversight of Transferability 

Decides which 

funds to use

Management and 

oversight

71% 57%

 (0.07%) (0.07%)

14% 16%

 (0.02%) (0.05%)

41% 57%

 (0.07%) (0.07%)

73% 80%

 (0.06%) (0.03%)

28% 26%

 (0.05%) (0.03%)

13% 9%

 (0.06%) (0.05%)

14% 4%

 (0.05%) (0.01%)

Other

Administrator for individual federal 

programs

Administrator assigned specifically to 

manage Transferability

School Board

Financial Officer

General Administrator for all federal 

programs

Superintendent

Note: Percentages do not sum to 100 because districts could mark multiple responses. 

Source: District Administrator Survey #15. 

Exhibit B-6 

Difference in Use of Funds After Exercising Transferability 

Funding Category

Title I, Part A $10.80 3%

Improving the Achievement of Disadvantaged Children ($4.56) (0.7%)

Title II, Part A -$17.13 -21%

Improving Teacher Quality State Grants ($4.50) (2.6%)

Title II, Part D $0.06 12%

Educational Technology State Grants ($0.60) (11.2%)

Title IV, Part A -$2.42 -25%

Safe and Drug-Free Schools and Communities ($0.50) (4.2%)

Title V, Part A $8.44 134%

State Grants for Innovative Programs ($2.11) (36.0%)

Mean Movement of 

Funds 

(in dollars per student)

Percent Difference 

from Initial 

Allocation

Note: Negative numbers indicate that, on average, more money was moved out of a program than moved into that 

program. Five districts reported using Transferability incorrectly by removing 100 percent of their funds out of 

Title 1, Part A, and were therefore excluded from the above calculations. 

Source: District Administrator Survey #18. 

36
Exhibit B-7 

Uses of Transferability 

Uses

Percent of 

Respondents

87%

 (0.04%)

82%

 (0.06%)

70%

 (0.07%)

53%

 (0.07%)

28%

 (0.02%)

Maintain a stable level of effort for on-going activities that 

have been affected by budgetary constraints

Initiate new activities that would not have been possible 

without exercising Transferability

Concentrate federal resources for a smaller number of 

programs

Increase the amount of federal funds available for highpriority programs

Target particular student groups or outcomes

Note: Percentages may not sum to 100 because districts could mark multiple responses. 

Source: District Administrator Survey #17. 

Exhibit B-8 

Sources of Transferability Information, Participants and Nonparticipants 

Information Source

Transferability

Participant

Transferability

Nonparticipant

 86%* 57%*

 (0.04%) (0.05%)

 81%* 55%*

 (0.05%) (0.05%)

 47%* 31%*

 (0.05%) (0.04%)

39% 33%

 (0.04%) (0.04%)

 28%* 17%*

 (0.05%) (0.03%)

10% 11%

 (0.02%) (0.03%)

4% 3%

 (0.02%) (0.02%)

 4%* 30%*

 (0.01%) (0.04%)

Other

No Information

Information or technical assistance 

provided by the state

Workshop or information session

Regional providers of technical 

assistance

U.S. Department of Education Web 

site or publications 

Professional organizations

Direct communication with staff from 

U.S. Department of Education

Note: Percentages may not total 100 percent because districts can receive information 

from multiple sources. Statistically significant differences are indicated by asterisks 

(p<.05). 

Source: District Administrator Survey #2. 

37
Exhibit B-9 

Reaction to Potential Changes to the Terms of the Transferability Provision, Given as 

Percent of Respondents for Whom the Change Would Cause Their Interest in 

Transferability to Be Somewhat or Much Higher 

Change in Tranferability Provision

Transferability

Nonparticipant

Transferability

Participant

 64%* 77%*

 (0.04%) (0.04%)

77% 76%

 (0.03%) (0.04%)

75% 72%

 (0.05%) (0.04%)

66% 68%

 (0.05%) (0.04%)

56% 63%

 (0.05%) (0.05%)

47% 52%

 (0.05%) (0.05%)

54% 52%

 (0.05%) (0.05%)

The terms of participation were not affected 

by a district's Title I accountability status

Transferred funds not restricted by the rules 

and regulations of the receiving program

Accounting requirements were relaxed or 

assistance was offered to maintain necessary 

Funds could be transferred from a larger 

number of federal programs

Funds could be transferred to a larger number 

of federal programs

A greater proportion of funds in eligible 

programs could be transferred

New funding provided to participating 

districts over and above existing allocations 

Note: Percentages do not sum to 100 because districts could mark multiple responses. Asterisks indicate 

statistically significant differences (p<.05). 

Source: District Administrator Survey# 13 and 24. 

