Report to the Secretary of Education

United States Government Accountability Office

GAO

December 2004 NO CHILD LEFT 

BEHIND ACT 

Education Needs to 

Provide Additional 

Technical Assistance 

and Conduct 

Implementation 

Studies for School 

Choice Provision 

GAO-05-7 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-7.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Marnie Shaul at 

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

Highlights of GAO-05-7, a report to the 

Secretary of Education

December 2004

NO CHILD LEFT BEHIND ACT 

Education Needs to Provide Additional 

Technical Assistance and Conduct 

Implementation Studies for School 

Choice Provision 

About 1 in 10 of the nation’s 50,000 Title I schools were identified for school 

choice in each of the first 2 years since enactment of the No Child Left 

Behind Act (NCLBA) of 2001. The proportion of schools identified for choice 

varied by state. About 1 percent of eligible children, or 31,000 students, 

transferred in school year 2003-2004. However, little is known about the 

students who did and did not transfer or factors affecting parents’ transfer 

decisions. Education has launched a study that will yield some information 

on these topics. 

Percentages of Title I Schools Identified for School Choice in 2003-2004 by State 

Source: GAO analysis of state data.

0 through 4%

5 through 10%

11 through 47%

Officials in most of the 8 districts GAO visited said they welcomed NCLBA’s 

emphasis on improved performance, but had difficulties providing choice 

because of tight timeframes and insufficient classroom capacity. Final state 

determinations of the schools that met state yearly performance goals were 

not generally available before the school year started, so offers of transfers 

were based on preliminary determinations. District officials expressed 

concern that parents had inadequate time and information to make an 

informed decision. Parents were offered at least 2 possible schools as 

transfer options, but many of these schools had not met state performance 

goals in the most recent year. Because of limited classroom capacity in 4 of 

the districts, some students did not receive the opportunity to transfer. For 

students who transferred, transportation was provided on school buses, 

public transit or personal cars, and most districts spent less than 7 percent 

of the pool of funds that NCLBA required be set aside for that purpose in 

school year 2003-2004. 

Education issued extensive guidance on choice. However, the complexity of 

providing school choice raises a number of issues that have not been 

addressed in guidance available through October 2004, such as how to 

handle cases where schools receiving transfers later are identified for choice 

and how to expand capacity in the short-term within budgetary constraints. 

The school choice provision of the 

No Child Left Behind Act (NCLBA) 

of 2001 applies to schools that 

receive Title I funds and that have 

not met state performance goals 

for 2 consecutive years, including 

goals set before the enactment of 

NCLBA. Students in such schools 

must be offered the choice to 

transfer to another school in the 

district. GAO undertook this review 

to provide the Congress a report on 

the first 2 years of the 

implementation of NCLBA school 

choice. GAO reviewed (1) the 

number of Title I schools and 

students that have been affected 

nationally, (2) the experiences of 

selected school districts in 

implementing choice, and (3) the 

guidance and technical assistance 

that Education provided. 

GAO collected school performance 

data from all states, interviewed 

Education officials, and visited 8 

school districts in California, 

Illinois, Ohio, Mississippi, 

Pennsylvania, Tennessee, and 

Washington. 

What GAO Recommends

GAO recommends that Education 

monitor issues and promote 

promising practices related to 

limited classroom capacity, help 

states develop strategies for better 

informing parents about school 

choice, and include in its planned 

NCLBA implementation study, an 

examination of the academic 

outcomes and retention rates of 

transferring students. Education 

generally agreed with GAO’s 

recommendations. 
Page i GAO-05-7 No Child Left Behind Act 

Letter 1

Results in Brief 2 

Background 4 

About 1 in 10 Schools Identified for Choice in the First 2 Years of 

NCLBA, and 1 Percent of Eligible Students Transferred in 2003-

2004 8 

Implementation of Choice Was Challenging in Selected Districts 18 

Education Issued Extensive Guidance on Choice, but Questions 

Remain as Implementation Proceeds 28 

Conclusions 34 

Recommendations for Executive Action 35 

Agency Comments and Our Evaluation 36 

Appendix I Scope and Methodology 38 

Appendix II NCLBA Interventions for Schools Not Meeting Yearly 

Performance Goals Over Time 42 

Appendix III Number of Title I Schools in Each State Identified 

for Choice in School Year 2002-2003 43 

Appendix IV Number of Title I Schools in Each State Identified 

for Choice in School Year 2003-2004 45 

Appendix V Number of Students in Each State Transferring 

under Choice Option in First 2 Years of NCLBA 47 

Appendix VI Poverty and Minority Rates of Schools Required to 

Offer Choice and Schools Offered as Transfer 

Options 49 

Contents 
Page ii GAO-05-7 No Child Left Behind Act 

Appendix VII Comments from the Department of Education 51 

Appendix VIII GAO Contacts and Staff Acknowledgments 54 

GAO Contacts 54 

Staff Acknowledgments 54 

Related GAO Products 55 

Tables 

Table 1: Students Eligible but Not Transferring from Elementary 

and Middle Schools Identified for Choice Compared with 

Students Transferring in 2003-2004 in One District Visited 18 

Table 2: Milestone Dates for Implementation of Choice for School 

Year 2003-2004 in Six Districts We Visited 20 

Table 3: Transfer Options Offered Parents of Elementary School 

Students in Seven Districts We Visited 23 

Table 4: Title I Status and Performance of Schools Offered as 

Transfer Options for 2003-2004, by District 24 

Table 5: Poverty and Minority Rates of Schools Required to Offer 

Choice and Schools Offered as Transfer Options in Fresno 25 

Table 6: Poverty and Minority Rates of Schools Required to Offer 

Choice and Schools Offered as Transfer Options in Akron 25 

Table 7: Number of Students Unable to Transfer Due to Capacity 

Limitations in 2003-2004 26 

Table 8: Transportation Allocations and Projected Expenses for 

School Year 2003-2004, by District 28 

Table 9: Dates, Type, and Title of Guidance or Technical Assistance 

Provided by Education on School Choice under NCLBA 30 

Table 10: Characteristics for 2003-2004 of Eight Districts We Visited 40 

Figures 

Figure 1: Number of Title I Schools and Number Identified for 

School Choice in 50 States, the District of Columbia, and 

Puerto Rico in School Years 2002-2003 and 2003-2004 10 
Page iii GAO-05-7 No Child Left Behind Act 

Figure 2: Demographics of Students Enrolled at Title I Schools 

Identified and Not Identified for Choice in School Year 

2003-2004 11 

Figure 3: Proportion of Schools Identified for Choice at Various 

Grade Spans Compared with All Title I Schools in School 

Year 2003-2004 12 

Figure 4: Percentage of Title I Schools Identified for School Choice, 

by State, in School Year 2003-2004 13 

Figure 5: Number of Title I Students Eligible for Choice and 

Number That Transferred in 42 States, the District of 

Columbia, and Puerto Rico in School Year 2003-2004 15 

Figure 6: Timeline for Tacoma Public Schools, 2003 21 

Abbreviations 

NCLBA No Child Left Behind Act 

NCES National Center for Education Statistics 

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-05-7 No Child Left Behind Act 

December 10, 2004 

The Honorable Rod Paige 

The Secretary of Education 

Dear Mr. Secretary:

Increased school choice is one of the cornerstones of The No Child Left 

Behind Act (NCLBA) of 2001. Signed into law in January 2002, this major 

legislation is designed to improve the academic achievement of all 

students by requiring states to set annual performance goals for schools 

that would result in all students being proficient in reading and math by 

school year 2013-2014. Title I of the act provides financial support to 

improve the education of low-income students in high-poverty schools. In 

2004, about 50,000 public schools—over half of all public schools 

nationwide—received a share of $12 billion in Title I funds. While all 

public schools are expected to meet state performance goals, some of the 

law’s provisions apply only to Title I schools, for instance, the school 

choice requirement. Title I schools are identified for choice when 

performance goals, including goals set before the enactment of NCLBA, 

are not met for 2 or more years in a row. In general, all students enrolled 

in such schools must be offered the option of transferring to other schools 

in the district that have not been identified for choice and transportation 

must be provided. Transfer requests cannot be denied for lack of 

classroom capacity, according to federal regulations. While states set the 

performance goals and schools are judged on the performance of their 

students, the nation’s 15,000 school districts are held responsible for 

implementing the school choice requirements of NCLBA, starting in school 

year 2002-2003. 

The school choice provision of NCLBA is intended to provide a unique 

opportunity for students in schools not meeting state goals to attend 

schools that have had greater success meeting these goals. However, little 

is known about how states and districts are implementing the provision 

and how many schools and students are participating. We undertook this 

review to provide the Congress an early report on the first 2 years of 

NCLBA implementation, with a more detailed look at the experiences of 

8 school districts. Specifically, we address: 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-7 No Child Left Behind Act 

1. To what extent have Title I schools been affected by the school choice 

provision of NCLBA in terms of the number of schools identified for 

choice and the number of students transferring? 

2. What were the experiences of selected school districts in 

implementing the choice provision? 

3. What guidance and technical assistance did the Department of 

Education provide states and districts as they implemented public 

school choice? 

To determine the numbers of schools and students affected by choice 

nationwide during the first 2 years of NCLBA, we compiled and analyzed 

data from a variety of sources, including our surveys of state education 

agencies and school districts, Department of Education (Education) 

reports of state agencies’ data, and other Education databases. We 

assessed the reliability of these data and determined that they were 

adequate for our purposes. To obtain information on district 

implementation, we visited 8 districts that had schools identified for 

choice and interviewed district and school officials about their 

experiences. Located in seven states—California, Illinois, Ohio, 

Mississippi, Pennsylvania, Tennessee, and Washington—these districts 

were selected to achieve variation in geographic, demographic, and 

program characteristics. All but one district we visited had students 

transferring under choice. One rural district —North Panola, Mississippi—

offered supplemental educational services instead of transfers under 

choice, as permitted, because the middle school identified for choice was 

the only middle school in the district. To ascertain the role of Education in 

providing guidance and technical assistance, we reviewed regulations and 

other forms of guidance available from Education and interviewed 

officials at the federal, state, and district levels, as well as representatives 

of national educational organizations and other experts in the area. See 

appendix I for a more detailed description of our methodology. We 

conducted our work from October 2003 through November 2004 in 

accordance with generally accepted government auditing standards. 

Since passage of NCLBA, about 1 in 10 schools receiving federal funds for 

low-income students under Title I—approximately 1 in 20 public schools 

nationwide—has been identified for school choice. In school year 2002-

2003, the first year under NCLBA, about 5,300 schools attended by 3 

million children were identified for choice; in the following school year, 

this number rose to about 6,200 schools. These schools had larger 

Results in Brief 
Page 3 GAO-05-7 No Child Left Behind Act 

proportions of minority and low-income students enrolled than Title I 

schools that were not identified for choice. Across states, the percentage 

of Title I schools identified for choice varied considerably. A number of 

factors may contribute to this variation, including differences in the 

diversity and size of school populations, as well as differences in states’ 

approaches to defining their yearly performance goals. Overall, about 

19,000 students transferred under the NCLBA choice option in the first 

year and an additional 31,000 in the second year, representing about 

1 percent of those eligible. While little is known about the factors that 

affect transfer decisions or about the students involved, Education has 

contracted for a study that will examine the reasons that parents give for 

their transfer decisions and identify students’ demographic characteristics. 

Part of this study, still under design, is intended to examine achievement 

outcomes of students who transfer. Our analysis of data from one district 

showed that lower percentages of transferring students were minorities 

and lower percentages were from low-income families than was the case 

for the eligible students who did not transfer. 

