Report to the Ranking Minority 

Member, Committee on Health, 

Education, Labor, and Pensions, 

U.S. Senate 

United States Government Accountability Office

GAO

July 2004 SPECIAL 

EDUCATION 

Additional Assistance 

and Better 

Coordination Needed 

among Education 

Offices to Help States 

Meet the NCLBA 

Teacher Requirements

GAO-04-659 
www.gao.gov/cgi-bin/getrpt?GAO-04-659.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Marnie S. 

Shaul, (202) 512-7215, shaulm@gao.gov. 

Highlights of GAO-04-659, a report to the 

Ranking Minority Member, Committee on 

Health, Education, Labor, and Pensions, 

United States Senate 

July 2004

SPECIAL EDUCATION

Additional Assistance and Better 

Coordination Needed among Education 

Offices to Help States Meet the NCLBA 

Teacher Requirements 

In the 2002-2003 school year, all states, the District of Columbia, and Puerto 

Rico required that special education teachers have a bachelor’s degree and 

be certified to teach—two of NCLBA’s teacher qualification requirements—

and half required special education teachers to demonstrate subject matter 

competency in core academic subjects, which is the third requirement. 

Specifically, 24 states, the District of Columbia, and Puerto Rico required 

their teachers to demonstrate some level of subject matter competency by 

having a degree or passing state tests in the core academic subjects that they 

wished to teach. Teachers of core academic subjects in the remaining states 

that did not have such requirements might not be positioned to meet the 

NCLBA requirements. To meet NCLBA teacher requirements, teachers 

would need to demonstrate competency in core academic subjects by the 

end of the 2005-2006 school year. 

Status of Special Education Teacher Subject Matter Competency Requirements for School 

Year 2002-2003, by State 

Source: GAO analysis of survey responses from the state special education directors in the 50 states, D.C., and P.R. for the 

2002-2003 school year.

States without subject matter 

competency requirements (26)

States with subject matter 

competency requirements 

(24, D.C., and P.R.)

Alaska

Hawaii

N.Y.

Ala.

Ariz. Ark.

Calif. Colo.

Fla.

Ga.

Idaho

Ill. Ind.

Iowa

Kans. Ky.

La.

Maine

Mich.

Minn.

Miss.

Mo.

Mont.

Nev. Nebr.

Vt.

N.H.

Mass.

R.I.

Conn.

N.J.

Del.

Md. N. Mex.

N.C.

N. Dak.

Ohio

Okla.

Oreg.

Pa.

S.C.

S. Dak.

Tenn.

Tex.

Utah

Va.

Wash.

Wis.

Wyo.

W.Va.

P.R.

D.C.

State education officials reported that the availability of funds to support 

professional development facilitated implementation of the NCLBA teacher 

requirements, while other factors, such as uncertainty about how to apply 

the subject matter competency requirement to special education teachers, 

impeded implementation. State education officials and national education 

organizations’ representatives we interviewed cited the need for more 

assistance from Education in explaining NCLBA’s teacher requirements and 

identifying implementation strategies. 

Education has provided a range of assistance, such as site visits, Webbased guidance, and financial assistance, to help states implement the 

highly qualified teacher requirements. However, department 

coordination related to the implementation of NCLBA’s teacher 

requirements for special education teachers has been limited.

During the 2001-2002 school year, 

more than 400,000 special 

education teachers provided 

instructional services to 

approximately 6 million students 

with disabilities in U.S. schools. 

Two federal laws contain teacher 

qualification requirements that 

apply to special education 

teachers: the No Child Left Behind 

Act (NCLBA) and the Individuals 

with Disabilities Education Act 

(IDEA). 

Given the committee’s interest in 

issues related to highly qualified 

special education teachers, we are 

providing information about (1) the 

state certification requirements, 

including the use of alternative 

certification programs, for special 

education teachers, and how they 

relate to NCLBA requirements; 

(2) the factors that facilitate or 

impede state efforts to ensure that 

special education teachers meet 

NCLBA requirements; and (3) how 

different offices in the Department 

of Education (Education) assist 

states in addressing NCLBA 

teacher requirements. 

GAO recommends that the 

Secretary of Education provide 

additional assistance to states in 

explaining NCLBA teacher 

requirements and identifying 

implementation strategies for 

special education teachers, and 

formalize its efforts to improve the 

department’s internal coordination 

related to the implementation of 

these teacher quality requirements. 
Page i GAO-04-659 Special Education 

Letter 1

Results in Brief 2

Background 4

All States Implemented at Least Two of Three NCLBA Teacher 

Requirements for Special Education Teachers 7

State Officials Cited Several Factors That Affected the 

Implementation of NCLBA Subject Matter Competency 

Requirements for Special Education Teachers 11

Coordination among Education’s Offices Responsible for 

Educating Students with Disabilities Was Limited 16

Conclusions 18

Recommendations for Executive Action 19

Agency Comments and Our Evaluation 19

Appendix I Thirty-One States with Alternative Routes to 

Certification in Special Education during the 

2002-2003 School Year 22 

Appendix II Comments from the Department of Education 28 

Appendix III GAO Contacts and Staff Acknowledgments 33 

GAO Contacts 33

Staff Acknowledgments 33

Table 

Table 1: Application of the NCLBA Teacher Quality Requirements 

to Special Educators’ Instructional Roles 14

Figure 

Figure 1: Status of Special Education Teacher Subject Matter 

Competency Requirements for School Year 2002-2003, by 

State 9

Contents 
Page ii GAO-04-659 Special Education 

Abbreviations 

ESEA Elementary and Secondary Education Act 

HOUSSE high, objective, uniform state standard of evaluation 

IDEA Individuals with Disabilities Education Act 

IEP individualized education program 

NCLBA No Child Left Behind Act of 2001 

OESE Office of Elementary and Secondary Education 

OSEP Office of Special Education Programs 

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Page 1 GAO-04-659 Special Education 

July 15, 2004 

The Honorable Edward M. Kennedy 

Ranking Minority Member 

Committee on Health, Education, 

 Labor, and Pensions 

United States Senate 

Dear Senator Kennedy: 

During the 2001-2002 school year, more than 400,000 special education 

teachers provided instructional services to approximately 6 million 

students with disabilities in U.S. schools. Two federal laws contain teacher 

qualification requirements that apply to special education teachers: the No 

Child Left Behind Act (NCLBA) of 2001 and the Individuals with 

Disabilities Education Act (IDEA), which was last amended in 1997. 

Within the Department of Education (Education), the Office of Elementary 

and Secondary Education (OESE) has primary responsibility for 

implementing NCLBA requirements, and the Office of Special Education 

Programs (OSEP) has primary responsibility for implementing IDEA 

requirements. State officials have raised issues regarding the compatibility 

of the laws’ teacher qualification requirements and how to apply NCLBA 

requirements to special education teachers. 