38
39

Appendix C: District Survey 
40
41

STUDY OF NCLB

FLEXIBILITY PROVISIONS

TRANSFERABILITY AUTHORITY

DISTRICT ADMINISTRATOR SURVEY

FALL 2005

To complete this survey online go to: 

http:// trans.urban.org 

Username: «Username» 

Password: «Password»

Prepared By: 

The Urban Institute 

Education Policy Center 

Prepared For:

U.S. Department of Education

Policy and Program Studies Service

Contract No. ED-01-CO-0080

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a 

collection of information unless it displays a valid OMB number. The valid OMB control 

number of this information collection is 1875-0235. The time required to complete this 

information collection is estimated to average 30 minutes per response, including the time to 

review instructions, search existing data resources, gather the data needed, and complete and 

review the information collection. If you have any comments concerning the accuracy of the 

time estimate(s) or suggestion for improving this form, please write to: U.S. Department of 

Education, Washington, DC 20202-4651. If you have comments or concerns regarding the 

status of your individual submission of this form, write directly to: 

Policy and Program Studies Service, Office of the Under Secretary, U.S. Department of 

Education, 400 Maryland Avenue SW, Room 6W203, Washington, DC 20202-8240. 
42

Dear District Official, 

Thank you for your district’s participation in the Study of No Child Left Behind Flexibility Provisions. 

Purpose of Study: To evaluate and understand the ways in which school districts are using the 

provisions for enhanced flexibility over the use of federal education funding authorized under the No 

Child Left Behind Act (NCLB). 

Sponsor: The study is being conducted by the Education Policy Center of the Urban Institute under a 

contract from the Policy and Program Studies Service of the U.S. Department of Education. 

Privacy: Responses to this data collection will be used only for statistical purposes. The reports 

prepared for this study will summarize findings across the sample and will not associate responses with a 

specific district or individual. We will not provide information that identifies you or your district to 

anyone outside the study team, except as required by law. 

Response Burden: This survey should require approximately 30 minutes of your time. 

Benefits: Your participation will help inform policy makers and educators at the local, state, and national 

levels about the implementation of the flexibility provisions of the No Child Left Behind Act. 

More Information: If you have questions or would like more information about this study, please 

contact Kathleen Feehan at the Urban Institute via email (nclb-flex@ui.urban.org) or call our toll-free 

number 1-800-217-6741. 

Please return your completed questionnaire to: 

Kathleen Feehan 

Education Policy Center 

The Urban Institute 

2100 M Street, NW 

Washington, DC 20037 

Thank you for your cooperation in this very important effort! 
43

PART I: NCLB Flexibility 

1. How familiar are you with the following provisions for flexibility over the use of federal funding authorized 

under No Child Left Behind? Mark one response in each row. 

Type of NCLB Flexibility Not at all 

Familiar 

Familiar with 

Name only 

Somewhat 

Familiar 

Very 

Familiar 

À À À À

a. Title I Schoolwide Programs

 Eligible schools may integrate Title I funds with other funds to improve the 

regular education program for all students in the school.

c d e f

b. Transferability

 Districts may transfer funds among a set of eligible federal programs. c d e f

c. REAP-Flex 

 Small rural districts receive additional flexibility in the use of certain federal 

formula funds. 

c d e f

d. Local-Flex

Demonstration program that extends the amount of flexibility that 

participating school districts can exercise over certain federal funds.

c d e f

e. Consolidation of Administrative Funds 

Districts may consolidate administrative costs for federal programs. c d e f

f Waivers or Ed-Flex

 Districts may be exempted from certain ESEA requirements by Secretary of 

Education or their state. 

c d e f

2. For each kind of flexibility listed in the columns below, please indicate whether your district obtained 

information from one or more of the specified sources. If you did not receive any information about a 

particular form of flexibility, please mark “No information” in the final row. Mark 

all responses that apply in each column. 

Type of NCLB Flexibility 

Mark all responses that apply in each column. 

Information Sources Schoolwide 

Title I Transferability REAPFlex 

LocalFlex 

Consolidation 

Admin. funds 

Waivers/ 

Ed-Flex 

À À À À À

a. U.S. Department of Education web site or publications 

(e.g., regulations, program guidance) c c c c c c

b. Direct communication with staff from U.S. Department 

of Education d d d d d d

c. Information or technical assistance provided by your 

state educational agency (SEA) e e e e e e

d. Regional providers of technical assistance f f f f f f

e. Workshop or information session (e.g., training for 

Title I coordinators) f f f f f f

f. Professional organizations (e.g., AASA or Council of 

Chief State Officers) g g g g g g

g. Other 

(Specify:__________________________________) h h h h h h

h. No Information i i i i i i
44

3. During the past school year (2004-05), did your district use any of the following types of flexibility 

under No Child Left Behind? Mark one response in each row. 