Officials at most of the 8 districts we visited said that they welcomed 

NCLBA’s increased emphasis on improved performance but had 

difficulties providing school choice due to tight timeframes and 

insufficient classroom capacity. One district received final data on schools’ 

performance about a month before school started in the fall; the other 

seven districts received final data weeks or even several months after the 

school year had begun. In order to notify parents of their options before 

the start of the school year as required by law, most districts relied on 

preliminary data to make school status determinations, putting the district 

at risk of misidentifying schools for choice and misinforming parents 

about their transfer options. District officials expressed concerns that 

parents may not always fully understand their options or have adequate 

time or information to make a fully informed decision. The total number of 

schools offered as transfer options to any one parent ranged from 2 to 

over 30, depending on the district, but many schools offered were similar 

to the students’ current schools. Limitations in available classroom 

capacity in 4 districts resulted in some eligible students not having an 

opportunity to transfer. District officials provided various explanations for 

why this occurred, including lack of feasible alternatives to increase 

capacity. Districts employed a variety of strategies to provide 

transportation to transferring students, including school buses, subsidized 

passes on public transit, and stipends to parents, and most districts we 

visited spent less than 7 percent of the pool of funds that NCLBA required 

to be set aside for transportation and supplemental services costs. 
Page 4 GAO-05-7 No Child Left Behind Act 

Education issued guidance and final regulations on school choice in 

December 2002, after the start of the first school year under NCBLA. Most 

districts implemented school choice based on the preliminary guidance 

contained in letters they received in June 2002, but some issues remained 

unclear. Additional assistance was provided subsequently in the form of 

policy letters, training tools, and presentations at conferences. Education 

issued updated guidance in February 2004, after the start of the second 

school year under NCLBA, and followed with a handbook on promising 

practices in the implementation of school choice. While district officials 

we visited generally had access to Education’s guidance, questions 

concerning the implementation of school choice remained, for example, 

how to offer choice when physical capacity is limited. Other questions 

involved issues that may arise as NCLBA implementation progresses, for 

instance, districts’ responsibilities if a school to which students have 

transferred subsequently does not meet state goals and is itself required to 

offer choice. 

To help state and district officials in implementing choice, we are 

recommending that Education monitor issues and promote promising 

practices related to limited physical capacity and assist in developing 

strategies to better inform parents about their transfer options. In addition, 

we are recommending that Education undertake a rigorous study that will 

provide more insight on the effects of school choice. In its comments on a 

draft of this report, Education agreed with our recommendations on 

capacity and on parental information. Education also agreed to consider 

including an examination of academic outcomes and retention rates of 

transferring students in its planned NCLBA implementation study. 

Education’s comments appear in appendix VII. 

The Department of Education is responsible for overseeing state 

implementation of NCLBA, which amended and reauthorized the 

Elementary and Secondary Education Act. Title I of this act authorizes 

funds to states for local school districts with high concentrations of 

children from low-income families to improve the academic achievement 

of students failing or at risk of failing to meet state standards. Title I is the 

single largest federal program supporting education in kindergarten 

through 12th grade,1

 supplying over $12 billion in federal funds in 2004. 

 1

In this report, we refer to Title I, Part A of the Elementary and Secondary Education Act as 

“Title I.” Other Parts of Title I (Parts B, C, and D) are targeted at specific populations or 

purposes and are commonly referred to by their program names, such as Even Start. 

Background 
Page 5 GAO-05-7 No Child Left Behind Act 

These funds are designed to supplement the instructional services and 

support that districts and schools provide. Title I and other federal funding 

represent about 8 percent of total spending on elementary and secondary 

public education, with the remaining 92 percent provided primarily by 

states and localities. Title I funds are distributed by formula to state 

education agencies, which retain a share but pass through most of the 

funds to school districts.2

 Districts with at least a minimum number and 

percentage of low-income students receive a share of Title I funds. The 

districts are required to distribute Title I funds first to schools with high 

poverty rates—over 75 percent—and then to eligible schools in rank order 

of poverty either districtwide or within grade spans. Because school 

enrollment numbers and demographics may vary from one year to the next 

and because districts have some discretion in how many and which 

schools receive Title I funds, the status of schools as Title I or not Title I 

can vary from one year to the next. Approximately 25 million students 

were enrolled in schools eligible for Title I funds in school year 2002-2003 

out of a total of about 49 million students in all schools nationwide, 

according to Education.3

Stronger accountability for educational results is one of several education 

reform principles embodied in NCLBA and it builds on requirements in 

place under prior law. Prior to NCLBA, states were expected to have 

accountability systems that included standards for what students should 

learn and tests every year in certain grade levels to measure their 

knowledge of reading and mathematics.4

 Each year, increasing 

percentages of students were expected to demonstrate their proficiency 

on these tests, and schools were judged on their ability to make adequate 

yearly progress in educating students to the state’s standards—referred to 

in this report as meeting their yearly performance goals. Title I schools 

that did not meet their goals for two consecutive years were to be 

designated for improvement, provided technical assistance, and required 

 2

State agencies may retain 1 percent for administration with the smallest states permitted 

to retain a slightly higher amount, and, starting in school year 2004-2005, must reserve 

4 percent for school improvement activities. In the 2 earlier years, state agencies were 

required to set aside 2 percent for school improvement. 

3

Education’s National Center for Education Statistics maintains information on schools 

“eligible” for Title I funds, based on the data used in the formula for distribution of funds. 

Given districts’ discretion, however, some eligible schools may not actually receive funds. 

4

In this report, when we refer to states, we are including the jurisdictions of the District of 

Columbia and Puerto Rico. 

Accountability for Results 

in All Public Schools under 

NCLBA and Prior Law 
Page 6 GAO-05-7 No Child Left Behind Act 

to implement improvement plans. States were at various stages of 

implementation when NCLBA was enacted, so some states had been 

identifying schools for improvement for several years while others were 

just beginning the process. 

Enactment of NCLBA strengthened accountability requirements by 

specifying timetables for school improvement and by holding all public 

schools, whether or not they receive Title I funds, accountable for the 

academic performance of various subgroups of students. For example, 

schools must reach yearly performance goals set by states that will result 

in 100 percent of students meeting state proficiency standards by school 

year 2013-2014.5

 In addition to meeting the state’s performance goals in 

general, schools are responsible for meeting those goals for specified 

subgroups of students who (1) are economically disadvantaged, 

(2) represent major racial and ethnic minorities, (3) have disabilities, or 

(4) are limited in English proficiency. If any subgroup does not meet the 

target, the school is identified as not having made its yearly performance 

goal.6

While NCLBA requires that all 94,000 public schools in the nation be held 

accountable for their performance, it requires specific actions or 

corrective interventions only for Title I schools that repeatedly miss their 

yearly performance goals.7

 Two kinds of immediate interventions are 

required for Title I schools that have not met their performance goals for 

two consecutive years. On the one hand, plans are set in motion to 

improve the school’s performance. At the same time, students must be 

given the opportunity to transfer to other schools under the school choice 

option. Depending on how often schools continue to miss their goals, 

other required actions range from offering students supplemental 

 5

For more information on state accountability systems, see GAO, No Child Left Behind 

Act: Improvements Needed in Education’s Process for Tracking States’ Implementation 

of Key Provisions, GAO-04-734 (Washington, D.C.: Sept. 30, 2004). 

6

The school can meet the state performance goal under the “safe harbor” provision even 

when a student subgroup does not otherwise meet the goal. To do so, the school must 

reduce the percentage of students in the subgroup who are not proficient by at least 10 

percent and that subgroup must also show progress on another academic indicator that the 

state uses to determine performance. For example, if a subgroup does not make the state’s 

goal for the percentage of students proficient in reading, but the percentage in that 

subgroup who are not proficient declines by 10 percent and the graduation rate for that 

subgroup improves, the school could make its performance goal for that year. 

7

States may, at their discretion, apply these interventions to other schools as well. 
Page 7 GAO-05-7 No Child Left Behind Act 

educational services, such as after-school tutoring, to completely 

restructuring schools. See appendix II for further details on the specific 

actions required in each year. 

The first year that Title I schools do not meet performance goals, no 

specific actions are required under NCLBA. However, if the goal is missed 

the next year, districts generally must offer parents of students attending 

these schools the choice to transfer their child to another school.8

 The 

district must provide transportation to the new school, within limits, and 

continue to pay for transportation until the school from which the student 

transferred is no longer identified for choice.9

 Schools are no longer 

identified for choice when they have met their yearly performance goals 

for at least 2 consecutive years. 

Districts are required by federal regulations to offer parents at least two 

schools from which to choose, if available, and these schools may be any 

public school that is not itself currently identified for choice. Thus, under 

NCLBA offered schools could include Title I schools that have missed 

their yearly performance goals for a single year or any school that does not 

receive Title I funds, regardless of its performance. However, states could 

further limit the schools offered as transfer options, for example, by 

prohibiting transfers to non-Title I schools that have not met their yearly 

performance goals. Under circumstances where no viable transfer options 

exist—as in districts with only one school serving particular grade levels 

or where all schools in the district have repeatedly missed their 

performance goals—districts are required, to the extent practicable, to 

make arrangements with other districts to accept their transfer students.10 

NCLBA requires that districts notify parents of the choice option by the 

first day of the school year immediately following the test administration 

 8

NCLBA states that the opportunity to transfer must be offered unless such transfers are 

prohibited by state law. 

9

The student may remain in the new school until he or she completes the highest grade 

level in the new school, but the district is no longer required to pay for transportation when 

the school from which the student transferred is no longer identified for choice. 

10In addition to making such arrangements for choice, districts have the option of offering 

supplemental educational services to students attending schools that have missed their 

yearly performance goals for two consecutive years. If schools miss their yearly 

performance goals for three or more years, districts are required to provide supplemental 

educational services as well as choice. 

School Choice under 

NCLBA 
Page 8 GAO-05-7 No Child Left Behind Act 

that resulted in the school being identified for choice. For example, if tests 

given in spring 2003 resulted in the school being identified for choice, then 

the option had to be offered parents by the first day of school of the 2003-

2004 school year. Notices to parents must be in an understandable and 

uniform format and, to the extent practicable, in a language that parents 

can understand. These notices must explain why the school was identified 

for choice and how it compares with others in the district and state. In 

addition, federal regulations require that the notice include information on 

the academic achievement of the schools offered as transfer options. 

Districts are not required to give parents their first choice among the 

transfer options provided, but may not deny transfer requests based on 

lack of physical capacity, such as lack of space within a building or 

classroom, according to federal regulations. When deciding which schools 

to offer as transfer options, districts can consider the amount of available 

capacity, but they must offer options for all students enrolled in schools 

identified for choice. When reviewing transfer applications, making school 

assignments, and arranging for transportation, districts are required to 

give priority to the lowest-achieving low-income students. 

In each of the first 2 school years following enactment of NCLBA, from 10 

to 12 percent of schools that received federal funds under Title I were 

identified for school choice. Several million students were enrolled in the 

schools identified for choice and were thus eligible to transfer. About 

31,000 students, representing 1 percent of those eligible, transferred in the 

second year, school year 2003-2004. Although Education has recently 

begun to collect information on the number of transferring students, little 

is known about their demographic or academic characteristics. Our 

analysis of data from one district showed that proportionately fewer 

minority and low-income students transferred, compared with students in 

the same schools who did not transfer. 

About 1 in 10 Schools 

Identified for Choice 

in the First 2 Years of 

NCLBA, and 1 Percent 

of Eligible Students 

Transferred in 2003-

2004 
Page 9 GAO-05-7 No Child Left Behind Act 

In each of the first 2 school years of NCLBA, about 1 in 10 Title I schools—

about 1 in 20 public schools nationwide—was identified for school choice. 

About 5,300 schools11 attended by 3 million children, were identified for 

choice in the first year of NCLBA. As shown in figure 1, the total number 

of schools identified for choice increased to about 6,200 in year two. 

Because schools must meet their performance goals for 2 consecutive 

years before they are no longer identified for choice, many of the same 

schools may have been included in the total number for both the first and 

second years. 

 11The 5,300 schools shown for school year 2002-2003 are derived from state data reported 

in 2004. Although Education released a list in July 2002 estimating that there were over 

8,600 such schools for school year 2002-2003, many states later revised these numbers. For 

example, Education estimated that 760 Ohio schools were identified for choice in 2002-

2003, but Ohio reported that only 161 schools were identified for choice in that year. 

From 10 to 12 Percent of 

Public Schools Nationwide 

That Received Title I 

Funds Were Identified for 

Choice in Each of the First 

2 Years of NCLBA 
Page 10 GAO-05-7 No Child Left Behind Act 

Figure 1: Number of Title I Schools and Number Identified for School Choice in 50 

States, the District of Columbia, and Puerto Rico in School Years 2002-2003 and 

2003-2004 

As figure 2 shows, Title I schools identified for choice enrolled larger 

proportions of minority students and students from low-income families 

than other Title I schools. 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

50,000

55,000

2002-2003 2003-2004 c

Number of Title I schools

Title I schools

Title I schools identified for choice

Source: GAO analysis of State data.