NCLBA requires that all teachers of “core academic subjects,” such as 

English, meet teacher qualification requirements, and most of these 

teachers must do so by the end of the 2005-2006 school year. To meet 

requirements, teachers (1) must have at least a bachelor’s degree, (2) be 

certified to teach by their states, and (3) must demonstrate subject matter 

competence in each core academic subject that they teach. Under the 

NCLBA, all teachers, including special education teachers, who provide 

instruction in core academic subjects are generally required to meet 

NCLBA requirements. However, special education teachers who provide 

other types of instruction do not need to meet NCLBA requirements. IDEA 

generally requires teachers to be appropriately and adequately trained in 

accordance with standards established by each state but does not specify 

any other minimum qualifications for special education teachers. Congress 

is considering including provisions on special education teacher 

qualifications in the pending reauthorization of IDEA. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-04-659 Special Education 

Given your interest in issues related to special education teacher 

qualifications, we are providing information about (1) the state 

certification requirements, including the use of alternative certification 

programs, for special education teachers, and how they relate to NCLBA 

requirements; (2) the factors that facilitate or impede state efforts to 

ensure that special education teachers meet NCLBA requirements; and 

(3) how different offices in the U.S. Department of Education assist states 

in addressing NCLBA teacher requirements. 

To obtain this information, we used multiple data collection methods. 

First, we surveyed special education directors in 50 states, the District of 

Columbia, and Puerto Rico1

 to obtain information on their states or 

territories for the 2002-2003 school year in the following areas: special 

education teacher certification requirements, the conditions or issues that 

affected implementation of the NCLBA teacher quality requirements for 

special education teachers, and the assistance that various Education 

offices provided states in implementing NCLBA requirements for special 

education teachers. We achieved a 100 percent response rate. Second, we 

interviewed education officials in 6 states: Arkansas, Maryland, 

Massachusetts, New York, South Dakota, and Washington. These states 

were selected for variance in the number of special education students 

served, the percentage of certified special education teachers, and 

geographic location. We also interviewed about 20 federal education 

officials and representatives from 8 national education organizations 

regarding special education teacher certification, qualifications, meeting 

NCLBA teacher requirements, and the assistance various Education 

offices provided to states in these areas. Finally, we reviewed the Internet 

sites of all states to gather information about certification requirements 

and alternative certification programs for special education teachers. We 

also analyzed agency documentation, legislation, and other documentation 

related to special education teacher qualifications and requirements. We 

conducted our work between August 2003 and June 2004 in accordance 

with generally accepted government auditing standards. 

In the 2002-2003 school year, all states required that special education 

teachers have a bachelor’s degree and be certified to teach—two of the 

NCLBA teacher qualification requirements—and half required special 

 1

Hereinafter, the term states will refer collectively to the 50 states plus the District of 

Columbia and Puerto Rico. 

Results in Brief 
Page 3 GAO-04-659 Special Education 

education teachers to demonstrate competency in core academic subjects, 

the third requirement. Specifically, 26 states required their teachers to 

demonstrate some level of subject matter competency by having a degree 

or passing tests in the academic subjects that they wished to teach. The 

remaining states did not have such requirements; in these states, statecertified special education teachers who were assigned to teach core 

academic subjects might not be positioned to meet the NCLBA 

requirements. To meet NCLBA teacher requirements, teachers would need 

to demonstrate competency in core academic subjects by the end of the 

2005-2006 school year. In 31 states that offered alternative routes to 

teacher certification, certification requirements for alternative route and 

traditional teacher preparation program graduates followed a similar 

pattern in terms of alignment with NCLBA teacher requirements. 

State education officials reported that while the availability of funds to 

support professional development facilitated implementation of the 

subject matter competency requirements, other factors, such as 

uncertainty about how to apply these requirements to special education 

teachers teaching multiple subjects, impeded implementation. Some states 

helped teachers meet requirements by providing financial aid for 

coursework. Other states have provided services to help teachers meet 

requirements—for example, allowing teachers to demonstrate subject 

matter competency without taking an exam or pursuing a degree. About 

half of the state officials and national education organizations’ 

representatives we interviewed reported that states needed more 

assistance on how to implement NCLBA teacher requirements. In addition, 

state officials reported that meeting the subject matter competency 

requirements would be challenging because of the time frame for 

implementation. Although recent Education guidance may have resolved 

some concerns regarding time frames, some state officials we interviewed 

have continued to report uncertainty regarding the application of the 

subject matter competency requirement to special education teachers. 

Education officials noted that NCLBA requirements apply to all teachers, 

but they also have said that the assessment level of the students being 

taught could be considered in determining the level of subject matter 

competency requirements for special education teachers. This could be 

confusing when special education teachers teach high school students 

functioning at elementary school levels because requirements differ for 

different grade levels. 

Education has provided a range of assistance, such as site visits, Webbased guidance, and financial assistance, to help states implement the 

highly qualified teacher requirements. However, department coordination 
Page 4 GAO-04-659 Special Education 

related to the implementation of NCLBA’s teacher requirements for special 

education teachers has been limited. Within Education, OESE has taken 

the lead in site visits and posting Web-based guidance, with support from 

offices such as the Office of the Secretary and Office of General Counsel. 

OSEP, however, played a limited role in these efforts. When states 

reportedly sought OSEP’s guidance on requirements for special education 

teachers, OSEP officials told us that they generally referred state officials 

to OESE or to the NCLBA Web site. Further, until recently, OSEP was not 

a member of Education’s teacher quality policy team, which is responsible 

for responding to state issues and identifying policy concerns. Special 

education teacher issues were among the most frequently discussed topics 

in team meetings. Because of OSEP’s limited involvement prior to being 

added to the team, Education may not have been in a position to be fully 

apprised of how special education concerns could affect implementation. 

However, Education officials told us that they included OSEP by 

contacting it to clarify IDEA substantive issues. 

In this report we are recommending that the Secretary of Education 

provide additional assistance to states in explaining NCLBA teacher 

quality requirements and identifying implementation strategies. We are 

also recommending that the Secretary of Education formalize efforts to 

improve the department’s internal coordination related to the 

implementation of these NCLBA teacher quality requirements. 

The No Child Left Behind Act of 2001,2

 which reauthorized the Elementary 

and Secondary Education Act (ESEA), is designed to improve the 

education of all students and the quality of teachers. NCLBA requires that 

all teachers of “core academic subjects”—defined to mean English, 

reading or language arts, mathematics, science, foreign languages, civics 

and government, economics, arts, history, and geography—be “highly 

qualified.” To be highly qualified, teachers (1) must have at least a 

bachelor’s degree, (2) be certified to teach by their state, and 

(3) demonstrate subject matter competency in each core academic subject 

that they teach. A teacher’s options for demonstrating subject matter 

competency vary according to whether the teacher is new and the grade 

level being taught. New elementary school teachers must demonstrate 

subject matter competency by passing a rigorous state exam in the basic 

elementary school curriculum; new middle or high school teachers may 

 2

Pub. L. No. 107-110, 115 Stat. 1425. 