Used by district in 2004-05 

Type of NCLB Flexibility No Yes 

À À

a. Title I Schoolwide Programs c d

b. Transferability c d

c. REAP-Flex c d

d. Local-Flex c d

e. Consolidation of Administrative Funds c d

f. Waivers or Ed-Flex c d

PART II: Learning about Transferability 

The questions in this section ask specifically about the Transferability provision of the No Child 

Left Behind Act. 

Please read the following brief description of the Transferability provision of No Child Left Behind. 

Description of Transferability 

The Transferability provision of ESEA allows a local educational agency to transfer up to 50 percent 

of formula-based funds from certain federal programs to its allocation under other eligible programs 

in order to use these resources more effectively. Transferred funds must be used in accordance with 

the rules and requirements of the receiving program. The eligible programs are: 

3⁄4 Title II Part A Improving Teacher Quality State Grants 

3⁄4 Title II Part D Educational Technology State Grants 

3⁄4 Title IV Part A Safe and Drug-Free Schools and Communities State Grants 

3⁄4 Title V Part A State Grants for Innovative Programs 

Districts exercising Transferability may also transfer funds into but not out of Title I Part A 

Districts identified as in need of improvement under Title I of the ESEA may transfer no more than 

30 percent of their formula allocation from the eligible programs and must use those transferred funds 

for improvement activities authorized under section 1116 of Title I. School districts identified for 

corrective action may not exercise Transferability. 
4. Thinking specifically about Transferability, how useful did you find the following sources for informing 

your decision about whether or not to use Transferability? If you did not receive any information from a 

particular source, please mark “No Information” in the final column. Mark 

one response in each row.

How useful was the information source 

Information Sources Not at all 

Useful 

Somewhat 

Useful 

Very 

Useful 

No 

Information 

À À À À

a. U.S. Department of Education web site or publications c d e f

b. Direct communication with U.S. Department of Education staff c d e f

c. Information or technical assistance provided by your SEA c d e f

d. Regional providers of technical assistance c d e f

e. Workshop or information session c d e f

f. Professional organizations c d e f

g. Other 

45

 (Specify:_________________________________________) c d e f

5. A district planning to use the Transferability provision must notify its SEA in writing 

of the intent to do so. Did your district provide such notification for the 2004-05 

school year? Mark one response. 

c No 

6. Some districts change their plans regarding the use of the Transferability authority during the course 

of a school year. Did your district actually exercise the Transferability authority during the 2004-05 

school year? Mark one response. 

d Yes 

c No if No Continue to next Question 

d Yes if Yes SKIP to Question 15
PART III-A: Questions for Districts NOT using Transferability 

7. To what extent did the following considerations factor into your district’s decision not to use 

Transferability in 2004-05? Mark one response in each row. 

Influence on Decision

Considerations No 

Influence 

Minor 

Influence 

Major 

Influence 

À À À

a. Was not aware of the Transferability option c d e

b. Did not have enough information about Transferability to make an informed 

decision c d e

c. District already had enough flexibility over use of funds without Transferability c d e

d. Amount of funds in eligible programs would have been too small to effectively 

carry out desired activities even after exercising the Transferability option c d e

e. District had been identified as in need of improvement under Title I of the 

ESEA, so its use of Transferability would have been restricted c d e

f. District was in corrective action under Title I of the ESEA, so it was not be 

eligible to use Transferability c d e

g. District was told by SEA that it could not use Transferability for a reason 

other than its accountability status c d e

h. Accounting requirements associated with Transferability would have been 

burdensome c d e

i. Concern about the possibility of an audit c

46

d e

j. Other 

 (Specify:______________________________________________________) c d e

8. Has your district used Transferability in years before 2004-05? c Mark one response. 

No 

d Yes 

c Yes 9. Is your district planning to use Transferability this year (2005-06)? 

 Mark one response. d

10. The table below lists the federal programs involved in the Transferability authority. For each program, 

please indicate the amount of your district’s allocation for the 2004-05 school year. If your district did not 

receive funds under a particular program, please enter “0” (zero) in the space provided. 

No 

e Undecided 

Initial Allocation for the 

2004-05 School Year 

Funding Category (in dollars) 

À

Title I Part A 

Improving the Achievement of Disadvantaged Children $ 

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 $ 

Title V Part A 

State Grants for Innovative Programs $ 
11. In the space below, please fill in the total amount of revenues your school district received from all 

sources for the 2004-05 school year. 

Total district revenues from all $ sources (2004-05 School Year) 

Fill in dollar amount 

12. Around the first of October 2004, what was the Average 

Daily Attendance (ADA) level for grades preK-12 in your 

district? Fill in response. Students 

13. Based on the description of Transferability above, consider the following changes that could be made 

to the terms of the provision. How would each of these possible changes affect your interest in pursuing 

Transferability? Mark one response in each row. 