52,100

5,300

52,500

6,200
Page 11 GAO-05-7 No Child Left Behind Act 

Figure 2: Demographics of Students Enrolled at Title I Schools Identified and Not 

Identified for Choice in School Year 2003-2004 

About 60 percent of all schools identified for choice were elementary 

schools. However, this proportion is smaller than might be expected, given 

that 71 percent of all Title I schools are elementary schools. As figure 3 

shows, proportionately more middle and high schools were identified for 

choice. 

0

10

20

30

40

50

60

70

80

90

100

Percent c

low-income

Percent minority

Percent of students

Enrollment at Title I schools not identified for choice

Enrollment at Title I schools identified for choice

Source: GAO analysis of data from states and the National Center for Education Statistics.

46

80

49

62
Page 12 GAO-05-7 No Child Left Behind Act 

Figure 3: Proportion of Schools Identified for Choice at Various Grade Spans Compared with All Title I Schools in School 

Year 2003-2004 

Most schools identified for choice in school year 2003-2004 were located in 

urban and suburban areas. Although 15 percent of all Title I schools were 

located in rural areas, only 11 percent of the Title I schools identified for 

choice were in rural areas. 

Figure 4 shows state variation in the proportion of schools identified for 

choice. In the majority of states, 10 percent or fewer of Title I schools 

were identified for choice in 2003-2004, but in some states a much larger 

percentage was identified. One state, Wyoming, had no schools identified 

for choice in 2003-2004. Among the states with relatively few schools 

identified for choice were some of the nation’s most rural states, including 

Maine, Mississippi, and Nebraska, but also some more populous states 

such as Florida and Texas. By contrast, in 22 states the percentage of Title 

I schools required to offer choice ranged from 11 percent to 48 percent. 

Among these were several of the nation’s most populous states, including 

California, Illinois, and New York, but also one of the most rural—Alaska. 

Georgia and Hawaii each had 40 percent or more of their schools 

4%

11%

61%

9%

16%

71%

24%

Other, including ungraded

High

Middle

Elementary

4%

Source: GAO analysis of data from states and the National Center for Education Statistics.

Title I schools identified for choice All Title I schools
Page 13 GAO-05-7 No Child Left Behind Act 

identified for choice, higher than any other state. See appendixes III and IV 

for state details for each year. 

Figure 4: Percentage of Title I Schools Identified for School Choice, by State, in School Year 2003-2004 

A number of factors contribute to state variations in the proportion of 

schools identified for choice, including differences in school populations 

and state accountability systems. Under NCLBA, if a school contains a 

N.H.

Mass.

R.I.

Conn.

N.J.

Del.

Md.

D.C.

Hawaii

Vt.

Ala.

Ariz.

Ark.

Calif. Colo.

Ga.

Idaho

Ill. Ind.

Iowa

Kans.

La.

Maine

Mich.

Minn.

Mo.

Mont.

Nev. Nebr.

N.Mex.

N.Y.

N.Dak.

Okla.

Oreg.

Pa.

S.C.

S.Dak.

Tenn.

Tex.

Utah

Va.

Wash.

W.Va.

Wisc.

Wyo.

Fla.

Miss.

N.C.

Ohio

Ky.

Source: GAO analysis of state data.

0 through 4%

5 through 10%

11 through 47%

P.R.

Alaska
Page 14 GAO-05-7 No Child Left Behind Act 

minimum number of students in specific groups—low-income, major 

racial and ethnic minorities, students with disabilities, and limited English 

proficient—schools are held accountable for the academic outcomes of 

those groups, in addition to academic outcomes of the entire school. Large 

or diverse schools are likely to have more student groups containing the 

state-defined minimum number of students, and consequently have more 

performance targets. Because it is harder for schools with many targets to 

meet their overall performance goals, states with larger or more diverse 

schools may be more likely to have a higher percentage of schools miss 

their targets and be identified for choice. 

Characteristics of states’ accountability systems also contribute to the 

variation among states. For example, states use different standards and set 

different annual progress rates for reaching 100 percent proficiency. In 

addition, some states use smaller minimum student group sizes than other 

states. The smaller the size of the group used, the more likely a school will 

include additional student groups in accountability, increasing the number 

of performance targets the school must meet.12

About 19,000 students transferred under the NCLBA school choice option 

in school year 2002-2003, the first year, and an additional 31,000 students 

transferred in the second year.13 As illustrated in figure 5, this number 

transferring in the second year represented about 1 percent of the students 

who were eligible. Across states, the number of eligible students who 

transferred under NCLBA in 2003-2004 ranged from zero in 6 states to over 

7,000 in one state. States also varied in the extent to which eligible 

students exercised the option and transferred. Oregon reported the 

highest proportion of eligible students transferring at 17 percent, followed 

by Florida with 6 percent. The remaining states had less than 5 percent of 

eligible students transfer. Further, states with more students eligible for 

 12For more information on differences in state accountability systems, see GAO-04-734. 

13For the first year, Education reported 45,000 actual transfers based on data from 48 

states, but this figure included one state that subsequently determined it had overstated its 

number by about 28,000 students. The 19,000 number we report is based on revised data for 

50 states. For the second year, Cynthia G. Brown, et al, estimated that about 65,000 

students requested transfers and 20,000 actually transferred based on data from 10 states 

and 68 districts (Choosing Better Schools: A Report on Student Transfers under the No 

Child Left Behind Act, The Citizens’ Commission on Civil Rights, (Washington, D.C: May 

2004)). Although higher, our 31,000 figure may still understate the actual numbers 

transferring because we could not obtain any transfer data for 7 states. See app.V for more 

information. 

About 1 Percent of Eligible 

Students Transferred in the 

Second Year; Little Is 

Known about Their 

Characteristics 
Page 15 GAO-05-7 No Child Left Behind Act 

choice under NCLBA did not necessarily have more students use the 

transfer option. For example, although Hawaii had more students eligible 

for choice, Colorado had about twice as many students transfer. The 

number of eligible students transferring in each year for each state is 

detailed in appendix V. 

Figure 5: Number of Title I Students Eligible for Choice and Number That 

Transferred in 42 States, the District of Columbia, and Puerto Rico in School Year 

2003-2004 

Overall, the proportion of eligible students transferring in the most rural 

states14 was about the same as in other states; however, statewide data 

may mask differences within states between rural and nonrural districts. 

For example, Kansas, the rural state with the most students eligible for 

choice, provided detailed data showing how many student transfers 

occurred in each district. About 70 percent of Kansas transfers were in the 

 14The states are Alaska, Iowa, Kansas, Maine, Mississippi, Montana, Nebraska, North 

Dakota, South Dakota, and Vermont, although Montana was unable to provide data for the 

second year and was not included in the analysis. These 10 states represent the most rural 

states in the country based on the percentage of their school districts in rural communities, 

the percentage of their students attending schools in rural communities, and the average 

distance between the states’ school districts and the nearest metropolitan statistical area. 

See GAO No Child Left Behind Act: Research on Effective Strategies Need for Small and 

Isolated Rural Districts, GAO-04-909 (Washington, D.C: Sept. 23, 2004). 

31,500

Students who transferred in the second

year under NCLBA

3,292,600 Students enrolled in Title I schools

identified for choice

Source: GAO analysis of state data.
Page 16 GAO-05-7 No Child Left Behind Act 

state’s three largest districts—Wichita, Shawnee Mission, and Kansas 

City —although about half of the students eligible for NCLBA transfers 

were located in those districts. Officials in several rural states reported 

that rural districts faced unique challenges implementing NCLBA choice. 

In some rural districts, although students were eligible for choice, no 

transfers took place because there were no other schools in the districts 

that could be offered as transfer options.15 Where transfer options were 

available, sometimes the distances between schools made transfers 

difficult. 

In the 41 states that could provide student transfer data and had schools 

identified for choice in both years, the total number of transferring 

students rose by about 85 percent.16 This increase was driven by several 

states that had substantial increases, such as New York, New Jersey, and 

South Carolina. However, 8 states reported declining numbers of transfers, 

and 6 of these states also reported fewer schools identified for choice in 

the second year, while 2 reported increases.17

Little is known about the demographic characteristics and academic 

performance of students who transferred under NCLBA school choice in 

either year or reasons why parents accept or do not accept transfer 

opportunities. Although Education has requested state data on the number 

of students transferring each year, it has not collected data on the 

characteristics or academic performance of transferring students. 

Education officials told us that they have contracted for a major, multifaceted study of NCLBA that will examine key areas of implementation, 

 15Where districts lack other schools to offer as transfer options, districts are required, to 

the extent practicable, to make transfer agreements with neighboring districts, but we are 

not aware of any locations where such interdistrict transfers have occurred. 

16The increase may be understated, because second year data for some states were not 

available statewide and instead represents numbers for large districts in these states. 

Florida, Vermont, and Wyoming were not included among the 41 states, because they had 

no schools identified for choice the first year, although in the second year, Florida 

accounted for about 1,800 transfers. See app. V for details. 

17The 8 states were Alabama, Illinois, Indiana, Iowa, North Dakota, Texas, Utah and 

Missouri. Illinois and Missouri reported increases in the number of schools identified the 

second year. Not included here are Massachusetts and Washington because the transfers 

for the second year are based only on the numbers in large districts, and thus may be 

understated. See app. III and IV for the number of schools identified in each year and 

app. V for the students transferring. 
Page 17 GAO-05-7 No Child Left Behind Act 

including school choice.18 Two parts of the study relating to school choice 

are descriptive: one is a descriptive comparison of the demographics of 

students who choose to transfer and those who do not. A second part 

examines reasons that parents give for their decisions about whether or 

not to apply for transfers. A third part of the study, still under design, will 

examine student achievement outcomes. This effort would examine the 

academic outcomes over time of transferring students in a sample of 

districts, but this portion of the study is not fully developed. For instance, 

officials said they are still exploring several possibilities for study 

methodology and whether demographic characteristics of these students 

will be included in the achievement analysis. 

Our analyses of 2003-2004 demographic and academic data that we were 

able to obtain from one district we visited showed diversity in transferring 

students. Of the students who transferred, 53 percent were male, 

62 percent were minorities representing all the major racial and ethnic 

groups, and 82 percent were from low-income families as measured by 

their eligibility for the free or reduced-price school lunch program. In 

addition, 10 percent of these transferring students were English language 

learners and 14 percent were enrolled in special education.19 In general, 

proportionately fewer minority and low-income students transferred, 

compared with students who were eligible but did not transfer, as shown 

in table 1. Our analysis of available student performance data from state 

reading and math assessments showed little difference between 

transferring students and those not transferring. The proportion of 

students who met the standards was about the same for each group.20

 18Education refers to this study as the National Longitudinal Study of No Child Left Behind. 

Data will be collected for school years 2004-05 and 2006-07, with a report expected in 

September 2007. 

19Demographic categories used are not mutually exclusive. 

20Assessment data were available for about one-quarter of the students in each group, 

because assessments were administered to students in only one grade at each school. 
Page 18 GAO-05-7 No Child Left Behind Act 

Table 1: Students Eligible but Not Transferring from Elementary and Middle Schools Identified for Choice Compared with 

Students Transferring in 2003-2004 in One District Visited 

 Percent minority Percent low income

School 1 Students eligible but not transferring 76 93

 Transferring students (N=15) 47 87

School 2 Students eligible but not transferring 72 92

 Transferring students (N=5) 40 100

School 3 Students eligible but not transferring 63 83

 Transferring students (N=75) 57 80

School 4 Students eligible but not transferring 73 84

 Transferring students (N=52) 63 81

School 5 Students eligible but not transferring 59 78

 Transferring students (N=58) 69 83

Total Students eligible but not transferring 68 85

 Transferring students (N=220) 62 82

Source: School district officials. 

Note: We were unable to associate 15 of the 220 transferring students with the school from which 

they transferred. 

Compared with students in the schools into which they transferred, 

however, transferring students were somewhat lower performing on state 

assessments.21 About 33 percent of transferring students met state reading 

standards, while 43 percent of the other students in the receiving schools 

met these standards. Similarly, about 20 percent of transferring students 

met state math standards, while 34 percent of the other students in 

receiving schools met state math standards. Transfer students were also 

more often from a minority background. About 62 percent of the 

transferring students were minorities, but about 52 percent of the students 

in receiving schools were minorities. 