Background 
Page 5 GAO-04-659 Special Education 

establish that they are highly qualified by either taking a rigorous state 

exam or successfully completing a degree (or equivalent credentialing) in 

each core academic subject taught. In addition, NCLBA allows current 

teachers to demonstrate subject matter competency based on a “high 

objective uniform state standard of evaluation.”3

 For example, under these 

uniform state standards, a combination of experience, expertise, and 

professional training could be used to meet the NCLBA subject matter 

competency requirements. 

Education has issued guidance to states on how to apply NCLBA 

requirements to all teachers, including special education teachers. 

According to Education’s January 2004 guidance, special education 

teachers who provide instruction in core academic subjects, such as 

teachers in self-contained classrooms, are required to comply with the 

NCLBA subject matter competency requirements. In contrast, those 

special educators who do not provide instruction in core academic 

subjects, such as those who provide consultative services to highly 

qualified general educators, do not have to comply with the NCLBA 

teacher requirements. In addition, Education’s March 2004 guidance 

provided additional flexibility on the implementation deadline and 

competency requirements for some special education teachers. 

Specifically, the guidance stated that educators in eligible rural areas who 

are highly qualified in at least one core academic subject they teach would 

have 3 additional years to demonstrate subject matter competency in other 

academic areas. The guidance also states that teachers who provide 

instruction in multiple core academic subjects will be able to demonstrate 

their subject matter competency through one process under their states’ 

uniform standards, such as taking a single test that covers multiple core 

academic subjects.4

IDEA is the primary federal law that addresses the unique needs of 

children with disabilities, including, among others, children with specific 

learning disabilities, speech and language impairments, mental 

retardation, and serious emotional disturbance. The law mandates that a 

free appropriate public education be made available for all eligible 

children with disabilities, ensures due process rights, requires an 

 3

Referred to as “HOUSSE” by state education administrators. 

4

For additional information on the U.S. Department of Education’s March 2004 guidance on 

the opportunities for flexibility in meeting the No Child Left Behind Act’s requirements, go 

to http://www.ed.gov/policy/elsec/guid/secletter/040331.html. 
Page 6 GAO-04-659 Special Education 

individualized education program (IEP)5 for each student, requires the 

inclusion of students with disabilities in state and district wide assessment 

programs, and requires the placement of students in the least restrictive 

environment. Under IDEA, states are required to establish special 

education teacher requirements that are based on the highest 

requirements in the state for personnel serving children and youth with 

disabilities. 

Congress is considering including new special education teacher 

qualifications in the reauthorized IDEA. Under H.R. 1350, a new definition 

of “highly qualified,” as it refers to teachers, would be added with the same 

meaning as in NCLBA. In contrast, S. 1248 would add an extensive 

definition of “highly qualified” with respect to the qualification of 

educational personnel, while taking into account differences between 

special education and general education teachers. For example, under 

S. 1248, special education teachers who consult with secondary school 

core academic subject teachers for children with disabilities would need 

to be fully certified in special education and demonstrate the knowledge 

and skills necessary to teach students with disabilities, to be highly 

qualified.6

 In addition, S. 1248 proposes to extend the deadline for meeting 

the highly qualified teacher requirements by 1 year—to school year 2006-

2007. 

Two offices within the Department of Education are responsible for 

addressing special education teacher qualifications: the Office of 

Elementary and Secondary Education and the Office of Special Education 

Programs. The enactment of NCLBA significantly changed the 

expectations for all teachers, including those instructing students with 

disabilities. For example, states are now required to report on the 

qualifications of their teachers and the progress of their students. 

OESE has assumed responsibility for developing policies for improving the 

achievement of all students and the qualifications of teachers. In addition, 

 5

The term individualized education program refers to a written statement that is 

developed for each student with a disability that specifies, among other components, the 

goals and objectives for the student, describes the services that a student will receive, and 

specifies the extent to which the student will participate in the regular education setting 

with nondisabled peers and or in the general curriculum adopted for all students. 

6

For additional information see The Individuals with Disabilities Education Act (IDEA): 

Selected Changes that Would be Made to the Law by S. 1248, 108th Congress, 

Congressional Research Service (May 2004). 
Page 7 GAO-04-659 Special Education 

the office provides technical and financial assistance to states and 

localities, in part so they can help teachers meet the new qualification 

requirements. For example, in fiscal year 2003, OESE provided funding to 

state and local education agencies through its Improving Teacher Quality 

state grant program.7

OSEP is responsible for providing leadership and financial resources to 

help states and localities implement IDEA for students with disabilities 

and their teachers. These responsibilities include awarding discretionary 

grants and contracts for projects designed to improve service provision to 

children with disabilities. In 2003, OSEP provided funding to 30 states 

through the State Improvement Grants program.8

 OSEP also supports 

research on special education through centers such as the Center on 

Personnel Studies in Special Education. 

In the 2002-2003 school year, all states required that special education 

teachers have a bachelor’s degree and be certified to teach—two of the 

three NCLBA teacher qualification requirements—and half required 

special education teachers to demonstrate competency in core academic 

subjects, which is the third requirement. In the 26 states that did not 

require teachers to demonstrate subject matter competency, state-certified 

special education teachers who were assigned to instruct core academic 

subjects might not be positioned to meet the NCLBA requirements. In 31 

states that offered alternative routes to teacher certification, certification 

requirements for alternative route and traditional teacher preparation 

program graduates followed a similar pattern, with half meeting two of 

three NCLBA teacher requirements. 

 7

Improving Teacher Quality state grants are made specifically to encourage states to 

improve the quality of their teaching force through activities such as recruiting and 

retaining highly qualified teachers and principals and reforming teacher and principal 

certification programs. 

8

The purpose of State Improvement Grant program is to assist state educational agencies 

and their partners with reforming and improving, among other things, their systems for 

professional development and technical assistance to improve results for children with 

disabilities. 

All States 

Implemented at Least 

Two of Three NCLBA 

Teacher Requirements 

for Special Education 

Teachers 
Page 8 GAO-04-659 Special Education 

Every state required special education teachers to hold at least a 

bachelor’s degree and to be certified by their states before teaching, 

according to our survey results and reviews of Education documents and 

state Web sites.9

 States varied in whether they offered one or more types 

of teaching certificates for special educators. Specifically, 30 states 

established a single certification for special education teachers that 

covered kindergarten through 12th grade, according to survey 

respondents. The remaining 22 states offered two or more certifications. 

For example, some states offered different certifications for teachers of 

elementary, middle school, and high school students. In addition, some 

states certified special education teachers to serve students with specific 

disability categories such as hearing impaired and emotionally disturbed, 

and/or with broader disability categories, such as mild, moderate, and 

severe special needs. Finally, several states certified their special 

education teachers for specific instructional roles such as general special 

education teacher, resource room teacher, or collaborative teacher. 