Level of Interest in Transferability if Change is Made

Change in Transferability provision Lower 

Interest 

About the 

Same 

Somewhat 

Higher 

Much 

Higher 

À À À À

a. If new funding was provided to participating districts over and 

above existing allocations in eligible programs c d e f

b. If funds could be transferred from a larger number of federal 

programs c d e f

c. If eligible funds could be transferred to a larger number of 

federal programs c d e f

d. If transferred funds were not restricted by the rules and 

regulations of the receiving program c d e f

e. If a greater proportion of funds in eligible programs could be 

transferred c d e f

f. If the terms of participation were not affected by a district’s 

Title I accountability status c d e f

g. If accounting requirements were relaxed or assistance was 

offered to maintain necessary records c d e f

h. Other 

 (Specify:_________________________________________) c d e f

47
48

14. This question asks you to provide a basic educational needs assessment for your district. For each 

of the areas of possible need listed below, please indicate how much of a priority this area is for your 

district. Mark one response in each row. 

Priority 

Level 

Possible Areas of Need Low Medium High 

À À À

Instruction 

a. Highly qualified teachers c d e

b. Highly qualified paraprofessionals c d e

c. Curriculum and instructional materials c d e

d. Educational technology c d e

Support for Special Programs and Services

e. Extended-time programs (e.g., before- or after-school, weekend) c d e

f. Summer programs c d e

g. Supplemental educational services (SES) provided under Title I c d e

h. Transportation for Title I school choice participants c d e

Performance on Specific Academic Outcomes 

i. English/Language Arts c d e

j. Mathematics c d e

k. Science c d e

l. Attendance rates c d e

m. Graduation rates c d e

n. Other (Specify: _____________________________________________) c d e

Performance of Specific Student Groups 

o. Racial and ethnic minorities c d e

p. Low-income students c d e

q. Students with disabilities c d e

r. Limited English Proficiency (LEP) students c d e

s. Students in low-performing schools c d e

t. Kindergarten and pre-K students c d e

u. Elementary students c d e

v. Middle school students c d e

w. High school students c d e

You have completed the survey. 

Thank You! 

Please return your completed questionnaire to: 

Kathleen Feehan 

Education Policy Center 

The Urban Institute 

2100 M Street, NW 

Washington, DC 20037
49

PART III-B: Questions for Districts that used Transferability in 2004-05 

15. We would like to learn about the way in which the Transferability authority is administered in your 

district. In Column A, please indicate who is responsible for deciding which applicable funds will be used 

under the provision. In Column B, indicate who is responsible for overall management or oversight of the 

Transferability authority. If more than one actor shares these responsibilities, mark all responses that 

apply. 

Responsibility for Transferability 

Mark all responses that apply in each column. 

(A) (B) 

District Actors Decisions about which funds to 

use under Transferability 

Management or Oversight 

of Transferability 

À À

a. Superintendent c c

b. School board d d

c. Financial officer e e

d. General administrator for all federal programs f f

e. Administrators for individual federal programs g g

f. Administrator assigned specifically to manage 

Transferability h h

g. Other 

 (Specify:_____________________________________) i i

16. Districts choose to use the Transferability authority for a variety of reasons. In the space below, 

briefly describe why your district decided to use this form of flexibility. In particular, please be sure to 

include: (1) the particular goals you hoped to achieve and (2) the specific programs or activities

supported by the funds that have been transferred under this authority. You may attach an additional 

sheet if you require more space to respond. 
50

17. Did your district use its Transferability authority in any of the following ways? 

Mark one response in each row. 

Transferability used to No Yes 

À À

a. Increase the amount of federal funds available for high-priority programs c d

b. Concentrate federal resources for a smaller number of programs c d

c. Initiate new activities that would not have been possible without exercising 

Transferability c d

d. Maintain a stable level of effort for on-going activities that have been affected by 

budgetary constraints c d

e. Target particular student groups or outcomes c d

18. Please describe the way in which your district’s use of Transferability has affected the way you 

allocate federal funds across eligible program categories. 

In the first column below please indicate the amount of funding your district was originally allocated for the past 

school year (2004-05) for each program. If your district did not receive funds under a particular program, please 

enter “0” (zero) in the space provided. In the second column please enter the amount of funds allocated to those 

program activities after using Transferability. 

Funding Category 

Initial Allocation for the 

2004-05 School Year 

(in dollars) 

Allocation after 

exercising Transferability 

(in dollars) 

À À

Title I Part A 

Improving the Achievement of Disadvantaged Children $ $ 

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 $ $ 

Title V Part A 

State Grants for Innovative Programs $ $ 

 Total 

 (Values in two columns should be equal) $ $ 

19. In the space below, please fill in the total amount of revenues your school district received from 

all sources for the 2004-05 school year. 