Officials in most of the 8 districts we visited mentioned that they 

supported the NCLBA focus on improved student performance and 

accountability; however, they had difficulties providing school choice, 

primarily because of tight timeframes and insufficient capacity. To try to 

get notices out to parents before school started, most districts took a risk 

and acted on preliminary data on school performance that they received 

 21Based on 2002-03 reading and math assessments. 

Implementation of 

Choice Was 

Challenging in 

Selected Districts 
Page 19 GAO-05-7 No Child Left Behind Act 

from the state in late summer because final data were not available. 

Parents of eligible students were presented at least two schools as transfer 

options, but many of these alternatives were similar to the schools 

students were currently attending. Some districts were not able to 

accommodate all transfer requests because the demand for some schools 

exceeded their capacity. Districts employed a variety of strategies to 

provide transportation to transferring students, including school buses, 

public transportation, and cash stipends. 

Although the law requires districts to notify parents of the choice option 

by the start of the school year, 7 of 8 districts we visited did not receive 

final results of school performance for the most recent year from the state 

in time to meet the requirement. Consequently, many used preliminary 

data to identify schools for choice. Akron was the only district that had 

final results from the state when notices were sent to parents. Four 

districts used preliminary data to identify which schools had to offer 

choice and notified parents before school started. A fifth district also used 

preliminary data but did not receive the data until after school started. 

Using preliminary data can put districts at risk of incorrectly identifying 

schools as having to offer choice and consequently misinforming parents.22

One district included language in the notification letter to parents 

explaining that the transfer offer could be revoked if final determinations 

by the state were different. Table 2 shows key testing and notification 

dates in 6 of the districts we visited. 

 22For example, Mississippi state officials told us that 3 of 10 schools identified for choice in 

2003-04 based on preliminary data were later found to have met their goals. Mississippi 

requires districts to provide choice based on preliminary results and to honor its 

commitment to choice even when the final data yield different results. However, the school 

in N. Panola was not among the three incorrectly identified. 

Short Timeframes Created 

Challenges 
Page 20 GAO-05-7 No Child Left Behind Act 

Table 2: Milestone Dates for Implementation of Choice for School Year 2003-2004 in Six Districts We Visited 

School district 

Month tests 

given (2003) 

Preliminary results 

in from the state on 

schools’ yearly 

performance (2003) 

District notices 

sent to parents 

(2003) 

Start of school 

year 2003-2004 

Final results from the 

state on schools’ yearly 

performance (2003 or 

later as noted) 

Akron, Ohio March June (early) July 25 August 27 July 21 

Chicago, Ill. March/April July 28 August 9 September 2 December 19 

Elgin, Ill. March/April July 30 August 6 August 25 June 2004 

Pittsburgh, Pa. March/April August 5 August 28 September 7 September 23 

Tacoma, Wash. April/May July 28 August 12 September 3 September 17 

North Panola, Miss.a April/May August 8 September 3 August 5 November 21 

Source: School district officials. 

a

North Panola, a rural district in Mississippi, did not offer school choice, because the middle school 

identified was the only one in the district. Instead, the district notified parents and offered 

supplemental educational services. 

The remaining 2 districts we visited, Memphis and Fresno, did not use 

preliminary data from the most recent testing period, but rather used data 

from the previous year to determine the schools that would have to offer 

choice.23 Officials said they were aware this delay was not in accord with 

Education guidance but took this action to combine NCLBA choice with 

their voluntary choice programs, which permit all students to request 

transfers in the spring. Memphis officials said that they planned to change 

their procedures and offer school choice twice in 2004—first in the spring, 

during the open enrollment process, for schools that they already know 

must offer choice and again in the fall when they receive the results of the 

spring 2004 assessments. Fresno officials did not indicate that they would 

be changing their procedures. 

Given the tasks that districts must complete to offer school choice before 

school starts, officials expressed concerns that little could be done to 

mitigate these timeframe problems. Districts must first administer state 

tests in the spring, which are sometimes sent to contractors to be scored. 

Next, after receiving the preliminary test results from the state, districts 

assess the scores to verify the accuracy of the data, use these data to 

identify schools likely to be required to offer choice, and notify schools. 

Schools may appeal this decision to the state. Only after reviewing such 

 23Tennessee did not provide Memphis with preliminary data prior to the start of school. 

California provided incomplete data prior to the start of school and final results in 

February 2004. 
Page 21 GAO-05-7 No Child Left Behind Act 

appeals do states release final determinations of which schools are 

required to offer choice. Most districts we visited did not have the final 

performance data before school started in the fall. Figure 6 shows the 

timeline of events in one school district we visited; similar patterns 

occurred in most others. 

Figure 6: Timeline for Tacoma Public Schools, 2003 

The compressed timeframe for making school status determinations and 

implementing the choice option left parents little time to make transfer 

decisions, and district and school officials expressed concerns that 

parents did not have adequate time to make an informed decision. In most 

of the districts we visited, parents had 3 weeks or less to make their 

transfer decisions. In addition, in districts and schools with highly mobile 

populations, reaching parents can be time-consuming. Akron and Memphis 

officials told us that many letters notifying parents of the transfer option 

were sent to addresses found to be incorrect. To ensure that parents had a 

greater chance of learning about school choice, some districts used a 

variety of additional notification strategies—fliers, newspaper articles, 

postings to the district Web site, and public meetings. In addition, they 

provided parents several ways to communicate their desires such as 

through the mail, by telephone, or going to the district in person. 

Officials in some districts also expressed concern that the information 

provided to parents was not always clear and that it may not have been 

May

5/15

Test booklets transported 

from district to vendor in 

Iowa for scoring.

July

7/28

District receives preliminary 

yearly performance results 

for each school from the 

state.

7/28-8/8

District reviews preliminary 

results, verifies data, and 

determines yearly 

performance for each 

school. 

August

8/4-8/8

District notifies schools that 

must offer choice and 

schools that will receive 

transfer students.

8/12

Notice to parents about 

school choice and the 

schools that they may select.

8/18-9/12

District notifies schools 

about transfers, sets final 

staffing for school, arranges 

transportation, and finalizes 

student transfers.

September

9/3

School year starts.

9/12

Deadline for parents to notify 

district about school choice.

9/27

District receives notice of 

final yearly performance 

results for each school from 

the state.

2003

April

4/21-5/9

Testing period for school 

year 2002-2003.

Source: Tacoma Public Schools.
Page 22 GAO-05-7 No Child Left Behind Act 

sufficient for them to base their decisions.24 Letters sent to parents 

generally explained what it meant to be identified for choice, gave the 

reasons for the identification, described the process for applying for 

transfer, and listed the transfer school options. However, little information 

was provided about the transfer schools. In some districts, school officials 

were concerned that the wording of the letters may have been confusing. 

They said that parents did not always understand the meaning of the 

school choice option as explained in the letter and needed more time to 

consult with district or school officials. For example, officials in 2 districts 

told us that some parents misunderstood the letter and believed that they 

were required to transfer their child to another school. Other school 

officials talked about the need for parents to have additional information 

about specialized services and instructional support that certain schools 

provide in order to understand the educational implications of their 

decisions. Officials in one district told us that some parents who chose a 

transfer school later changed their minds when they found that student 

support services their child had received at their Title I school, such as 

extended day programs and after school tutoring made possible by Title I 

funds, were not available at the non-Title I transfer school. 

Schools also faced challenges in implementing choice within the 

timeframes, particularly in adjusting staffing and scheduling, when they 

learned shortly before the start of school that they would be receiving 

students under the NCLBA school choice program. For example, a 

Tacoma middle school principal said that she faced a variety of challenges 

when she was notified a month before school started that the school was 

to receive NCLBA transfer students. Based on spring predictions of the 

school’s student population and student needs, she had released six 

teachers. However, when notified the school was receiving 57 NCLBA 

transfers in the fall, she had to quickly hire two new teachers and 

reconfigure the schedule to include more remedial classes to 

accommodate the learning needs of the transferring students. In addition, 

school officials did not receive records for some students from the schools 

 24Researchers in Colorado and Massachusetts echoed the districts’ concerns. See Pamela 

Benigno, No Child Left Behind Mandates School Choice: Colorado’s First Year 

(Independence Institute: June 2003) 

http://www.independenceinstitute.org/edpublications.aspx downloaded November 5, 2004. 

See also William Howell, “Fumbling for an Exit Key: Parents, Choice, and the Future of 

NCLB” in Frederick M. Hess and Chester E. Finn, Jr, editors, Leaving No Child Behind? 

Options for Kids in Failing Schools (New York, N.Y.: Palgrave Macmillan, Oct. 2004) 161-

190. 
Page 23 GAO-05-7 No Child Left Behind Act 

they left until after school started, and some students were initially placed 

in the wrong classes. 

Whenever possible, districts offered each parent at least 2 schools as 

transfer options, as required by federal regulations, but some districts 

offered more than 30 schools. The locations varied by district. Table 3 

shows the number and location of elementary schools offered in the 

districts we visited. Some districts offered schools based on geographic 

location within the district and some offered schools districtwide. For 

example, as table 3 shows, students in Memphis attending one of the 

40 schools identified for choice selected from among 3-10 transfer schools 

that were in the same general area of the city, while students in each of the 

6 schools identified in Akron selected from a group of 33 schools spread 

across the district. Elementary schools offered as transfer options were 

more commonly selected for their proximity to sending schools than 

middle and high schools, which were generally offered districtwide. 

Although not shown in table 3, parents generally were offered fewer 

transfer options for middle and high school students, because districts 

tend to have fewer middle and high schools than elementary schools. 

Table 3: Transfer Options Offered Parents of Elementary School Students in Seven Districts We Visited 

District 

Number of elementary 

schools required to offer 

choice 

Number of elementary 

schools offered as 

transfer options to 

parents for each school 

required to offer choice

Number of schools 

parents instructed to 

select 

Location: 

Districtwide or 

geographic area 

within district 

Akron, Ohio 6 33 1 Districtwide 

Chicago, Ill. 305 37 2 Districtwide 

Elgin, Ill. 6 16 3 Districtwide 

Fresno, Calif. 23 2 2 Geographic 

Memphis, Tenn. 40a 3-10 2 Geographic 

Pittsburgh, Pa. 11 11-19 2 Geographic 

Tacoma, Wash. 2 2 2 Geographic 

Source: School district officials. 

a

Memphis schools are those the state identified for choice in school year 2002-03. 

Many schools that districts offered as transfer options had not met state 

performance goals in the prior year, and some were at risk themselves of 

having to offer choice in the following year. Among the seven districts that 

offered transfers, all had some schools offered as choices that had not met 

the state’s yearly performance goals, based on the spring 2003 

Most Districts Offered 

Parents a Number of 

Schools as Choices, but 

Many of These Alternatives 

Were Similar to the 

Student’s Current School 
Page 24 GAO-05-7 No Child Left Behind Act 

assessments. Table 4 provides more detail on the status of schools offered 

as transfer options by district. Because many of these schools were Title I 

schools and, therefore, subject to NCLBA requirements, those that did not 

meet their yearly performance goals for a second consecutive year would 

have to offer school choice the following year. For example, in Memphis 

37 Title 1 schools were offered as transfer options, and 29 of these had not 

met yearly performance goals based on spring 2003 tests. Some schools 

offered were not Title I schools and, therefore, were not required to offer 

transfers, regardless of the performance of the school. Overall, as shown 

in Table 4 for the districts we visited, from 21 to 73 percent of all schools 

offered, Title I and non-Title I, had met yearly performance goals. 

Table 4: Title I Status and Performance of Schools Offered as Transfer Options for 2003-2004, by District 

Number of schools offered 

as transfer options 

 Number of schools offered as 

transfer options that did not meet 

yearly performance goals based on 

spring 2003 tests 

 Number and percentage of all 

schools offered as transfer options 

that met yearly performance goals 

based on spring 2003 tests 

District Title I 

Other 

schools Title I Other schools

Number Title I 

and other

Percentage Title I 

and other

Akron, Ohio 32 5 11 3 23 62

Chicago, Ill. 21 19 12 11 16 40

Elgin, Ill. 0 16 0 6 10 62

Fresno, Calif. 15 3 10 1 7 39

Memphis, Tenn. 37 10 29 6 10a21

Pittsburgh, Pa. 51 0 14 0 37 73

Tacoma, Wash. 4 4 1 3 3a38

Source: GAO analysis of school data from state or district education agency Web sites. 

a

In Memphis and Tacoma numbers do not add to totals because test data are not available for 

schools that were new as of 2003-2004 and did not have a testing history; in Tacoma there was one 

such school; in Memphis, there were two. In addition, there was one school in Chicago that did not 

have test data for 2002-2003. 