During the 2002-2003 school year, 24 states, the District of Columbia, and 

Puerto Rico required special education teachers to demonstrate some 

level of competency in the core academic subjects that they wished to 

teach at the time of their initial certification by having a degree or passing 

tests in the academic subjects that they wished to teach. Teachers in these 

states are better positioned to meet NCLBA’s teacher requirements. 

However, the level of competency required varied by state and in some 

cases may not meet NCLBA competency level requirements. The rest of 

the states did not have any such requirements. (See fig. 1.) 

 9

Although data are available on the numbers of certified and uncertified special education 

teachers, we did not consider the data to be sufficiently reliable for our reporting purposes. 

Half of States Have Similar 

Teacher Requirements to 

NCLBA, but 26 States Did 

Not Require Special 

Education Teachers to 

Demonstrate Competency 

in Core Academic Subjects 
Page 9 GAO-04-659 Special Education 

Figure 1: Status of Special Education Teacher Subject Matter Competency Requirements for School Year 2002-2003, by State 

In states that did not have these requirements, the certified special 

education teachers who were assigned to instruct core academic subjects 

might not be positioned to meet the NCLBA requirements. To meet NCLBA 

teacher requirements, these teachers would need to demonstrate subject 

matter competency by the end of the 2005-2006 school year. 

The extent to which special education teachers were required to meet 

NCLBA subject matter competency requirements depended upon their 

instructional roles, which could sometimes be difficult for prospective 

teachers to determine. Special education teachers often attained their 

Source: GAO analysis of survey responses from the state special education directors in the 50 states, D.C., and P.R. for the 2002-2003 school year.

States without subject matter competency requirements (26 states)

States with subject matter competency requirements (24 states, D.C., and P.R.)

Alaska

Hawaii

New York

Alabama

Arizona

Arkansas

California Colorado

Florida

Georgia

Idaho

Illinois Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

Vermont

New Hampshire

Massachusetts

Rhode Island

Connecticut

New Jersey

Delaware

Maryland

New Mexico

North 

Carolina

North 

Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

South 

Carolina

South

Dakota

Tennessee

Texas

Utah

Virginia

Washington

Wisconsin

Wyoming

West

Virginia

Puerto Rico

District of Columbia
Page 10 GAO-04-659 Special Education 

certification prior to being hired by local school districts for specific grade 

levels, subjects, or instructional roles. Therefore, these individuals might 

not be positioned to meet NCLBA teacher requirements for their future 

instructional roles. Furthermore, any special education teacher who was 

assigned to teach a different subject from one year to the next might meet 

subject matter competency requirements one year but not the next. 

According to Education officials, these challenges are not specific to 

special education teachers and will require school districts to be more 

mindful of teacher qualifications, including subject matter mastery, when 

assigning teachers to various teaching roles. 

According to survey respondents, 31 states provided alternative routes to 

certification for prospective special education teachers. States have 

developed such routes to meet specific teacher shortages as well as to 

allow professionals in related fields to become teachers. The alternative 

routes to certification programs that we reviewed were generally 

administered by the state education agencies, often through institutions of 

higher education. However, this was not always the case: In Maryland, for 

example, one county contracted with Sylvan Learning Center10 and the 

New Teacher Project11 to provide its alternative route to certification 

program. 

Most of the states that provided alternative routes to certification required 

that the graduates from such alternative route to certification programs 

fulfill the same certification requirements as graduates from traditional 

special education teacher preparation programs, such as having a 

bachelor’s degree and passing teacher licensing examinations. The 

primary difference between alternative route programs and traditional 

teacher preparation programs was the extent to which teaching candidates 

received practical teaching experience prior to attaining full state 

certification. 

In general, prospective teachers in alternative route to certification 

programs were required to receive more practical teaching experience 

 10Sylvan Learning Centers is an international organization that provides personalized 

instruction to students of all ages and skill levels. 

11The New Teacher Project is a national organization that works with state departments of 

education, school districts, and institutions of higher education to recruit, select, and train 

new teachers. 

Special Education 

Teachers from Programs 

Offering Alternative 

Routes to Certification 

Were Generally Required 

to Meet the Same 

Certification Requirements 

as Other Special Education 

Teachers 
Page 11 GAO-04-659 Special Education 

before being certified than were teachers in traditional programs. For 

example, candidates in an alternative route to certification program in 

Illinois were required to complete a 1-year mentored teaching internship, 

while most traditional certification programs for special education 

teachers required teaching candidates to complete a 9- to 18-week 

supervised student teaching assignment. This additional teaching 

experience has been required because individuals in some alternative 

programs have not received courses in pedagogy and instructional 

techniques. (See app. I for state special education alternative route to 

certification program contact information.) 

State officials indicated that implementing the core academic subject 

competency requirements of NCLBA would be difficult and cited factors 

that have facilitated or impeded application of this requirement to special 

education teachers. State officials identified several key facilitators, 

including having funds available to dedicate to special educators’ 

professional development and having preexisting or ongoing efforts to 

develop subject matter competency standards for special educators. State 

officials and national education organizations’ representatives also cited 

several factors that impeded meeting the subject competency 

requirements, including uncertainty about how to apply the law to special 

education teachers in some circumstances, and the need for additional 

assistance from Education in identifying implementation strategies. 

Survey respondents, as well as state officials and national education 

organizations’ representatives we interviewed, reported that the 

availability of professional development funding and the flexibility to use 

funds were essential in helping teachers meet the NCLBA subject matter 

competency requirement. For example, officials in 19 states reported 

helping special education teachers by allocating some of the states’ 

professional development money to financial aid for those seeking to 

enhance their knowledge in a core academic subject, such as by pursuing 

a degree. In addition, states can use their professional development funds 

to create alternative routes to certification. This could result in developing 

a cadre of special educators who would already have expertise in a core 

academic subject area. 

Survey respondents described several state assistance initiatives that were 

designed to help special education teachers meet the subject matter 

State Officials Cited 

Several Factors That 

Affected the 

Implementation of 

NCLBA Subject 

Matter Competency 

Requirements for 

Special Education 

Teachers 

Availability of Professional 

Development Funds Was 

among the Factors Cited 

as Facilitating the 

Implementation of NCLBA 

Requirements 
Page 12 GAO-04-659 Special Education 

competency requirements. For example, 17 survey respondents reported 

holding workshops for special education teachers on specific academic 

subjects, and a few states held review sessions to prepare teachers for 

states’ academic content exams. In addition, respondents from 7 states 

reported providing sample test questions to help teachers prepare for 

subject matter competency tests. Nineteen survey respondents reported 

that their states had established partnerships with institutions of higher 

education to develop and implement strategies to assist special education 

teachers. For example, Arkansas collaborated with state colleges and 

universities to develop dual-certification programs for special educators. 

Officials we interviewed from 2 of 6 states said that they expected their 

uniform state standards of evaluation would make it easier for their 

experienced teachers to meet NCLBA subject matter requirements. 