Total district revenues from all sources 

(2004-05 School Year) $

Fill in dollar amount 
20. Around the first of October 2004, what was the Average 

Daily Attendance (ADA) level for grades preK-12 in your 

district? Fill in response. Students 

21. This question asks you to provide a basic educational needs assessment for your district. For each 

of the areas of possible need listed below, please provide two pieces of information. First, in Column A

indicate how much of a priority this area is for your district. Next, in Column B indicate whether your 

district used Transferability authority to address that area of need. 

For each row, mark one response in Column A and one response in Column B. 

(A) (B) 

Priority 

Level 

Used 

Transferability 

to address need? 

Low Medium High No Yes Possible Areas of Need 

À À À À À

51

Instruction 

a. Highly qualified teachers c d e c d

b. Highly qualified paraprofessionals c d e c d

c. Curriculum and instructional materials c d e c d

d. Educational technology c d e c d

Support for Special Programs and Services

e. Extended-time programs (e.g., before- or after-school, 

weekend) c d e c d

f. Summer programs c d e c d

g. Supplemental educational services (SES) provided under Title I c d e c d

h. Transportation for Title I school choice participants c d e c d

Performance on Specific Academic Outcomes 

i. English/Language Arts c d e c d

j. Mathematics c d e c d

k. Science c d e c d

l. Attendance rates c d e c d

m. Graduation rates c d e c d

n. Other 

 (Specify: ________________________________________) c d e c d

Performance of Specific Student Groups 

o. Racial and ethnic minorities c d e c d

p. Low-income students c d e c d

q. Students with disabilities c d e c d

r. Limited English Proficiency (LEP) students c d e c d

s. Students in low-performing schools c d e c d

t. Kindergarten and pre-K students c d e c d

u. Elementary students c d e c d

v. Middle school students c d e c d

w. High school students c d e c d
22. Did your district use Transferability in years before 2004-05? c Mark one response. 

No 

d Yes 

c No 23. Is your district planning to use Transferability this year (2005-06)? 

 Mark one response. d Yes 

e Undecided 

24. Please consider the following changes that might be made to the terms of the Transferability 

provision. How would each of these possible changes affect your interest in continuing to use this 

provision ? Mark one response in each row. 

Level of Interest in Continuing to use Transferability 

if Change is Made

Lower 

Interest 

About the 

Same 

Somewhat 

Higher 

Much Change in Transferability provision Higher 

À À À À

a. If new funding was provided to participating districts over 

and above existing allocations in eligible programs c d e f

b. If funds could be transferred from a larger number of 

federal programs c d e f

c. If eligible funds could be transferred to a larger number 

of federal programs c d e f

d. If transferred funds were not restricted by the rules and 

regulations of the receiving program c d e f

e. If a greater proportion of funds in eligible programs 

could be transferred c d e f

f. If the terms of participation were not affected by a 

district’s accountability status c d e f

g. If accounting requirements were relaxed or assistance 

was offered to maintain necessary records c d e f

h. Other 

 (Specify:_____________________________________) c d e f

You have completed the survey. 

Thank You!

Please return your completed questionnaire to: 

Kathleen Feehan 

Education Policy Center 

The Urban Institute 

2100 M Street, NW 

Washington, DC 20037

52
53

Appendix D: Transferability Authority District Interview Protocols 

1. Participants 

2. Nonparticipants 

 
54
55

STUDY OF NO CHILD LEFT BEHIND

FLEXIBILITY PROVISIONS

TRANSFERABILITY AUTHORITY

DISTRICT INTERVIEW PROTOCOL

(TRANSFERABILITY PARTICIPANT)

Thank you for agreeing to speak with me today. I’m ____________ from the Urban Institute in 

Washington, D.C. We’re conducting this phone interview on behalf of the U.S. Department of 

Education, which has commissioned the Urban Institute to conduct a case study of School 

Districts’ experiences with Transferability. The goal of this study is to provide other districts 

and states with information about participation in this program. 

In the fall your district participated in a survey we conducted to learn about the Transferability 

provision of the No Child Left Behind Act. The Transferability authority allows districts to 

exercise expanded flexibility over the way they use funds allocated under certain federal 

programs. That survey examined the reasons districts choose to use (or not to use) 

Transferability and the ways in which participating districts are making use of this flexibility. 

Based on that survey, we learned that your district was using Transferability last year (that is, 

during the 2004–05 school year). Today, I would like to ask you a few questions to learn 

more about your district’s experiences with Transferability. 