Officials from large urban districts such as Fresno and Memphis said that 

they would have few schools to offer as choices if they did not offer Title I 

schools that had failed to meet the performance goals for only one year. 

Officials in some districts expressed concerns that, as the bar for meeting 

yearly performance goals is raised, more schools would fail and few 

schools would be available as transfer options. In these districts, over 

80 percent of schools received Title I funds and many more students could 

become eligible for transfer under NCLBA. 
Page 25 GAO-05-7 No Child Left Behind Act 

In districts such as Chicago, Fresno, and Memphis with high proportions 

of Title I schools, the majority of the schools offered as transfer options 

were often demographically similar to those attended by students eligible 

for transfer. Specifically, the schools offered as transfer options served 

many poor students and had high minority populations. As shown in table 

5, for example, 34 of Fresno’s 39 schools required to offer choice—about 

seven-eighths—had poverty rates that exceeded 75 percent, as did over 

half of the 18 schools offered as transfer options. 

Table 5: Poverty and Minority Rates of Schools Required to Offer Choice and Schools Offered as Transfer Options in Fresno 

Poverty Minorities 

School enrollment 

percentage 

Number of schools 

required to offer choice

Number of schools 

offered as transfer 

options

Number of schools 

required to offer choice 

Number of schools 

offered as transfer 

options

0-25% 0 3 0 0

26-50% 1 4 0 3

51-75% 4 1 1 7

76-100% 34 10 38 8

Source: GAO analysis of school data from state or district education agency Web sites. 

In contrast, other districts that we visited tended to offer more transfer 

options that differed demographically from the schools required to offer 

choice. As shown in table 6, for example, 7 of Akron’s 8 schools required 

to offer school choice had poverty rates that exceeded 75 percent, but less 

than one-third of schools offered as transfer options had such rates. See 

appendix VI for poverty and minority rates of schools in seven districts 

that we visited. 

Table 6: Poverty and Minority Rates of Schools Required to Offer Choice and Schools Offered as Transfer Options in Akron 

 Poverty Minorities 

School enrollment 

percentage 

Number of schools 

required to offer choice

Number of schools 

offered as transfer 

options

Number of schools 

required to offer 

choice 

Number of schools 

offered as transfer 

options

0-25% 0 1 0 11

26-50% 0 9 0 11

51-75% 1 16 4 7

76-100% 7 11 4 8

Source: GAO analysis of school data from state or district education agency websites. 
Page 26 GAO-05-7 No Child Left Behind Act 

Despite the fact that all districts offered parents a choice of schools, 

officials in four districts told us that they were unable to accommodate 

some requests for transfers because of constraints on classroom capacity, 

as shown table 7. In two districts in Illinois—Elgin, and Chicago—officials 

said that they believed that state law did not allow their districts to offer 

choice under NCLBA if it led to overcrowding in schools.25 Akron officials 

told us that they were seeking clarification from the state about whether 

any transfers in their district would be prohibited by Ohio state law. 

Memphis officials told us that demand exceeded the capacity at certain 

schools that were already overcrowded, and use of portables to expand 

capacity was unrealistic because of the expense and lack of sufficient 

space on school campuses. 

Table 7: Number of Students Unable to Transfer Due to Capacity Limitations in 

2003-2004 

District 

Number of 

students that 

applied for a 

transfer

Number of 

students that 

transferred to 

another school

Number of 

students 

unable to 

transfer 

because of 

capacity

Number of 

students not 

transferring for 

other reasons

Akron, Ohio 114 76 19 19

Chicago, Ill. 19,000 548 17,903 549

Elgin, Ill. 113 60 14 39

Fresno, Calif 465 101 0 364

Memphis, 

Tenn. 830 388a

442 0

Pittsburgh, Pa. 161 151 0 10

Tacoma, Wash. 253 253 0 0

Source: School district officials; Chicago data from The Center for Education Policy, From the Capitol to the Classroom, January 2003. 

a

Memphis approved 388 student transfers but did not collect data on the number of students that 

actually transferred. 

In some districts with capacity constraints, open enrollment programs 

could limit the ability of students to transfer under NCLBA. In all but 2 of 

the districts we visited, school choice was available to all students through 

open enrollment programs. These programs offered students the chance to 

apply for transfers, typically during the winter and spring months, and, in 

 25Elgin and Chicago cited an Illinois law, effective July 1, 2002, that limits transfer options 

when the receiving school would exceed capacity as a result of the transfer. 

Several Districts We 

Visited Cited Lack of 

Sufficient Capacity as 

Limiting the Number of 

Transfers 
Page 27 GAO-05-7 No Child Left Behind Act 

several districts, allowed transferring students to learn which school they 

would attend before the end of that school year. In contrast, students in 

most districts transferring under NCLBA did not know about their 

opportunity until just before the next school year started. Unless these 

districts took special care, schools could be filled to capacity with 

transfers approved under the open enrollment program before NCLBA 

students had the opportunity to apply. To avoid this situation, Akron gave 

NCLBA transfers priority and delayed decisions on requests for transfers 

under its open enrollment program until the decisions on NCLBA transfers 

had been made. 

Officials in Fresno, Pittsburgh, and Tacoma reported that they had not yet 

experienced problems with capacity because few students had 

transferred. However, some officials expressed concern that capacity 

could pose a challenge in their district in the future. Specifically, officials 

in Fresno, Memphis, and Tacoma noted that if more schools were required 

to offer choice in the future, the number of students eligible to transfer 

could increase and capacity could become a problem. 

The districts we visited arranged and paid for the transportation of 

students who transferred, as required under NCLBA, but did so in a variety 

of ways as allowed under the law. For instance, some districts provided 

school buses, while others paid for public transportation or provided cash 

stipends to cover public or private transportation. In 5 of the 7 districts, 

school buses picked up elementary students who lived more than 1-2 miles 

from their schools. For middle and high school students, some districts 

paid for public transportation by giving students passes or tokens. Finally, 

Akron gave parents a $170 transportation subsidy at the end of the school 

year in which students transferred to subsidize the costs of public transit 

or defray the gasoline costs of driving their child to school. 

In providing transportation, districts used relatively little of the funding 

that was required to be set aside for school choice transportation and for 

supplemental services because few students transferred. In 2003-2004, the 

estimated expenditures for transportation represented less than 7 percent 

of the set-aside funds in all but one district we visited. As shown in table 8, 

the proportions ranged from less than 1 percent in Akron to about 25 

percent in Elgin. Most district officials did not expect to spend the full 

amount that had to be set-aside for the combined costs of choice-related 

Districts Used Different 

Strategies to Meet 

Transportation 

Requirement 
Page 28 GAO-05-7 No Child Left Behind Act 

transportation and supplemental educational services.26 However, some 

district officials said they anticipated that as more schools have to offer 

school choice and more students become eligible to transfer, it is likely 

that transportation expenditures will increase. 

Table 8: Transportation Allocations and Projected Expenses for School Year 2003-2004, by District 

District 

Total Title I 

allocation 

Required set-aside for 

transportation and 

supplemental services

Projected dollars 

spent on 

transportation

Number of 

students provided 

transportation 

Percent of set-aside 

used to provide 

transportation

Akron, Ohio $12,463,428 $2,492,686 $13,416 76 0.54

Chicago, Ill. $240,829,945a $48,165,989a$1,000,000 548 2.08 

Elgin, Ill. $2,323,966 $464,793 $117,934 51 25.37

Fresno, Calif. $40,225,930 $8,045,186 $385,900 101 4.80

Memphis, Tenn. $38,653,432 $7,730,686 $526,070 b 6.80

Pittsburgh, Pa. $17,014,258 $3,402,852 $103,600 136 3.04

Tacoma, Wash. $8,854,322 $1,770,864 $72,070 253 4.07

Source: School district officials except where otherwise shown. 

a

Department of Education estimated allocation for fiscal year 2003. 

b

Memphis provided information on the number of transfers approved but did not collect data on the 

number of students that actually transferred. 

Education issued final regulations and guidance on school choice within a 

year of NCLBA enactment, but did so after districts had begun their first 

year of implementation, and some issues remain unclear. Extensive 

additional guidance and technical assistance in the form of policy letters, 

training tools, presentations at conferences, and a handbook on promising 

practices became available at various times throughout the first and 

second years of implementation. While district officials we visited 

generally had access to Education’s guidance, questions concerning the 

implementation of school choice remained, as might be expected in initial 

years of implementation. For example, there were “how to” questions 

about ways to offer choice when building capacity is limited. There were 

also “what if” questions involving issues that may arise as NCLBA 

implementation progresses, such as districts’ use of Title I funds for 

transportation when students choose to remain at a school to which they 

have transferred if that school subsequently does not meet its yearly 

 26Generally districts are permitted to carry over up to 15 percent of their Title I funds for 

use in the following year. 

Education Issued 

Extensive Guidance 

on Choice, but 

Questions Remain as 

Implementation 

Proceeds 
Page 29 GAO-05-7 No Child Left Behind Act 

performance goals and is itself required to offer choice. Some of these 

questions have been addressed in guidance but others remain. 

Responding to the need to get information out quickly, Education issued 

preliminary guidance in June 2002 before the start of the first school year. 

The information provided, however, was not always clear or complete. 

The preliminary guidance was sent out in the form of a “Dear Colleague” 

letter directly to school district superintendents as well as state education 

agency officials. In the letter, Education acknowledged that its preliminary 

guidance was necessarily brief and not as comprehensive as guidance that 

would be forthcoming. The letter highlighted key topics such as notices to 

parents, designation of sending and receiving schools, prioritization of 

students, capacity and transportation. The letter stated that choice had to 

be provided, unless prohibited by state law, to all eligible students, 

“subject to health and safety code requirements.” Some district officials 

believed this language allowed them to limit the number of transfers based 

on state or local health and safety codes or classroom size requirements. 

Subsequent guidance provided additional information about Education’s 

position on capacity and other issues. Final regulations and draft guidance 

on choice were issued in December 2002, after the start of the first school 

year. The final regulations applied to all aspects of Title I, while the draft 

guidance applied specifically to school choice and was characterized as 

“non-regulatory” guidance. The final regulations clarified some key 

information and the December guidance added extensively to material in 

the June 2002 letter. For example, in response to numerous requests for 

clarification of its language on capacity, Education’s regulations made it 

explicit that districts were required to accommodate all transfer requests 

while complying with all applicable state and local health and safety codes 

as well as classroom size requirements. Districts had to offer all students 

at schools identified for choice the option of transferring and could not 

use lack of capacity as a reason to deny students this option. The 

regulations explained that state law exempts districts from offering choice 

only if the state law prohibits choice through restrictions on public school 

assignments or the transfer of students from one public school to another 

public school. The December guidance went further to help clarify 

Education’s position by contrasting its regulations on capacity before and 

after enactment of NCLBA and providing an explanation for the 

differences. Because there had been no mention of capacity in NCLBA and 

some district representatives were uncertain about the meaning of the 

preliminary guidance in the June letter, the final regulations and December 

guidance represented an important clarification of Education’s official 

In the First Year, Districts 

Implemented Choice Using 

Preliminary Guidance 

Released through Letters 

to Superintendents 
Page 30 GAO-05-7 No Child Left Behind Act 

position on the issue. In these December documents, Education also 

suggested ways that districts might expand capacity, for example, by 

adding classes and additional teachers, in order to be able to offer choice 

to students while adhering to state classroom size requirements and health 

and safety codes. 

In the second year of NCLBA implementation, Education updated and 

expanded its draft guidance and published a handbook on promising 

practices in the provision of school choice. Education also provided 

additional assistance in the form of training materials, presentations at 

various conferences and a toll-free hotline for district superintendents in 

both the first and second years. See table 9 for a chronology of the various 

types of guidance on choice issued by Education. 