Specifically, they asserted that these competency standards would allow 

states and territories to design alternative methods for evaluating teachers’ 

knowledge of the subject matter they teach, other than having a degree or 

passing subject matter tests in a core academic subject. According to 

officials in 2 of the 6 states we interviewed, their alternative methods of 

evaluating teachers’ subject matter competency would take into account 

both a teacher’s years of experience and factors such as participation in 

professional development courses. A few state officials and national 

education organizations’ representatives we spoke to commented that the 

flexibility to design alternative methods for evaluating teachers’ subject 

matter knowledge provided more options for making subject matter 

competency assessments of experienced special education teachers. 

State officials we interviewed and surveyed reported being concerned 

about how difficult meeting the subject matter competency requirements 

might be for special educators providing instruction, given that their roles 

may require them to teach at multiple grade levels or multiple subjects. 

State officials told us that because of special educator shortages, special 

education teachers’ instructional roles might vary. For example, some 

special educators might not have to meet subject matter competency 

requirements when they were hired, but subsequently might have to meet 

subject matter competency requirements for one or more core academic 

subjects, depending upon their instructional roles. Education has issued 

guidance that says that teachers instructing core academic subjects must 

demonstrate subject matter competency. This guidance applies to all 

teachers, including special education teachers. However, Education 

officials told us that the assessment level of the student being taught was a 

consideration in determining the application of the NCLBA subject matter 

Uncertainty about How to 

Apply the Subject Matter 

Competency Requirement 

to Special Education 

Teachers in Different 

Instructional Roles Was 

One of Several Barriers 

Cited to Meeting the 

NCLBA Requirements 
Page 13 GAO-04-659 Special Education 

competency requirement. The inclusion of the assessment levels in 

determining how to apply the NCLBA requirements may explain some of 

state officials’ uncertainty regarding the application of the requirement to 

special education teachers. 

About half of the state officials and national education organizations’ 

representatives we interviewed reported that states needed more 

assistance on how to implement NCLBA teacher requirements for their 

special education teachers. For example, some state officials from 

Oklahoma and South Dakota reported being uncertain how to apply the 

requirements to the unique situations in which special education teachers 

provide instruction. Officials in these states reported that they were 

unclear whether a teacher providing instruction in core academic subjects 

to high school age students who are performing at the elementary level 

would need to meet elementary or high school level subject competency 

requirements (See table 1 for examples of the application of NCLBA 

requirements to special educators’ instructional roles).12

 12Students with disabilities generally attend school with other students of similar ages. As a 

result, a high school-aged student with a disability would generally receive instruction with 

other high school-aged students in general education or separate classrooms. In addition, 

students with disabilities receive their instruction based upon their individuals needs. This 

instruction may be presented either at or below the student’s chronological age grade level 

as required by the student’s IEP. 
Page 14 GAO-04-659 Special Education 

Table 1: Application of the NCLBA Teacher Quality Requirements to Special Educators’ Instructional Roles 

Nature of work Examples of associated roles 

NCLBA requirements special education 

teachers must meet 

Providing instruction to students in core 

academic subjects 

Providing instruction to special education 

students, e.g., teachers in self-contained 

classrooms and some resource room 

teachers 

(1) Bachelor’s degree 

(2) State certification 

(3) Demonstration of subject matter 

competency in each core academic subject 

taught. 

(Elementary school teachers must only 

demonstrate subject matter competency in 

general elementary school curriculum.) 

All other special education instruction Resource room teachers who reinforce 

instruction provided by other highly 

qualified teachers 

Teachers that consult with a highly 

qualified general education teacher to 

assist students in one grade 

None 

Source: GAO analysis of NCLBA requirements. 

Officials from half the states we surveyed indicated that they did not 

believe the law provided enough flexibility for teachers to meet the subject 

competency requirements. A few state officials we interviewed, 

particularly those with a large percentage of rural districts, such as those 

in South Dakota and Arkansas, mentioned this perceived lack of flexibility 

as a key concern. In particular, these officials indicated that because their 

special education teachers often teach multiple subjects, they would have 

to attain multiple degrees or pass several subject matter tests to meet the 

subject matter competency requirement. Recent Education guidance 

issued after this survey was concluded gives states more time to help all 

teachers, including special education teachers who teach core academic 

subjects, in small, rural school districts, meet the requirements. Under this 

new guidance, teachers in eligible rural school districts, who are highly 

qualified in at least one subject, will have 3 years to become highly 

qualified in the additional subjects they teach. 

State officials reported concerns about their states’ ability to meet the 

federal timelines for implementing the NCLBA teacher requirements for 

special education teachers. Officials from 32 states reported that the time 

frames were not feasible for implementing the requirements. This included 

15 states that had established subject matter competency requirements for 

their special education certification. However, depending on the specific 

state certification requirements, teachers in these states may still be 

required to do additional work to meet the subject matter competency 
Page 15 GAO-04-659 Special Education 

requirements of NCLBA. In addition, some state officials reported that 

their states were not positioned to meet federal deadlines because some 

institutions of higher education had not aligned their programs with 

NCLBA requirements. For example, officials in 31 states reported that that 

current special education teacher preparation programs hindered 

implementation of NCLBA requirements, primarily because these 

programs did not emphasize majors or concentrations in core academic 

subjects. Given these conditions, state officials, in 3 of the 6 states we 

visited, reported the need for additional assistance in identifying strategies 

to meet the timelines for meeting requirements. Education also noted that 

the challenge facing states is developing new mechanisms to make sure 

that all teachers of core academic subjects are able to demonstrate 

appropriate subject matter mastery. 

Some state officials and national education organizations’ leaders also 

cited concerns that special education teachers currently teaching might 

leave the field rather than take exams or return to school to take the 

courses needed to demonstrate subject matter competency. Thirty-two 

survey respondents expressed concern that the potential flight of special 

education teachers would hinder efforts to implement the requirements. 

Finally, state education officials reported uncertainty over how to 

reconcile requirements of the two laws that appear to be inconsistent and 

thus could impede implementation of NCLBA. These officials reported 

that they were unsure as to which act—IDEA or NCLBA—should take 

precedence in establishing personnel requirements for special education 

teachers. For example, under IDEA, a student’s IEP could require that he 

be taught mathematics at a functional level 3 years below his 

chronological age, and under IDEA a certified special education teacher 

would be qualified to provide this instruction. However, under NCLBA, a 

teacher might not be qualified to instruct this student without first 

demonstrating subject matter competency in mathematics. According to 

Education officials, the requirements would depend in part on the 

assessment level of the students being taught. At the same time, Education 

officials noted that NCLBA teacher requirements apply to all teachers, 

including special education teachers. As a result of this uncertainty, some 

of the state special education officials we interviewed and surveyed said 

that they had decided to wait for further guidance or assistance before 

beginning to implement any NCLBA requirements for special education 

teachers. Education officials reported that they were aware that some 

states had expressed uncertainty about how to implement NCLBA’s 

teacher requirements. Moreover, Education officials noted that states that 

wait for further guidance could hinder their special education teachers’ 
Page 16 GAO-04-659 Special Education 

ability to meet the subject matter competency requirements by the end of 

the 2005-2006 school year. 