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 or your district’s name in connection with your responses. We will 

not provide any individually identifying information in reporting your responses and avoid using 

specific titles. We thank you in advance for providing the expertise and time needed for this case 

study. 

 
56
Respondent Background 

. 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 your current position? 

 ____ What is your professional background? 

 ____ How long have you been in the education field? 

 ____ What were your previous administrative and teaching positions? 

Needs for Flexibility 

. Please think back to the time before your district started using Transferability. Did the 

district feel that there were certain constraints on the use of these federal funds that 

prevented you from effectively addressing your local educational priorities? If so, 

please describe these constraints. 

 

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 on the way your district used available 

federal funds? 

. We will discuss your strategy for using Transferability in more depth shortly. But 

generally speaking, what prompted your district to adopt Transferability? Where there 

particular situations or events that resulted in a need for additional flexibility over the 

use of federal funds that Transferability helped you to meet? 

Probe if not offered: 

 ____ Has your district experienced any major shifts in its financial 

situation in recent years that required more flexibility over use of 

federal funds? 

57
Adopting Transferability 

4. Could you describe the decision-making process that led to your district adopting 

Transferability? 

Probe if not offered: 

 ____ Who were key actors (not identified by name) and organizations involved 

in this process? 

 ____ As [respondent title], what was your role in this process? 

 ____ Did your district consult with the local private schools when deciding 

whether and how to pursue Transferability? 

 ____ How long did this deliberation process take? Was there sufficient time to 

investigate thoroughly before the deadline for notifying your SEA? 

5. What were the major pros and cons your district considered when deliberating over whether 

to exercise Transferability? 

6. Has your district had any communication about Transferability with your state education 

agency (SEA), either at the time you were deciding whether to adopt Transferability or since? 

If so, what is the nature of this dialog? 

Probe if not offered: 

 ____ Did your SEA inform you of restrictions or limitations on fund transfer 

(amounts or types of funds, numbers of transfers)? 

 ____ Did your SEA inform you of restrictions on use of Transferability related 

to AYP or school improvement status? 

 ____ Were you informed about procedures for financial reporting? 

Strategies for Using Transferability 

Now, I would like to talk about your district’s strategy for using Transferability in 

more detail. 

. Is your district’s strategy for using Transferability documented in a formal plan? If so, 

who has access to that plan? 

58
59

8. What educational goals does your district hope to achieve by using Transferability? 

 

Probe if not offered: 

 ____ What specific achievement outcomes were targeted? 

 ____ Were other academic outcomes targeted? 

 ____ Was support for teacher or paraprofessional quality targeted? 

 ____ How do Transferability goals relate to your district’s other educational 

priorities and improvement strategies? 

9. How does using Transferability allow you to better meet these goals? In other words, what 

specific activities or programs are being supported by the funding transferred? 

10. To what extent would it be possible to undertake these efforts without using Transferability? 

11. Are these efforts targeted to particular groups of students? For example, does your strategy 

focus on specific demographic groups, low-income students, students with disabilities, 

students with limited English proficiency, or students in low performing schools? 

12. Does your plan for exercising Transferability include concrete benchmarks for 

implementation of activities or improvement in student (or other) outcomes? 

If yes ... 

What are these benchmarks? 

For student academic outcomes, how do these benchmarks compare to your state’s 

annual measurable objectives for making AYP? 
60

Transferability Accounting Walkthrough 

The survey your district completed in the fall asked for a summary of the ways in which 

applicable funds were used under the Transferability provision for the 2004–05 fiscal year. 

Based on this information, we have prepared worksheets that can be used to track the way in 

which funds allocated to each of the eligible federal programs were utilized under 

Transferability. These new worksheets examine the allocation and the use of Transferability in 

prior years. If specific numbers are not available, please think generally about the trends in how 

money has been allocated before and after exercising Transferability in prior years. 

This section of the interview will be repeated for each year in which 

Transferability was used (starting with the first year the provision was employed). 

Information obtained from district surveys will be will be pre-entered into 

worksheets. These summaries will be sent to the respondent for review prior to 

the interview. Data will be updated and corrected during the interview as 

applicable. 

Please look at the worksheets we sent you earlier, which summarize the federal funding 

your district receives for programs involved with Transferability. 

Please look at the worksheets we sent you earlier, which summarize the federal funding 

your district receives for programs involved with Transferability. 

13. Let’s start with your district’s allocations under these programs for the [200__] school year. 

For each of these programs, I would like you to answer several brief questions. Beginning 

with [program] ... 

13a. What was the initial amount of the federal allocation? 

13b. How much of the funding allocated to this program was utilized under the 

Transferability provision? 

Summary questions after filling out the worksheet 

13c. Has the way you exercised Transferability changed since using this provision? If yes, 

why have these changes occurred? 

13d. Have trends in carryover funding changed for these programs over the past three years? 