Table 9: Dates, Type, and Title of Guidance or Technical Assistance Provided by Education on School Choice under NCLBA 

Year Date Guidance, information, or action 

2002 February 15 Policy letter to Chief State School Officers on timetable for required actions in school year 2002-2003, 

including provision of choice. http://www.ed.gov/policy/elsec/guid/secletter/020215.html

 June 14 Preliminary guidance: Letter to District Superintendents and Chief State School Officers on school choice 

and supplemental educational services. http://www.ed.gov/policy/elsec/guid/secletter/020614.html

 September Summary of law: NCLB: A Desktop Reference. 

http://www.ed.gov/admins/lead/account/nclbreference/index.html

 December 2 Final regulations to implement Title I under NCLBA. 

http://www.ed.gov/legislation/FedRegister/finrule/2003-4/120903a.html

 December 4 Draft non-regulatory guidance: Public School Choice. (23 pp.) 

2003 February Training materials: Choice Provisions of NCLBA (power point slides). 

 March 24 Draft non-regulatory guidance: Impact of the New Title I Requirements on Charter Schools. (12 pp.) 

 Summer Letters to some states on additional steps needed to comply with choice and other requirements. 

 August 21 Non-regulatory guidance: Local Educational Agency (LEA) Identification and Selection of School 

Attendance Areas and Schools and Allocation of Title I Funds to Those Areas and Schools. 

http://www.ed.gov/policy/elsec/guid/edpicks.jhtml?src=fp

 August 28 Policy letter to Chief State School Officers allowing carry over of Title I funds set aside for school choice 

transportation. http://www.ed.gov/policy/elsec/guid/secletter/030828.html

 December 22 Consolidated State Performance Reports due, including data on implementation on choice. 

2004 January 7 Non-regulatory guidance: LEA and School Improvement. 

http://www.ed.gov/policy/elsec/guid/list.jhtml?page=12&size=10&sort=date&desc=show

 January Letter to school superintendents regarding hotline. 

http://www.ed.gov/policy/gen/guid/secletter/040101.html

 February 6 Draft non-regulatory guidance: Public School Choice. (29 pp.) 

http://www.ed.gov/policy/elsec/guid/edpicks.jhtml?src=fp

Additional Guidance and 

Technical Assistance 

Provided in the Second 

Year of Implementation 
Page 31 GAO-05-7 No Child Left Behind Act 

Year Date Guidance, information, or action 

 May Technical Assistance Handbook: Innovations in Education: Creating Strong District School Choice 

Programs. http://ed.gov/admins/comm/choice/choiceprograms/index.html

 July Non-regulatory guidance: Impact of the New Title I Requirements on Charter Schools. (16 pp.) 

http://www.ed.gov/policy/elsec/guid/edpicks.jhtml?src=fp

 August 18 Policy letter to Chief State School Officers on how to calculate the portion of transportation expenses 

related to choice when no additional costs are incurred. 

http://www.ed.gov/policy/elsec/guid/stateletters/choice/choice081804.html

 October 12 Policy letter to Chief State School Officers on reallocating reserved Title I funds, use of set-asides, and 

handling of schools that change Title I status. 

http://www.ed.gov/policy/elsec/guid/stateletters/uofcssos.html

Source: Education officials and Education’s Web site www.ed.gov. 

The February 2004 guidance was developed in response to state questions, 

often made at the request of districts, for further clarification of several 

issues. Although Education’s primary relationship was with state agencies, 

Education officials also made appearances at conferences attended by 

district and school officials and made a concerted effort to alert local 

education officials and other interested parties when it released its latest 

guidance through electronic mailing lists to subscribers and through its 

Web site. In many of the districts that we visited, officials told us that they 

had access to Education’s guidance, either directly from Education’s Web 

site, from the state agency or from a national organization representing 

their interests, such as the Council of the Great City Schools. 

One of the major changes in the February 2004 guidance was a list of 

10 ways that districts might increase capacity in order to provide school 

choice for all eligible students requesting transfers. The guidance 

suggested that districts “employ creativity and ingenuity” in developing 

ways to expand capacity, such as setting up “virtual” schools, reallocating 

portable classrooms, or creating “schools within schools” that would be 

new, distinct schools, with separate faculty, within the physical sites of 

schools required to provide choice. Some district officials we interviewed 

expressed their reservations about the feasibility of Education’s 

suggestions on how to develop the needed capacity, in part because of 

concerns about the costs of implementing the suggestions. 

The May 2004 technical assistance handbook describes promising 

practices in several key areas, including capacity, that have been 

employed to implement choice in 5 school districts. The most detailed and 

thorough description covers strategies that these districts have used to 

deal with parental notification and decision-making, but other chapters 

deal with capacity and transportation, support for sending and receiving 

schools, use of databases and surveys for planning, and factors leading to 
Page 32 GAO-05-7 No Child Left Behind Act 

success. With respect to capacity, the handbook lists the actions that 

certain districts have taken but does not describe them in detail. For 

example, the handbook states that Milwaukee established a special team 

that spent 2 months assessing available capacity; Miami-Dade used 

portables; Denver used teacher lounges and resource rooms as 

classrooms, and Mesa created new schools. Individuals interested in more 

details could contact the districts involved to find out more about 

timetables and costs of these various strategies at the postal or Web site 

addresses listed in the handbook. Education officials told us that within 

the first 6 months following its publication they had sent out over 16,000 

copies of handbook to state officials and to organizations representing 

local education officials, such as the National School Boards Association 

and the National Alliance of Black School Educators. 

Numerous questions concerning current or future implementation issues 

were raised during our visits with district and school officials that were 

not answered clearly in Education’s February 2004 guidance on choice. 

The issues involved how best to handle, within the context of federal 

regulations and guidance, certain complex situations involving timetables, 

schools receiving transfers, transportation, and capacity. With respect to 

timetables for parental notification, district officials we visited in two 

states were concerned about the accuracy of preliminary state 

determinations of the schools that made or did not make yearly 

performance goals. Because NCLBA required that they offer choice by the 

start of school, the districts were acting on preliminary but possibly 

inaccurate determinations made by states and were uncertain if there were 

any circumstances that would permit them to delay choice until they 

received final determinations. Basically, the questions involved how best 

to mitigate the risks for all involved—districts, schools, parents and 

students. Notices sent to parents had included warnings—either that the 

school status might change within a month or that the offer of choice 

might be withdrawn. However, there was interest in finding better ways to 

deal with the uncertainty involved, including what steps should be taken 

on behalf of parents and students when transfers have occurred either into 

or out of schools that were designated incorrectly. 

Even where school designations were known, planning for future 

contingencies raised a number of questions about schools offered as 

transfer options and about transportation arrangements. District officials 

Complexity of 

Implementing Choice 

Raises Issues Not 

Addressed in Guidance 
Page 33 GAO-05-7 No Child Left Behind Act 

explained that they are operating in a dynamic environment where school 

performance can change from one year to the next and their status as Title 

I or not Title I schools can also change.27 Officials in one district we visited 

asked for confirmation that, if they could not find reasonable alternatives, 

they would be permitted to offer as transfer options those schools that had 

missed their performance goals for one or more years, as long as they 

were not Title I schools. Confirmation could be inferred from the February 

2004 non-regulatory guidance on choice, but was not clear-cut. 

Considerations of schools offered as transfer options led into further 

questions about transportation provided for students who transferred, for 

example if students could continue to receive Title I-funded transportation 

if they had transferred into a Title I school offered as a transfer option that 

later missed its yearly performance goals for 2 consecutive years. 

In several districts we visited, we found that officials were struggling to 

find practical and realistic ways to offer choice when building capacity, 

budgets and timeframes were limited. Some of these officials had studied 

the suggestions offered in Education’s February guidance but considered 

creation of virtual or charter schools to be long-term projects that could 

not provide capacity in time to meet short deadlines. Other officials 

commented that they did not know what steps to take to create “schools 

within schools,” as suggested, or how to estimate the costs. Cost 

considerations were a major issue in several districts where capacity 

constraints had limited the number of transfers under NCLBA. 

Education officials told us in November 2004 that they believed that the 

guidance and technical assistance that they had provided thus far was 

sufficient to meet the needs identified by states and district officials with 

whom they were in contact. At that time, they had no specific plans to 

issue further guidance or provide additional technical assistance on these 

issues. However officials added that policy letters will continue to be 

issued as needed in response to questions raised by states that have not 

been addressed elsewhere. 

 27Title I funds must be provided to schools with high poverty rates. Schools that previously 

received no Title I funds may become eligible with changes in their student enrollment or 

may lose their eligibility. Also, districts have the option to extend Title I funding to other 

eligible schools with lower poverty rates, or having done so in the past, to alter their 

decision. For example, Memphis officials told us that they expanded the number of schools 

receiving Title I funds in school year 2004-2005. 
Page 34 GAO-05-7 No Child Left Behind Act 

Finally, some issues that district officials raised during our site visits were 

not ones for which Education could provide guidance. These issues 

involved distinctions between federal and state requirements that 

individual states would be expected to resolve for their districts. For 

example officials in one district sought clarification as to whether or not 

their state applied the NCLBA interventions both to schools not receiving 

Title I funds and to Title I schools. Officials in another district were unsure 

about whether their state exempted schools that did not receive Title I 

from some NCLBA interventions, such as school choice and supplemental 

services, but not from other interventions, such as corrective action and 

restructuring after repeatedly missing yearly performance goals. 

NCLBA is an important and complex piece of legislation, and as 

implementation proceeds, Education will need to continue to help states 

and districts address the many issues they face in providing school choice. 

State and districts officials, although positive about the intent of NCLBA, 

nevertheless identified a variety of challenges in implementing the law. 

Half of the districts we visited did not grant as many transfers as were 

requested because of constraints on the building capacities at many of 

their schools. Difficulties related to building capacity are unlikely to 

diminish in the future, and could become more pronounced if the number 

of students eligible to transfer increases and the number of schools 

available as potential transfer options decreases. In the first 2 years under 

NCLBA, Education data show that the number of schools not making their 

yearly performance goals increased. Several state officials suggest that this 

trend will continue. Consequently, it is likely that more schools will be 

identified for choice, which would increase the number of students eligible 

for transfer while decreasing the pool of possible transfer schools. 

Further, new challenges may arise if the schools to which students have 

transferred in the early years of NCLBA do not themselves make their 

yearly performance goals. 

In addition, our work raised questions about how well-informed parents 

are about the school choice option. In the second year of NCLBA, about 1 

percent of eligible students transferred, and without more information on 

the reasons parents do or do not take advantage of the transfer option, 

policy makers and school officials may miss opportunities to better serve 

parents and students through the choice option. In addition, it is unclear 

whether or not parents are receiving adequate information to make fully 

informed transfer decisions. It may be that parents do not fully understand 

why their child’s school was identified for choice or the educational 

services available in the transfer school. Education’s longitudinal study of 

Conclusions 
Page 35 GAO-05-7 No Child Left Behind Act 

NCLBA will address some of these questions. The parental survey will 

explore the reasons parents do or do not exercise the transfer option and 

the circumstances that facilitate or hinder their decisions. The result of the 

survey may give Education and policymakers insight into the reasons 

behind the numbers of students who have transferred, as well as assist 

school officials in assuring that parents are aware of the option. In 

addition, the technical assistance handbook that Education issued in May 

2004 provides some suggestions that may help districts improve their 

communications with parents, but this information is based on the 

experiences of only a small number of school districts. Districts may need 

additional help in various ways, including how to provide information on 

choice options that can be easily understood by parents and how to 

provide additional information parents need to make an informed 

decision. 

Finally, little is known about transferring students or the effects of 

transfers, but Education’s plans for its major study of NCLBA are 

promising. As planned, the study should provide insight into the 

demographic characteristics of students transferring under the school 

choice provision and the extent to which the lowest achieving students 

from low-income families, identified for priority consideration under the 

law, are exercising the transfer option. Equally important is Education’s 

proposed analysis of how transfers may affect the subsequent academic 

performance of students who change schools under the choice provision 

of NCLBA. This portion of Education’s proposed study is critical to 

informing policy makers and school officials about whether or not the 

school choice option is achieving its intended outcome of improving 

student achievement; however, this part of the study is still in the design 

phase. 

To help states and districts implement choice and to gain a better 

understanding of its impact, we recommend that the Secretary of 

Education: 

• Monitor issues related to limited classroom capacity that may arise as 

implementation proceeds, in particular, the extent to which capacity 

constraints hinder or prevent transfers. Based on this monitoring, 

Education should consider whether or not additional flexibility or 

guidance addressing capacity might be warranted. 

Recommendations for 

Executive Action 
Page 36 GAO-05-7 No Child Left Behind Act 

• Collect and disseminate additional examples of successful strategies that 

districts employ to address capacity limitations and information on the 

costs of these strategies. 