Education has provided a range of assistance, such as site visits, Webbased guidance, and financial assistance, to help states implement the 

highly qualified teacher requirements. However, department coordination 

related to the implementation of NCLBA’s teacher requirements for special 

education teachers has been limited. OESE has taken the lead in providing 

this guidance, with support from offices such as the Office of General 

Counsel and the Office of the Secretary. OSEP played a limited role in 

these efforts. Further, departmental coordination among Education’s 

offices was limited with respect to OSEP’s involvement in other key 

teacher quality initiatives. Because of this, Education may not have been in 

a position to be fully apprised of how special education concerns could 

affect implementation of the NCLBA teacher requirements. However, 

Education officials told us that they included OSEP by contacting OSEP 

staff to clarify IDEA substantive issues. Further, Education officials told us 

they have recently added OSEP to the department’s teacher quality policy 

team. However, Education currently does not have plans to develop 

written policies and procedures for coordination among its offices. 

According to Education officials, OESE took the lead in providing 

assistance to states concerning the NCLBA teacher requirements, with 

some support provided by offices including OSEP, the Office of the 

Secretary, the Office of the Undersecretary, the Assistant Secretary of 

Elementary and Secondary Education, and the Office of General Counsel. 

One of OESE’s key efforts to provide technical assistance to states was the 

Teacher Assistance Corps initiative, which sent teams of experts to states 

to provide clarification and guidance on implementing NCLBA teacher 

requirements. According to Education, these teams have been responsible 

for sharing promising strategies, providing advice on compliance issues, 

and assisting state officials in setting and meeting teacher quality goals. 

The teams have also gathered feedback from states on their concerns 

about implementing the teacher requirements. Team members have 

included lead officials from OESE and general counsel, individuals with 

expertise on issues of concern to particular states, higher education 

representatives, and education officials from that state. Education officials 

told us that OSEP staff did not participate in these visits, but two state 

officials with expertise in special education participated in some visits. 

Coordination among 

Education’s Offices 

Responsible for 

Educating Students 

with Disabilities Was 

Limited 

Education Provided 

Assistance to States in 

Implementing the NCLBA 

Teacher Requirements 
Page 17 GAO-04-659 Special Education 

OESE also offered states other types of assistance. OESE created a 

teacher quality newsletter, and the Office of the Under Secretary created 

and then updated the No Child Left Behind Toolkit for Teachers booklet, 

to help teachers understand the law in general, the highly qualified teacher 

requirements, and to explain which teachers need to meet the NCLBA 

requirements. However, while the tool kit provided detailed information 

pertaining to general education teachers, it provided limited information 

for special education teachers. According to OESE officials, the office had 

also been developing a Web site on promising practices for implementing 

the NCLBA teacher quality requirements and had plans to feature special 

education on the site. However, at the time of our interviews, OESE did 

not have a timeline for when this Web site would be available. Finally, 

OESE also provided financial assistance to states through Improving 

Teacher Quality state grants; states could use this financial assistance to 

help special education teachers meet NCLBA teacher requirements. 

The enactment of NCLBA significantly changed the expectations for all 

students and their teachers in the nation’s schools and increased the need 

for OESE and OSEP to coordinate their efforts. NCLBA covers to a greater 

extent than did previous educational legislation the groups that have 

historically been the primary responsibility of OSEP—students with 

disabilities and their teachers. Moreover, NCLBA established qualifications 

for all teachers, including special education teachers, who provide 

instruction in core academic subjects such as English, language arts, 

mathematics, and science. 

As state education officials began implementing NCLBA subject matter 

competency requirements, they sought guidance from OSEP, their primary 

source of information on special education issues. However, OSEP 

officials told us that they had generally referred these officials to OESE or 

to the NCLBA Web site. OSEP officials told us that they were waiting until 

IDEA is reauthorized to develop their own guidance on special education 

teacher quality requirements. However, during this time NCLBA 

requirements applied to special educators teaching core academic 

subjects, and several state officials told us they needed clarification of the 

guidance on these requirements. 

Coordination between OSEP and OESE has generally been limited. For 

example, OSEP commented on the teacher quality policies and initiatives 

that OESE developed, but generally was not involved in the initial 

development of these policies. Education officials told us that OSEP was 

included in the implementation of the teacher requirements, noting that 

Education’s Internal 

Coordination on Special 

Education Teacher 

Qualification Issues Was 

Limited 
Page 18 GAO-04-659 Special Education 

they contacted this office to clarify IDEA substantive issues and that OSEP 

officials reviewed NCLBA guidance. OSEP did not participate in OESE’s 

Teacher Assistance Corps visits to states and generally was not involved in 

the analysis of the information that was collected from these visits. OESE 

officials told us that they did not believe that states would benefit from 

OSEP’s participation in these visits, because the focus of the visits was on 

meeting the NCLBA requirements, not IDEA requirements. In addition, 

Education told us that there were no written policies or procedures to 

assist OESE and OSEP in coordinating the development and 

implementation of its teacher quality policies for special education 

teachers. Finally, these officials did not indicate that Education was 

planning to develop such policies. 

In March 2003, Education formed a teacher quality policy team under the 

auspices of the Office of the Under Secretary and included other key 

offices in Education such as the Office of the Secretary, the Office of 

General Counsel, and OESE. This team, run by OESE, has focused on 

NCLBA implementation related to teacher qualifications, and special 

education teacher issues have been among the topics most frequently 

discussed. OSEP was not a member of this team until April 2004, when 

Education officials told us that OSEP had become a part of the team. 

NCLBA is a complex law with new requirements that hold states, districts, 

and schools accountable for ensuring that their teachers meet specific 

qualifications. Further, the law applies to all teachers, including special 

education teachers, resulting in states and districts having to reassess how 

they certify and assign special education teachers, as well as provide 

professional development geared toward helping teachers meet 

requirements. 

State officials reported the need for assistance on how to meet NCLBA 

requirements, with Education also noting the need for states to have more 

information on strategies to meet requirements. Because half of the states 

do not have subject matter competency requirements as part of special 

education certification, these states in particular are challenged with 

developing strategies to help their teachers meet NCLBA requirements. 

Without additional assistance on such strategies, special education 

teachers may not be positioned to meet requirements by the end of 2005-

2006 school year. In addition, several state education officials cited the 

need for additional clarification on the application of the NCLBA subject 

matter competency requirement to special education teachers in special 

circumstances, for example those providing instruction to high school age 

Conclusions 
Page 19 GAO-04-659 Special Education 

students who are performing at the elementary level. Without additional 

assistance from Education to resolve state concerns related to special 

education teacher qualification issues, some states might not be able to 

determine how to focus their resources to ensure that their teachers meet 

the act’s requirements. 

