SPECIAL 

EDUCATION

State and LocalImposed 

Requirements 

Complicate Federal 

Efforts to Reduce 

Administrative Burden

Report to Congressional Requesters

GAO-16-25

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-25, a report to 

congressional requesters

January 2016

SPECIAL EDUCATION

State and Local-Imposed Requirements Complicate

Federal Efforts to Reduce Administrative Burden

Why GAO Did This Study

When IDEA was reauthorized in 2004, 

it included provisions to reduce 

administrative and paperwork 

requirements to address concerns 

about burden. GAO was asked to 

review federal efforts to reduce burden 

related to meeting IDEA requirements 

for educating children with disabilities. 

Congress provided about $11.5 billion 

in grants in fiscal year 2015 under 

IDEA Part B to help states and local 

districts defray the costs of special 

education services for nearly 6.6 

million students ages 3 to 21. 

This report examines (1) what 

Education and states have done to 

implement selected IDEA provisions 

intended to reduce burden, (2) 

stakeholder views about IDEA’s 

administrative and paperwork 

requirements, and (3) steps that 

Education and others have taken to 

minimize IDEA-related burden.

GAO reviewed relevant federal laws 

and regulations; held nongeneralizable 

focus groups with state and local 

administrators and educators from 37

states; visited schools in Clinton, 

Arkansas and Rochester, New York; 

and interviewed officials from 

Education and stakeholder 

organizations. GAO selected focus 

group participants, site visit locations, 

and organizations to highlight a range 

of demographic and geographic 

characteristics and obtain perspectives 

from a variety of stakeholders.

What GAO Recommends

GAO is not making any 

recommendations at this time. 

What GAO Found

In response to the 2004 reauthorization of the Individuals with Disabilities 

Education Act (IDEA)—the primary federal law governing education of children 

with disabilities—the Department of Education (Education) attempted to reduce 

administrative burden by creating pilot programs and publishing model 

paperwork forms, but states have used these tools sparingly. Specifically, 

Education created pilot programs allowing states to use multi-year rather than 

annual individualized education programs (IEP) to describe services to meet 

each student’s needs, and to waive certain federal paperwork requirements. 

However, no state applied for these pilots, citing a perceived lack of benefit, and 

inadequate funding to implement and evaluate the pilots. As required by law, 

Education also published templates, known as model forms, to help states 

streamline the process of preparing IEPs and comply with parent notice 

requirements in IDEA. Although some states and school districts adopted at least 

one of these model forms, they have used others primarily as a starting point to 

develop their own forms. State and district officials told GAO this allowed them to 

meet federal as well as state and local requirements, and provided better 

protection against potential litigation. Stakeholders were mixed in their views 

about the effects of other provisions intended to reduce administrative burden. 

For example, several stakeholders viewed a provision allowing states to use 

more grant funds for paperwork reduction activities as helpful; others said the 

effect of a provision eliminating benchmarks and short-term objectives for IEPs 

was largely negligible.

Stakeholders across 9 focus groups—3 each with state administrators, local 

administrators, and educators—said that state-imposed requirements contribute 

to the administrative and paperwork burden, but their views on the burdens and 

benefits of federal IDEA requirements varied somewhat. For example, in focus 

groups, educators expressed concerns about monitoring and documenting 

student progress, while local and state administrators expressed concerns, 

respectively, about IEP implementation and federal reporting requirements. 

Consistent with prior research, many educators in these focus groups estimated 

they spend roughly one to two hours daily on administrative tasks, and 

expressed concern about this taking time away from the classroom. Despite 

perceived burdens, stakeholders widely acknowledged that IDEA’s requirements 

play an important role in accountability. For example, educators said the 

requirements provide information about student strengths and limitations that 

help them assist the student, while state administrators said requirements aid 

planning and program development. 

Education, states, and school districts have reduced administrative burdens by 

adopting new technology and using certain resource strategies. For example, 

several state administrators said Education’s electronic data submission system 

has made it easier to complete federally-required state performance plans. 

During fall 2014, Education launched a new electronic reporting system intended 

to, among other things, consolidate data collections and ease data entry. Some 

schools and districts have also adopted resource strategies, such as hiring data 

clerks to reduce administrative burdens, but these strategies can be costly.