• Assist states in developing strategies for better informing parents about 

the school choice option by collecting and disseminating promising 

practices identified in the course of working with states and districts. For 

instance, Education might collect and share examples of clear, wellwritten, and particularly informative notices. In addition, Education 

should make the results of its parental surveys, conducted as part of its 

national study, widely available for use by states and districts to help them 

better refine their communications with parents regarding school choice. 

• For its student outcomes study, Education should use the methodology 

with the greatest potential to identify the effects of the school choice 

transfer on students’ academic achievement. The methodology selected 

should allow it to compare academic outcomes for transferring students 

over several years with outcomes for similar students not transferring, 

while accounting for differences in student demographics. The study 

should also examine the extent to which transferring students remain in 

the schools to which they transfer. 

We provided a draft of this report to the Department of Education for 

review and comment. Education’s written comments appear in appendix 

VII. Recommended technical changes have been incorporated in the report 

as appropriate. 

Education said that the report would be a useful addition to the literature 

on the public school choice provision and indicated its intent to use the 

findings and recommendations in the report to improve Education’s 

technical assistance to states and districts and to strengthen its 

implementation studies. Specifically, Education agreed with our 

recommendations concerning monitoring capacity and disseminating 

successful strategies to meet capacity challenges, noting several projects 

under development that might assist in carrying out these 

recommendations. Education also strongly supported our 

recommendation that it assist states in better informing parents about the 

school choice option and related some of its plans for doing so. Regarding 

our recommendation concerning the department’s study of choice 

implementation, Education said that it is working to design a rigorous 

analysis of student outcomes and will take our recommendation into 

consideration as it refines the design for the study. 

Agency Comments 

and Our Evaluation 
Page 37 GAO-05-7 No Child Left Behind Act 

We are sending copies of this report to appropriate congressional 

committees, the Secretary of Education, and other interested parties. 

Copies will be made available to other interested parties upon request. In 

addition, the report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. If you or your staff have any question about this 

report, please call me at (202) 512-7215. Key contributors are listed in 

appendix VIII. 

Marnie S. Shaul 

Director, Education, Workforce, and 

 Income Security Issues 
Appendix I: Scope and Methodology 

Page 38 GAO-05-7 No Child Left Behind Act 

The objectives of this report were to determine (1) the extent to which 

Title I schools have been affected by the school choice provision of The 

No Child Left Behind Act (NCLBA) of 2001 in terms of the number of 

schools identified for choice and the number of students exercising the 

option; (2) the experiences of selected school districts in implementing the 

choice provision; and (3) the kinds of guidance and technical assistance 

that the Department of Education provided states and districts as they 

implemented public school choice. 

To determine the extent that schools have been affected by school choice 

in terms of the number of schools required to offer choice and the number 

of students exercising the option, we analyzed data for school years 2002-

2003 and 2003-2004 using two sources: our survey of state education 

agencies and state reports to Education. To obtain data on the number of 

schools that had to offer choice, we used a different source for each 

school year. For 2002-2003, we surveyed state education agencies in all 50 

states, the District of Columbia, and Puerto Rico; for 2003-2004, we 

obtained data from Education that had been reported by each state in its 

Consolidated State Performance Report: Part I. Information on the 

number of students that chose to transfer to another school for 

school year 2002-2003 was obtained from the Consolidated State 

Performance Report: Part I; for 2003-2004, the data were obtained from 

our survey of the state education agencies, the District of Columbia, and 

Puerto Rico. Although there was a 100 percent response rate to our survey 

and to Education’s report, not all states provided complete information. 

Seven states did not provide any transfer information for 2003-2004 

because they did not plan to collect this information until later in school 

year 2004-2005. 

To test the reliability of these data, we performed a series of tests, which 

included checking that data were consistent, that subtotals added to totals 

and that data provided for one year bore a reasonable relationship to the 

next year’s data and to data reported elsewhere, including state education 

websites. Where we found discrepancies or sought clarification, we 

followed up with state officials. In several states, officials revised the 

numbers that they had initially reported to us or to Education. We 

determined these data to be sufficiently reliable for our purposes. 

In addition, we sought information on schools and students from several 

sources. The grade span and location of schools (urban or rural) identified 

for choice and the demographics of their students was available from the 

National Center for Education Statistics (NCES). We were not able to 

describe the characteristics of the schools required to offer choice in 2002-

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 39 GAO-05-7 No Child Left Behind Act 

2003 because the list of schools was not available. We analyzed data for 

the nation as a whole and by state, expressing the results in relation to the 

universe of all Title I schools or all public K-12 schools. When we 

compared results in the first school year with results in the second, we 

compared only states that provided information for both years and 

eliminated any states that provided data only for a single year. Because 

NCES data were not available for 2003-2004, the year for which we 

obtained lists of schools identified for choice, we used as a proxy the 2002-

2003 enrollment data for these schools including student numbers, 

minority status and eligibility for the free or reduced price school lunch 

program as a measure of the family income. Because these were the only 

data available, and because we considered them adequate for our 

purposes, we used 2002-2003 enrollment data to characterize schools in 

2003-2004, based on an assumption that at the aggregate levels the 

numbers and characteristics did not differ significantly from one year to 

the next. We discussed this assumption with education officials at NCES, 

and for a sample of states, tested it by checking the changes from 2001-

2002 to the following year for schools identified. We also tested the 

reliability of the NCES data by comparing our numbers to published totals 

and by reviewing documentation. We considered these data to be 

sufficiently reliable for our purposes. 

To determine the experiences of selected school districts’ implementation 

of NCLBA school choice, we visited eight districts that had schools 

required to offer choice. On the basis of our discussions with state officials 

and our own research, we selected districts located in seven states—

California, Illinois, Ohio, Mississippi, Pennsylvania, Tennessee, and 

Washington. Districts selected were based on geographic location and 

district profile in terms of the number of schools required to offer school 

choice, student population, and demographic profile. (See table 10 for 

district characteristics.) During our visits, we interviewed officials in 

school district offices and in most districts, also interviewed principals of 

schools that were required to offer school choice as well as principals of 

schools that received transferring students. In each of these districts, we 

attempted to obtain data on the characteristics of students—such as race, 

poverty, and academic achievement—that had transferred to another 

school under NCLBA school choice in school year 2003-2004; we had 

limited success at obtaining such information from most schools. We were 

able to obtain information on transferring students’ academic achievement 

from one district but most districts had not collected this information. 
Appendix I: Scope and Methodology 

Page 40 GAO-05-7 No Child Left Behind Act 

Table 10: Characteristics for 2003-2004 of Eight Districts We Visited 

District 

Characteristic 

Akron 

Public 

Schools, 

Ohio 

Chicago 

Public 

Schools, 

Ill. 

Elgin 

(School 

District U46), Ill.

Fresno 

Unified 

School 

District, 

Calif.

Memphis 

Public 

Schools, 

Tenn.

North 

Panola 

School 

District, 

MS 

Pittsburgh 

Public 

Schools, Pa.

Tacoma 

Public 

Schools, 

Wash.

Geographic area Midwest Midwest Midwest West South South Northeast West

Total schools in 

districta

58 588 51 86 176 5 85 54

Total enrollment in 

district 28,100 426,000 39,500 80,300 114,800b

1,820c 33,800 31,700

Number of schools 

required to offer 

choice 8 368 6 39 71d

1 21 5

Number of students 

eligible for choice 2,960 250,000 2,460 34,005 52,600 390 6,800 2,480

Number of students 

that transferred 76 548e

 60 101 388f0 151 253

Percentage of eligible 

students that 

transferred 2.6% 0.2% 2.4% 0.3% 0.7% 0% 2.2% 10.2%

Percentage of 

students 

economically 

disadvantaged 56% 85% 32% 75% 65% 94% 63% 55%

Voluntary school 

choice program Yes Yes No Yes Yes No Yes Yes

Source: GAO analysis of school data from state or district education agency Web sites and school district officials. 

a

Includes district charter and magnet schools; excludes specialized and alternative schools. 

b

Memphis student enrollment is average daily membership. 

c

The student count for North Panola is from the NCES Common Core of Data for 2002.2003. 

d

Memphis schools are those the state identified for choice in school year 2002-03. 

e

 Chicago approved 1,097 student transfers and about half of the students actually transferred. 

f Memphis approved 388 student transfers but did not collect data on the number of students that 

actually transferred. 

To determine the kinds of guidance and technical assistance that 

Education provided states and districts as they implemented NCLBA 

public school choice, we reviewed regulations, policy letters, and nonregulatory guidance provided to states and districts. We also interviewed 

Education officials involved with developing the guidance and providing 

assistance to states in implementing school choice. To obtain the 

perspective of officials using the guidance provided by Education, we 
Appendix I: Scope and Methodology 

Page 41 GAO-05-7 No Child Left Behind Act 

interviewed district officials at all eight sites and state agency officials in 

2 states. In addition, to obtain a national perspective on the effectiveness 

of Education’s guidance and assistance to the states and districts, we 

interviewed officials at the Council of the Great City Schools, the Council 

of Chief State School Officers, and the Center on Education Policy. 
Appendix II: NCLBA Interventions for 

Schools Not Meeting Yearly Performance 

Goals Over Time 

Page 42 GAO-05-7 No Child Left Behind Act 

Number of years of missing 

performance goals based on tests 

administered in prior school year 

NCLBA interventions for schools that do 

receive Title I funds 

NCLBA interventions for schools that 

do not receive-Title I funds 

First year missed None None; states may set their own 

Second year missed In first year of school improvement, required to 

offer choice 

None; states may set their own 

Third year missed In second year of school improvement, 

required to offer choice and supplemental 

educational services 

None; states may set their own 

Fourth year missed In corrective action,a required to offer choice 

and supplemental services 

None; states may set their own 

Fifth year missed In planning for restructuring,b required to offer 

choice and supplemental services 

None; states may set their own 

Sixth year missed In implementation of restructuring, required to 

offer choice and supplemental services 

None; states may set their own 

Source: GAO analysis of NCLBA. 

a

Corrective action is a significant intervention in a school that is designed to remedy the school’s 

persistent inability to make adequate progress toward all students becoming proficient in reading and 

mathematics. 

b

Restructuring is a major reorganization of a school, involving fundamental reforms, such as 

significant changes in the school’s staffing and governance. 

Appendix II: NCLBA Interventions for 

Schools Not Meeting Yearly Performance 

Goals Over Time 
Appendix III: Number of Title I Schools in 

Each State Identified for Choice in School 

Year 2002-2003 

Page 43 GAO-05-7 No Child Left Behind Act 

State 

Number of schools that 

received Title I funds

Number of schools 

identified for choice 

Percent of Title I schools 

identified for choice

Hawaii 139 82 58.99

Georgia 1,064 600 56.39

Indiana 791 236 29.84

Maryland 361 105 29.09

New Mexico 533 116 21.76

Illinois 2,433 526 21.62

Arizona 1,021 193 18.90

Delaware 106 20 18.87

New Jersey 1,379 259 18.78

Idaho 403 72 17.87

Massachusetts 1,129 195 17.27

Arkansas 825 123 14.91

California 5,467 814 14.89

New York 2,941 431 14.65

Colorado 582 80 13.75

Tennessee 856 114 13.32

Rhode Island 149 17 11.41

Pennsylvania 1,892 198 10.47

Nevada 117 12 10.26

Michigan 2,196a216 9.84

District of Columbia 172 15 8.72

Utah 216 18 8.33

Ohio 2,052 161 7.85

Kansas 648 50 7.72

Montana 643 45 7.00

North Dakota 443 29 6.55

Wisconsin 1,083 68 6.28

Alabama 872 52 5.96

Minnesota 1,007 60 5.96

Alaska 299 17 5.69

Nebraska 497 27 5.43

South Carolina 534 27 5.06

Washington 997 48 4.81

Virginia 785 34 4.33

South Dakota 345 13 3.77

Appendix III: Number of Title I Schools in 

Each State Identified for Choice in School 

Year 2002-2003 
Appendix III: Number of Title I Schools in 

Each State Identified for Choice in School 

Year 2002-2003 

Page 44 GAO-05-7 No Child Left Behind Act 

State 

Number of schools that 

received Title I funds

Number of schools 

identified for choice 

Percent of Title I schools 

identified for choice

Iowa 712 26 3.65

Puerto Rico 1,511 48 3.18

Kentucky 866 25 2.89

Oklahoma 1,188 30 2.53

West Virginia 452 8 1.77

Missouri 1,277 21 1.64

Connecticut 528 8 1.52

New Hampshire 269 4 1.49

Mississippi 668a9 1.35

North Carolina 1,131 15 1.33

Louisiana 943 11 1.17

Maine 442 4 0.90

Oregon 582 5 0.86

Texas 4,823 37 0.77

Florida 1,374 0 0.00

Vermont 214 0 0.00

Wyoming 171 0 0.00

Total 52,128 5,324 

Source: GAO survey, Education’s Consolidated State Performance Report. 

a

Michigan and Mississippi did not report the number of Title I schools for school year 2002-2003. 