NCLBA covers to a greater extent than did previous elementary and 

secondary education acts the groups that have historically been the 

primary responsibility of OSEP—students with disabilities and their 

teachers. OESE has assumed primary responsibility for implementing 

NCLBA, including provisions applying to special education teachers. 

OESE has generally not relied on OSEP staff or information produced by 

OSEP to develop policy or guidance. Consequently, OESE may not have 

fully benefited from OSEP’s expertise to inform its NCLBA discussions on 

policies and guidance related to special education teacher issues and 

requirements. Although Education has recently added OSEP to its NCLBA 

teacher quality policy team, overall NCLBA coordination efforts among 

Education offices have not been formalized in writing to ensure 

appropriate and continuing involvement of these offices. As a result, the 

department may not fully address states’ needs for information and 

assistance on the implementation of NCLBA requirements for special 

education teachers. 

To better address states’ concerns about their special education teachers 

being positioned to meet NCLBA teacher requirements, we recommend 

that the Secretary of Education provide additional assistance to states on 

strategies to meet the requirements and clarification of subject matter 

competency requirements for special education teachers. 

To continue to improve policy development and technical assistance that 

Education’s offices provide to states on NCLBA requirements, we 

recommend that Education formalize in writing coordination efforts 

between OESE and OSEP. For example, such efforts could include 

defining how OSEP’s expertise and staff would be involved in developing 

NCLBA policies and guidance related to special education teachers and in 

providing technical assistance to states. 

We provided a draft of this report to Education for review and comment. 

In their comments, Education officials noted that they believed their 

guidance was clear but recognized that states were still struggling to 

identify strategies to meet requirements. Education officials provided new 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 20 GAO-04-659 Special Education 

information in their comments on the draft that indicated improved 

coordination among those Education offices that are involved in NCLBA 

policy development and guidance. Consequently, we modified the report 

on both these topics to reflect Educations’ comments. Education officials 

also provided technical comments that we incorporated into the report 

where appropriate. Education’s comments are reproduced in appendix II. 

Given the difficulties states are experiencing in implementing the law and 

the level of uncertainty reported by state officials, we believe that 

additional assistance needs to be provided by Education to help states 

implement the requirements. In Education’s comments, the department 

noted that states were having difficulty implementing NCLBA teacher 

requirements. Education officials highlighted assistance they provided and 

their willingness to provide additional technical assistance, depending on 

what states need. We believe Education could help states by identifying 

strategies to help states meet requirements, especially those states without 

subject matter competency requirements for their special education 

teachers. In addition, Education noted in its comments that guidance on 

how to apply the NCLBA subject matter competency requirement for 

special education teachers instructing high school age students 

functioning at elementary school levels was not different from guidance 

for all teachers. However, Education officials have also said that the 

assessment level of a student could be considered in determining how to 

apply the NCLBA teacher requirements. We encourage Education to 

provide assistance to explain the requirements, particularly as they relate 

to unusual circumstances involving varying student assessment levels. We 

have modified the report to reflect Education’s comments. 

We continue to believe that improved coordination is needed. However, 

we modified the report to reflect Education’s recent addition of OSEP to 

its teacher quality policy team. We acknowledge Education’s effort in this 

regard and encourage the department to formalize its coordination 

policies by putting them in writing. We believe that formalizing 

coordination efforts will ensure that the different offices continue to be 

involved in developing NCLBA policies and guidance related to special 

education teachers. 

Copies of this report are being sent to the Secretary of Education, relevant 

congressional committees, and other interested parties. We will also make 

copies available to others upon request. In addition, the report will be 

made available at no charge on GAO’s Web site at http://www.gao.gov. 
Page 21 GAO-04-659 Special Education 

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

questions about this report. Other contacts and major contributors are 

listed in appendix III. 

Sincerely yours, 

Marnie S. Shaul 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 

Page 22 GAO-04-659 Special Education 

State 

State alternative route to certification in special 

education contact information 

Alabama Director 

Teacher Education and Certification 

Alabama Department of Education 

Post Office Box 302101 

Montgomery, AL 36104 

Phone: (334) 242-9560 

Fax: (334) 242-0498 

Web site: www.alsde.edu 

Arizona Deputy Associate Superintendent for Highly Qualified 

Professionals 

AZ Department of Education 

1535 W. Jefferson Street 

Phoenix, AZ 85007-6490 

Phone: (602) 364-2294 

Fax: (602) 542-1411 

Web site: www.ade.az.gov/certification 

California California Commission on Teacher Credentialing 

1900 Capitol Avenue 

Sacramento, CA 95814 

Phone: (916) 327-8663 

Fax: (916) 324-8927 

Web site: www.ctc.ca.gov 

Colorado Director 

Colorado Department of Education 

201 E. Colfax Avenue, Room 201 

Denver, CO 80203 

Phone: (303) 866-6932 

Fax: (303) 866-6968 

Web site: www.cde.state.co.us 

Georgia Director 

Educator Preparation 

Professional Standards Commission 

Two Peachtree, Suite 6000 

Atlanta, GA 30303 

Phone: (404) 232-2640 

Fax: (404) 232-2760 

Web site: gapsc.com 

Hawaii Hawaii Teacher Standards Board 

650 Iwilei Road, Suite 201 

Honolulu, HI 96817 

Phone: (808) 586-2617 

Fax: (808) 585-2606 

Web site: www.htsb.org 

Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 
Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 

Page 23 GAO-04-659 Special Education 

State 

State alternative route to certification in special 

education contact information 

Kentucky Director 

Division of Professional Learning and Assessment 

Education Professional Standards Board 

100 Airport Road 

Third Floor 

Frankfort, KY 40601 

Phone: (502) 564-4606 

Fax: (502) 564-9484 

Web site: www.kyepsb.net 

Louisiana Director of Teacher Certification and Higher Education 

Louisiana Department of Education 

1201 North Third Street 

Baton Rouge, LA 70802 

Phone: (225) 342-3562 

Fax: (225) 342-7367 

Web site: http://www/lde/index.html 

Maine Education Policy Director 

Maine Department of Education 

23 State House Station 

Augusta, ME 04333 

Phone: (207) 624-6603 

Fax: (207) 624-6604 

Web site: www.state.me.us/education 

Maryland Director of Quality Teaching 

Maryland State Department of Education 

200 West Baltimore St. 

Baltimore, MD 21201-2595 

Phone: (410) 767-0390 

Fax: (410) 333-8963 

Web site: marylandpublicschools.org/ 

Massachusetts Title II Accountability Team Leader 

Department of Education, Educator Preparation 

350 Main Street 

5th Floor 

Malden, MA 02148 

Phone: (781) 338-3270 

Fax: (781) 338-3396 

Web site: www.doe.mass.edu 

Michigan Higher Education Coordinator 

Michigan Department of Education (MDE) 

John A. Hannah Building, 608 West Allegan Street, Lansing, 

MI 48933 

Or P.O. Box 30008 

Lansing, MI 48909 

Phone: (517) 373-1925 

Fax: (517) 373-0542 

Web site: http://www.michigan.gov/mde 
Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 