View GAO-16-25. For more information, 

contact Jacqueline M. Nowicki at (617) 788-

0580 or nowickij@gao.gov.
Page i GAO-16-25 Special Education

Letter 1

Background 4

Education Has Implemented Provisions of IDEA Designed to 

Reduce Paperwork, but States Have Been Reluctant to Use 

Them 9

Stakeholders Said Additional State and Local Requirements 

Contribute to Burden, but Differed on the Burdens and Benefits 

of Federal Requirements 14

Education and States Stated that They Have Adopted Computer 

Technology and Other Steps that Reduce Administrative 

Burdens, but These Efforts Have Limitations 21

Despite Benefits, Existing Technology Reportedly Has Limitations 

in Addressing Burdens 23

Appendix I Objectives, Scope, and Methodology 26

Appendix II Comments from the U.S. Department of Education 31

Appendix III GAO Contact and Staff Acknowledgments 32

Tables

Table 1: Administrative Tasks Perceived to Be Particularly 

Burdensome under the Individuals with Disabilities 

Education Act (IDEA), as Cited in GAO Focus Groups 16

Table 2: Types of Burdens Associated with Administrative Tasks 

under the Individuals with Disabilities Education Act 

(IDEA), as Identified by GAO Focus Group Participants 17

Table 3: Perceived Benefits of Administrative Tasks and 

Paperwork under the Individuals with Disabilities 

Education Act (IDEA), as Cited in GAO Focus Groups 18

Contents
Page ii GAO-16-25 Special Education

Abbreviations

CEC Council for Exceptional Children

Education Department of Education

IDEA Individuals with Disabilities Education Act

IEP Individualized education program

LEA Local educational agency

NASDSE National Association of State Directors of Special 

Education, Inc.

NASSP National Association of Secondary School 

Principals

OMB Office of Management and Budget

OSEP Office of Special Education Programs

PRA Paperwork Reduction Act 

SEA State educational agency

SPeNSE Study of Personnel Needs in Special Education

SPP/APR State Performance Plan/Annual Performance 

Report

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Page 1 GAO-16-25 Special Education

441 G St. N.W.

Washington, DC 20548

January 8, 2016

The Honorable John Kline

Chairman

Committee on Education and the Workforce

House of Representatives

The Honorable Todd Rokita

Chairman

Subcommittee on Early Childhood,

Elementary and Secondary Education

Committee on Education and the Workforce

House of Representatives

The Individuals with Disabilities Education Act (IDEA), the primary federal 

law authorizing federal funding for special education and related services, 

is designed to ensure that eligible students with disabilities have available

a free appropriate public education, as well as to give parents a role in 

their children’s education. In fiscal year 2015, an estimated 6.6 million 

students ages 3 through 21 received special education services through a 

combination of federal, state, and local funding, according to Department 

of Education (Education) data.1 Under IDEA Part B,2 the federal 

government contributed $11.5 billion that same year to help defray the 

excess costs of educating these students. Administered at the federal 

level by Education’s Office of Special Education Programs (OSEP) in the 

Office of Special Education and Rehabilitative Services, IDEA has been 

reauthorized several times since its enactment in 1975, most recently in 

2004. Prior to the 2004 reauthorization, organizations representing state 

and local administrators, educators, disability education advocates, and 

parents expressed concerns that resources were being directed away 

from classrooms in order to meet paperwork and other IDEA 

requirements that were not directly related to improving education 

outcomes for children. To address these concerns, Congress added 

several provisions in the 2004 reauthorization intended to help reduce 

 1

U.S. Department of Education estimate, based on the state-reported cumulative totals for 

students served in the fall of 2013 and 2014. 

2

20 U.S.C. §§ 1411-1419.

Letter
Page 2 GAO-16-25 Special Education

administrative tasks and paperwork associated with special education 

programs. Among other things, the provisions included a pilot under 

which Education could waive statutory or regulatory requirements under 

IDEA Part B for up to 4 years for up to 15 states.3 The provisions also 

included a requirement for Education to provide templates, known as 

“model forms,” for states and local educational agencies (LEAs) to use in 

documenting various administrative requirements in the special education 

process.4 You asked us to review federal efforts to reduce the burden 

associated with IDEA administrative and paperwork requirements.