Why or Why not? 

If specific numbers are not available: 

13e. What are the general trends in the use of these Title funds in the past three years? Has the 

amount of money used for activities after exercising Transferability changed in the past three 

years? What specific changes have occurred? Why were these changes made? Have trends in 

carryover funding changed in this time period? Why or why not? 
14. Several of the programs into which funds can be transferred under the Transferability 

authority have provisions for statutory set-asides. Specifically, these are: Title I, Part A; 

Title II, Part D; and Title IV, Part A. When transferring funds into these programs, how did 

your district determine and account for the amounts to be set aside? 

15. Did exercising Transferability affect your district’s ability to maintain services under this set 

of programs at levels comparable to those supported prior to using Transferability? If so, how 

was each of these programs affected? 

16. Have changes in your district’s AYP or school improvement status affected the way you have 

used Transferability? 

Probe further if not offered: 

 ____ Did making AYP (or failing to do so) result in a shift of priorities or 

targets? 

 ____ Has your district been identified as in need of improvement under Title I 

of the ESEA (limiting the amount of funds that can be transferred and 

their uses)? If so, has that affect the way your district used 

Transferability? 

Record-Keeping and Reporting 

Now I would like to ask you about the record-keeping and reporting associated with 

exercising Transferability. 

17. How does your district maintain financial records for documenting the way in which 

applicable funds are transferred under Transferability? 

Probe further if necessary in order to classify record keeping methods: 

 ____ How are funds are moved from one program account to another? 

 ____ Is a new separate account is established for transferred funds? 

 ____ Do transferred funds remain in original account but documentation is 

maintained to show how those funds have been reclassified? 

 ____ Is there some other method of accounting? 

18. What other financial and program information is your district required to report to state 

agencies as part of exercising Transferability? Has your district been formally reviewed or 

audited since it started using Transferability? 

61
19. Do these record-keeping and reporting requirements differ from routine procedures (i.e., what 

you would be expected to do if you weren’t exercising Transferability)? If so, did your 

district encounter any challenges in meeting these requirements? 

20. Has the amount of time and effort your district devotes to reporting and record-keeping 

changed as a result of exercising Transferability? If so, how? 

21. Has your state educational agency provided any guidance or assistance with respect to 

maintaining financial or programmatic documentation associated with Transferability? 

62

Now I would like to ask you some questions about your experience using Transferability. 

22. To what extent has Transferability helped your district to better utilize federal funds to meet 

23. Earlier you described the kinds of educational activities your district supports under the 

ed 

24. In each of these areas—allocating funds and promoting activities—are there particular ways 

Probe further if not offered: 

eds for greater flexibility be addressed by revising your 

 ____ district need to address these 

Experiences with the Transferability Provision 

your local needs? 

federal programs associated with Transferability. To what extent has Transferability help

your district to promote the educational activities and programs you targeted with applicable

funds? 

in which Transferability has been especially helpful to your district? Are there areas where 

Transferability is not currently meeting your needs for additional flexibility? 

 ____ Could these ne

current strategy for using the Transferability authority (i.e., operating 

within the current rules of the provision)? 

If not, what additional flexibility would your

needs? 
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ransferability and Targeted Goals 

e have just discussed the ways in which Transferability can assist participants in directing 

t to 

25. Earlier you mentioned some specific performance goals that your district is targeting with 

26. Do you think Transferability has helped your district’s efforts to make AYP? If so, how? 

Probe if not offered: 

as your district AYP status before and after Transferability? 

g students and schools 

If no, 

What are your reasons for not pursuing Transferability next year? Do you think you 

If yes, 

Do you anticipate making any changes to your strategy? This might include things like 

Plans for Using Transferability in the Future 

T

W

resources to better meet local educational activities. Now I would like to ask about the exten

which Transferability has helped your district work towards the educational goals it has targeted. 

It can sometimes take a while for the effects of programs like Transferability to show up in 

certain outcomes like student achievement. So I am asking you to share your impressions of

how Transferability may be contributing to progress on these outcomes so far. 

Transferability. Have you seen improvement in these outcomes since starting to use 

Transferability? How do you think Transferability might have contributed to these 

improvements? 

 ____ What w

 ____ Have overall performance levels changed? 

 ____ Have gaps between high- and low-performin

changed? 

7. Does your district plan to continue using Transferability next year? 

might use Transferability again at some point in the future? 

changing: the type or amount of applicable federal funds you transferred; the set of 

activities you support with transferred dollars; or the way these efforts are targeted to

particular groups of students or particular outcomes. 
Conclusion

 

28. Overall, what would you say has been the best thing about using Transferability? 

29. What is the least positive aspect of exercising Transferability or the part of the provision you 

would most like to see changed? 