Page 24 GAO-04-659 Special Education 

State 

State alternative route to certification in special 

education contact information 

Mississippi Director 

Office of Educator Licensure 

Mississippi Department of Education 

P. O. Box 771 

Jackson, MS 39205-0771 

Phone: (601) 359-3483 

Fax: (601) 359-2778 

Web site: www.mde.k12.ms.us/license/ 

Missouri Assistant Director 

Educator Preparation 

Department Elementary and Secondary Education 

PO Box 480 

Jefferson City, MO 65102 

Phone: (573) 522-2544 

Fax: (573) 526-3580 

Web site: http://dese.mo.gov/ 

Nevada Administrator 

Nevada Department of Education 

Office of Teacher Education and Licensure 

1820 E. Sahara Ave. Suite 205 

Las Vegas, NV 89104-3721 

Phone: (702) 486-6496 

Fax: (702) 486-6474 

Web site: www.nde.state.nv.us 

New Hampshire Administrator 

Bureau of Credentialing 

Division of Program Support 

New Hampshire Department of Education 

101 Pleasant Street 

Concord, NH 03801 

Phone: (603) 271-4196 

Fax: (603) 271-8709 

Web site: ed.state.nh.us 

New Mexico Director of Professional Licensure 

New Mexico State Dept. of Education 

Education Building, 300 Don Gaspar 

Santa Fe, NM 87501-2786 

Phone: (505) 827-6581 

Fax: (505) 827-4148 

Web site: sde.state.nm.us/divisions/ais/licensure/index.html 

New York Executive Coordinator 

New York State Education Department 

Office of Teaching Initiatives 

89 Washington Avenue - Room 5N EB 

Albany, NY 12234 

Phone: (518) 474-4661 

Fax: (518) 473-0271 

Web site: http://www.nysed.gov/tcert 
Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 

Page 25 GAO-04-659 Special Education 

State 

State alternative route to certification in special 

education contact information 

North Carolina Director 

Division of Human Resource Management 

NC Department of Public Instruction 

Mail Service Center 6330 

Raleigh, NC 27699-6330 

Phone: (919) 807-3355 

Fax: (919) 807-3362 

Web site: www.ncpublicschools.org 

Ohio Office of Educator Preparation 

Ohio Department of Education 

25 S. Front St. 

MS502 

Columbus, OH 43215-4183 

Phone: (614) 752-9447 

Fax: (614) 728-3058 

Web site: www.ode.state.oh.us 

Oklahoma Director of Professional Services 

Oklahoma State Department of Education 

2500 North Lincoln Boulevard 

Oklahoma City, OK 73105-4599 

Phone: (405) 521-2062 

Fax: (405) 521-3744 

Web site: http://sde.state.ok.us 

Pennsylvania Chief 

Division of Teacher Education 

Pa. Dept. of Education 

333 Market Street 

Third Floor 

Harrisburg, PA 17126 

Phone: (717) 783-9252 

Fax: (717) 783-6736 

Web site: www.teaching.state.pa.us 

South Carolina Title II Coordinator 

South Carolina Department of Education 

3700 Forest Drive 

Columbia, SC 29204 

Phone: (803) 734-8944 

Fax: (803) 734-0872 

Web site: http://www.scteachers.org/ 

South Dakota Director of Teacher Education and Certification 

Department of Education 

700 Governors Drive 

Pierre, SD 57501-2291 

Phone: (605) 773-4774 

Fax: (605) 773-6139 

Web site: www.state.sd.us/deca/account/certif.htm 
Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 

Page 26 GAO-04-659 Special Education 

State 

State alternative route to certification in special 

education contact information 

Tennessee Director 

Office of Teacher Licensing 

Tennessee State Department of Education 

5th Floor, Andrew Johnson Tower 

710 James Robertson Parkway 

Nashville, TN 37243-0377 

Phone: (615) 532-4880 

Fax: (615) 532-1448 

Web site: http://www.tennessee.gov/education/lic_home.htm 

Texas Program Administrator 

State Board for Educator Certification 

4616 W. Howard Lane 

Suite 120 

Austin, TX 78728 

Phone: (512) 238-3200 

Fax: (512) 238-3203 

Web site: www.sbec.state.tx.us 

Utah Utah State Office of Education 

250 East 500 South 

P.O. Box 144200 

Salt Lake City, UT 84114-4200 

Phone: (801) 538-7739 

Fax: (801) 538-7973 

Web site: www.usoe.org 

Vermont Director for Educator Quality 

Vermont Department of Education 

120 State Street 

Montpelier, VT 05620 

Phone: (802) 828-3850 

Fax: (802) 828-5107 

Web site: http://www.state.vt.us/educ 

Virginia Director of Teacher Education 

Virginia Department of Education 

P.O. Box 2120 

Richmond, VA 23218-2120 

Phone: (804) 692-0251 

Fax: (804) 786-6759 

Web site: www.pen.k12.va.us 

West Virginia Teacher Preparation Coordinator 

West Virginia Department of Education 

Building 6, Room 252 

1900 Kanawha Blvd. East 

Charleston, WV 25305-0330 

Phone: (304) 558-2703 

Fax: (304) 558-7843 

Web site: http://wvde.state.wv.us/ 
Appendix I: Thirty-One States with 

Alternative Routes to Certification in Special 

Education during the 2002-2003 School Year 

Page 27 GAO-04-659 Special Education 

State 

State alternative route to certification in special 

education contact information 

Wyoming Director 

Professional Teaching Standards Board 

1920 Thomes Ave. 

Suite 400 

Cheyenne, WY 82002 

Phone: (307) 777-6261 

Fax: (307) 777-8718 

Web site: www.k12.wy.us/ptsb 

Source: GAO analysis of survey responses from the special education directors in the 50 states, the District of Columbia, and Puerto 

Rico, and state 2003 Title II reports. 
Appendix II: Comments from the Department 

of Education 

Page 28 GAO-04-659 Special Education 

Appendix II: Comments from the Department 

of Education 
Appendix II: Comments from the Department 

of Education 

Page 29 GAO-04-659 Special Education 
Appendix II: Comments from the Department 

of Education 

Page 30 GAO-04-659 Special Education 
Appendix II: Comments from the Department 

of Education 

Page 31 GAO-04-659 Special Education 
Appendix II: Comments from the Department 

of Education 

Page 32 GAO-04-659 Special Education 
Appendix III: GAO Contacts and Staff 

Acknowledgments 

Page 33 GAO-04-659 Special Education 

Harriet C. Ganson, (202) 512-7042, gansonh@gao.gov 

Arthur T. Merriam Jr., (617) 788-0541, merriama@gao.gov 

In addition to those named above, Emily Leventhal, Benjamin Howe, 

Ron La Due Lake, Luann Moy, Jean McSween, Bob DeRoy, Bryon Gordon, 

Behn Kelly, and Amy Buck made key contributions to the report. 

Appendix III: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(130286) 
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