Michigan suggested and we agreed to use the number in school year 2001-2002 as a proxy. For 

Mississippi, we used a proxy from the National Center for Education Statistics. 
Appendix IV: Number of Title I Schools in 

Each State Identified for Choice in School 

Year 2003-2004 

Page 45 GAO-05-7 No Child Left Behind Act 

State 

Number of schools that 

received Title I funds

Number of schools 

identified for choice

Percent of Title I schools 

identified for choice

Georgia 1,115 533 47.80

Hawaii 204 82 40.20

Arkansas 824 230 27.91

Maryland 380 102 26.84

Illinois 2,357 562 23.84

Nevada 117 27 23.08

New Mexico 546 120 21.98

California 5,521 1205 21.83

Alaska 296 64 21.62

Arizona 1,021 220 21.55

New Jersey 1,379a 262 19.00

Massachusetts 1,163 208 17.88

New York 3,006 528 17.56

Pennsylvania 1,724 298 17.29

South Carolina 549 90 16.39

Rhode Island 147 24 16.33

Michigan 2,196a352 16.03

Indiana 786 97 12.34

Colorado 659 80 12.14

Delaware 104 12 11.54

District of Columbia 138 15 10.87

Idaho 399 43 10.78

South Dakota 336 32 9.52

Puerto Rico 1,494 140 9.37

Ohio 2,116 191 9.03

Louisiana 945 69 7.30

Tennessee 856 56 6.54

North Dakota 365 23 6.30

Montana 678 40 5.90

Virginia 791 44 5.56

Alabama 859 46 5.36

Wisconsin 1,095 52 4.75

Kansas 665 30 4.51

Washington 995 44 4.42

Minnesota 1,006 38 3.78

Appendix IV: Number of Title I Schools in 

Each State Identified for Choice in School 

Year 2003-2004 
Appendix IV: Number of Title I Schools in 

Each State Identified for Choice in School 

Year 2003-2004 

Page 46 GAO-05-7 No Child Left Behind Act 

State 

Number of schools that 

received Title I funds

Number of schools 

identified for choice

Percent of Title I schools 

identified for choice

Oklahoma 1,238 46 3.72

North Carolina 1,154 35 3.03

Florida 1,426 43 3.02

Kentucky 874 25 2.86

Utah 218 6 2.75

Missouri 1,275 32 2.51

Connecticut 499 12 2.40

Vermont 209 4 1.91

West Virginia 409 7 1.71

Iowa 694 11 1.59

Maine 461 6 1.30

Nebraska 494 6 1.21

Oregon 595 7 1.18

Mississippi 668a7 1.05

New Hampshire 248 2 0.81

Texas 5,061 9 0.17

Wyoming 184 0 0.00

Total 52,539 6,217

Source: GAO survey, Education’s Consolidated State Performance Report. 

a

Michigan, Mississippi, and New Jersey did not report the number of Title I schools in school year 

2003-2004. Michigan suggested and we agreed to use the number in school year 2001-2002 as a 

proxy. For Mississippi, we used a proxy from the National Center for Education Statistics for the 

2002-2003 school year. For New Jersey, we used the number of Title I schools the state reported for 

the 2002-2003 school year. 
Appendix V: Number of Students in Each 

State Transferring under Choice Option in 

First 2 Years of NCLBA 

Page 47 GAO-05-7 No Child Left Behind Act 

State 

Number of students who 

transferred in 2002-2003

Number of students who 

transferred in 2003-2004

Percent of eligible studentsa

 who 

transferred in 2003-2004

Oregon 742 873 17.40

Florida Not applicable 1,820 6.28

South Carolina 519 1,772 4.28

West Virginia 49 90 4.14

New Mexico 529 1,699 3.72

Kentucky 229 384 3.66

Alabama 777 740 3.50

North Carolina 93 337 3.42

Connecticut 7 262 3.32

Delaware 0 195 2.92

Utah 204 58 2.85

Tennessee 810 929b2.82

Indiana 1,301 1,199 2.52

Virginia 277 432 2.26

Kansas 202 212 2.18

District of Columbia 192 197 2.18

Maryland 709 1,050 2.01

New Jersey 257 2,738 1.80

Minnesota Not available 270b1.68

New York 1,507 7,373 1.51

Iowa 170 60 1.48

Ohio 698 1,169 1.24

Washington 620 270b1.21

Nevada 127 226 1.20

Louisiana 18 371 0.88

Colorado 194 299b0.86

Pennsylvania 110 1,126 0.56

Illinois 1,418c1,364c0.34

Hawaii 21 154 0.31

Alaska 2 26 0.31

Massachusetts 845 304b 0.31

California 3,139 3,419 0.28

New Hampshire 1 2 0.23

Mississippi 4 7 0.19

Rhode Island 17 27b0.19

Appendix V: Number of Students in Each 

State Transferring under Choice Option in 

First 2 Years of NCLBA 
Appendix V: Number of Students in Each 

State Transferring under Choice Option in 

First 2 Years of NCLBA 

Page 48 GAO-05-7 No Child Left Behind Act 

State 

Number of students who 

transferred in 2002-2003

Number of students who 

transferred in 2003-2004

Percent of eligible studentsa who 

transferred in 2003-2004

Missouri 91 16 0.13

South Dakota 1 5 0.07

Idaho 0 4 0.03

Maine 0 0 0.00

Nebraska 0 0 0.00

North Dakota 11 0 0.00

Puerto Rico 0 0 0.00

Texas 59 0 0.00

Vermont Not applicable 0 0.00

Arizona 83 Not available Not available

Arkansas 171 Not available Not available

Georgia 1,874 Not available Not available

Montana 38 Not available Not available

Oklahoma 549 Not available Not available

Wisconsin 111 Not available Not available

Michigan Not available Not available Not available

Wyoming Not applicable Not applicable Not applicable

Total 18,732 31,479

Source: GAO survey, Education’s Consolidated State Performance Report. 

a

To calculate percents, we used NCES 2002-2003 school year enrollment figures for all schools 

identified for choice in the 2003-2004 school year. See app. I. 

b

Transfer figures shown may be understated, because they represent transfers in large districts in 

these 6 states: Colorado, Massachusetts, Minnesota, Rhode Island, Tennessee, and Washington. 

c

In both years, Illinois state officials reported transfers for most but not all districts. In 2002-2003, the 

state report included Chicago; in 2003-2004, the state report excluded Chicago and we added the 

transfer figure provided by Chicago. 

Note: Michigan officials told us that they were not able to distinguish the number of NCLBA transfers 

from the other transfers under their statewide open enrollment programs. 
Appendix VI: Poverty and Minority Rates of 

Schools Required to Offer Choice and Schools 

Offered as Transfer Options 

Page 49 GAO-05-7 No Child Left Behind Act 

Poverty Minorities 

School enrollment 

percentage by 

district 

Number of schools 

required to offer 

choice 

Number of schools 

offered as transfer 

options

Number of schools 

required to offer choice 

Number of schools 

offered as transfer 

options

Akron, Ohio 

0-25% 0 1 0 11

26-50% 0 9 0 11

51-75% 1 16 4 7

76-100% 7 11 4 8

Chicago, Illinois

0-25% 1 1 0 2

26-50% 0 5 0 2

51-75% 2 11 3 6

76-100% 365 23 365 29

Elgin, Illinois 

0-25% 0 13 0 4

26-50% 0 3 0 9

51-75% 3 0 1 3

76-100% 2 0 4 0

Fresno, California 

0-25% 0 3 0 0

26-50% 1 4 0 3

51-75% 4 1 1 7

76-100% 34 10 38 8

Memphis, 

Tennesseeb

 

0-25% 0 1 0 0

26-50% 0 9 0 2

51-75% 5 5 3 7

76-100% 66 30 68 36

Pittsburgh, 

Pennsylvania 

 

0-25% 0 0 0 6

26-50% 0 11 0 15

51-75% 2 17 8 17

76-100% 19 23 13 13

Appendix VI: Poverty and Minority Rates of 

Schools Required to Offer Choice and 

Schools Offered as Transfer Options 
Appendix VI: Poverty and Minority Rates of 

Schools Required to Offer Choice and Schools 

Offered as Transfer Options 

Page 50 GAO-05-7 No Child Left Behind Act 

Poverty Minorities 

School enrollment 

percentage by 

district 

Number of schools 

required to offer 

choice 

Number of schools 

offered as transfer 

options

Number of schools 

required to offer choice 

Number of schools 

offered as transfer 

options

Tacoma, Washington 

0-25% 0 0 0 0

26-50% 0 1 0 3

51-75% 0 3 4 5

76-100% 5 3 1 0

Source: GAO analysis of school data from state or district education agency Web sites. 

a

For Chicago, minority data were not available for one of the 40 transfer schools. 

b

Two of the 47 transfer schools in Memphis were new in school year 2003-2004, and no data were 

available on the poverty or minority rates for the student enrollment at these two schools. 

c

One of the 8 transfer schools in Tacoma was new in school year 2003-2004, and no data were 

available on the poverty rate for the student enrollment at this one school. 
Appendix VII: Comments from the 

Department of Education 

Page 51 GAO-05-7 No Child Left Behind Act 

Appendix VII: Comments from the 

Department of Education 
Appendix VII: Comments from the 

Department of Education 

Page 52 GAO-05-7 No Child Left Behind Act 
Appendix VII: Comments from the 

Department of Education 

Page 53 GAO-05-7 No Child Left Behind Act 
Appendix VIII: GAO Contacts and Staff 

Acknowledgments 

Page 54 GAO-05-7 No Child Left Behind Act 

Deborah L. Edwards (202) 512-5416 or edwardsd@gao.gov 

Patricia L. Elston (202) 512-3016 or elstonp@gao.gov 

In addition to those named above, the following individuals made 

important contributions to this report: Nancy Purvine, Sara Margraf, 

Scott Spicer, John Mingus, Amy Buck, and Margaret Armen. 

Appendix VIII: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 
Related GAO Products 

Page 55 GAO-05-7 No Child Left Behind Act 

No Child Left Behind Act: Improvements Needed in Education’s Process 

for Tracking States’ Implementation of Key Provisions. GAO-04-734. 

Washington, D.C.: September 30, 2004. 

No Child Left Behind Act: Additional Assistance and Research on 

Effective Strategies Would Help Small Rural Districts. GAO-04-909. 

Washington, D.C: September 23, 2004. 

Special Education: Additional Assistance and Better Coordination 

Needed among Education Offices to Help States Meet the NCLBA Teacher 

Requirements. GAO-04-659. Washington, D.C.: July 15, 2004. 

Student Mentoring Programs: Education’s Monitoring and Information 

Sharing Could Be Improved. GAO-04-581. Washington, D.C.: June 25, 2004. 

No Child Left Behind Act: More Information Would Help States 

Determine Which Teachers Are Highly Qualified. GAO-03-631. 

Washington, D.C.: July 17, 2003. 

Title I: Characteristics of Tests Will Influence Expenses: Information 

Sharing May Help States Realize Efficiencies. GAO-03-389. Washington, 

D.C.: May 8, 2003. 

Disadvantaged Students: Fiscal Oversight of Title I Could Be Improved. 

GAO-03-377. Washington, D.C.: February 28, 2003. 

Title I: Education Needs to Monitor States’ Scoring of Assessments. 

GAO-02-393. Washington, D.C.: April 1, 2002. 

Title I Funding: Poor Children Benefit Though Funding Per Poor Child 

Differs. GAO-02-242. Washington, D.C.: January 31, 2002. 

Title I Program: Stronger Accountability Needed for Performance of 

Disadvantaged Students. GAO/HEHS-00-89. Washington, D.C.: June 1, 

2000. 

Related GAO Products 

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