30. Are there any other issues that we have not talked about that you think are important for 

understanding your district’s experience using Transferability? 

Probe if not offered: 

 ____ Are there unintended consequences—either positive or negative—as a 

result of using Transferability (e.g., related to fund allocation, support for 

programmatic activities, or student 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 Transferability. 

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STUDY OF NO CHILD LEFT BEHIND

FLEXIBILITY PROVISIONS

TRANSFERABILITY AUTHORITY

DISTRICT INTERVIEW PROTOCOL

(TRANSFERABILITY NONPARTICIPANT)

Thank you for agreeing to speak with me today. I’m ____________ from the Urban Institute in 

Washington, D.C. We’re conducting this phone interview on behalf of the U.S. Department of 

Education, which has commissioned the Urban Institute to conduct a case study of School 

Districts’ experiences with Transferability. The goal of this study is to provide other districts and 

states with information about why districts may choose to participate or not participate in this 

program. 

In the fall your district participated in a survey we conducted to learn about the Transferability 

provision of the No Child Left Behind Act. The Transferability authority allows districts to 

exercise expanded flexibility over the way they use funds allocated under certain federal 

programs. That survey examined the reasons districts choose to use (or not to use) 

Transferability and the ways in which participating districts are making use of this flexibility. 

Based on that survey, we learned that your district was not using Transferability last year (that 

is, during the 2004–05 school year). Today, I would like to ask you a few questions to learn 

more about why your district decided not to use Transferability. 

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 or your district’s name in connection with your responses. We will 

not provide any individually identifying information in reporting your responses and avoid using 

specific titles. We thank you in advance for providing the expertise and time needed for this case 

study. 
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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 your current position? 

 ____ What is your professional background? 

 ____ How long have you been in the education field? 

 ____ What were your previous administrative and teaching positions? 

2. In general, how familiar are you with the Transferability provision of NCLB? 

Probe if not offered: 

 ____ Were there any barriers to obtaining information about the Transferability 

provision? 

 ____ Was there any particular information or technical assistance that was 

unavailable but would have been helpful? 

If respondent is unfamiliar with the provision, describe the provision to the respondent using the 

text below: 

The Transferability provision of ESEA allows a local educational agency to transfer up to 

50 percent of formula-based funds from certain federal programs to its allocation under 

other eligible programs in order to use these resources more effectively. Transferred 

funds must be used in accordance with the rules and requirements of the receiving 

program. The eligible programs are: 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 State Grants); and Title V, Part A, (State Grants 

for Innovative Programs). Districts exercising Transferability may also transfer funds into 

but not out of Title I, Part A. 

3. Were you involved in your district’s decision not to use Transferability? If so, what was your 

role in that process? 
REASONS FOR NOT USING TRANSFERABILITY 

4. Could you describe to me the reasons your district has decided not to use Transferability? 

Please feel free to mention kind of decision-making process that was involved and the major 

pros and cons that might have been discussed (Please make sure all of the probes below are 

covered). 

Probe if not offered: 

 ____ Was the amount of funding allocated to these eligible programs a 

consideration in not using Transferability? 

 ____ Was the particular set of applicable programs under Transferability a 

consideration? That is, would you have been more likely to use 

Transferability if a larger number of programs were considered 

applicable funding sources or if funds could be used for activities 

authorized under a larger number of programs? 

 ____ Did your district have any concerns about its ability to maintain the 

accounting records necessary to document the use of eligible funds, as 

required under the provision? 

 ____ Funds transferred under the Transferability provision must be used 

according to the rules and regulations of the programs receiving the 

funds. Was this aspect of the provision a factor in your district’s decision 

not to use Transferability? 

 ____ Under the terms of the Transferability provision, limits are placed on the 

amount of funds that can be transferred. For example a district not 

identified as “in need of improvement” under Title I of NCLB may 

transfer up to 50 percent of the formula-based funds in eligible programs. 

Was this limit a factor in your district’s decision not to use 

Transferability? 

 ____ The extent to which a district can use Transferability depends on its 

accountability status. Specifically, districts identified as “in need of 

improvement” under Title I of NCLB may transfer no more than 30 

percent of their formula allocations from the eligible programs and must 

use those transferred funds for improvement activities authorized under 

Section 1116 of Title I. In addition, districts identified for corrective 

action may not exercise Transferability. Was your district’s academic 

performance and accountability status a factor in its decision not to 

employ Transferability? 

CONCLUSION 

5. Does your district have any current unmet needs for greater flexibility over the way it uses its 

federal funding allocations to address local educational priorities? If so, what are these 

needs? 

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6. Are there any other issues that we have not talked about that you think are important for 

understanding the reasons your district decided not to use Transferability? 

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 Transferability. 
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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