This report examines (1) what Education and states have done to 

implement selected provisions of the law to help minimize the burden 

associated with administrative and paperwork requirements under IDEA, 

(2) stakeholder views about IDEA’s administrative and paperwork 

requirements, and (3) the steps Education and others have taken to 

minimize IDEA-related burden.

To address our first objective, we reviewed relevant laws, regulations, 

and published studies. We also interviewed officials from Education, and 

from organizations representing education stakeholder groups, including 

state and local education administrators, parents of students with 

disabilities, and educators. To address our second objective, we 

conducted 9 focus group discussions—3 with state administrators from 18 

states, 3 with local administrators from 14 states, and 3 with educators 

from 15 states. Overall, participants came from 37 separate states and, 

though not generalizable, their views represent a broad range of 

experiences from across all regions of the country and all types of school 

districts. To identify potential participants for our focus groups, we worked 

with the National Association of State Directors of Special Education, Inc., 

the Council of Administrators of Special Education, the National 

Education Association, and other organizations representing special 

education stakeholders. To select focus group participants, we extended 

invitations to potential participants to maximize diversity in the following 

areas: the state in which they were employed, type of position, years of 

experience, and type of school district (rural or urban).

 3

Pub. L. No. 108-446, § 609(a)(2)(A), 118 Stat. 2647, 2661 (2004), codified at 20 U.S.C. § 

1408(a)(2)(A). 

4

Pub. L. No. 108-446, § 617(e), 118 Stat. 2647, 2738 (2004), codified at 20 U.S.C. 

§ 1417(e).
Page 3 GAO-16-25 Special Education

We also completed site visits in Clinton, Arkansas and Rochester, New 

York. We selected these two school districts to highlight different 

experiences in how urban and rural school districts manage 

administrative requirements. These site visits provided opportunities to 

understand and document local efforts to manage administrative 

requirements, and to speak with parents about how they perceive special 

education procedures, although the views of the parents with whom we 

met are not generalizable. At each location, we met with parents whose 

children were receiving special education services. Parents were 

informed of the opportunity to attend these meetings by the local districts, 

and attendance was voluntary. The site visits allowed us to explore how 

differences in state and local requirements may contribute to differences 

in perceptions of the relative benefits and challenges associated with 

meeting key federal requirements.

To address our third objective, we spoke with Education officials about 

the agency’s efforts to minimize the burden associated with selected 

administrative and paperwork requirements under IDEA. We also spoke 

with state and local officials in New York and Arkansas, and included a 

question about efforts to minimize burden in our focus group 

discussions.5 Finally, we discussed this topic with educators and officials 

from organizations representing state and local administrators of special 

education programs, as well as officials from organizations representing 

parents of students with disabilities. We selected these organizations to 

provide a range of views on the benefits and burdens of IDEA 

requirements.

We conducted this performance audit from August 2014 to January 2016 

in accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 5

We did not conduct a legal analysis of state special education requirements. 
Page 4 GAO-16-25 Special Education

IDEA Part B authorizes federal grants to states to help them meet the 

excess costs of providing special education and related services to 

students with disabilities. There are a number of conditions that states 

must meet to be eligible for funding. In particular, states must agree to 

make available a free appropriate public education to all students with 

disabilities beginning at the age of 3 and possibly lasting to the 22nd

birthday depending on state law or practice, in the least restrictive 

environment—meaning, to the maximum extent appropriate, these 

children are educated with other children who do not have disabilities.6 To 

accomplish this, states and LEAs must first identify, locate, and evaluate 

students who are eligible for special education services, regardless of the 

severity of their disability.

7 For those deemed eligible, the state and LEA 

must ensure that each student has an individualized education program 

(IEP) describing their present levels of academic achievement and 

functional performance; measurable annual goals, including academic 

and functional goals; special education and related services; 

supplementary aids and services; and other supports to enable the child 

to advance appropriately toward attaining those goals.8 The IEP is 

developed by a team of teachers, parents, school district representatives, 

and other educational professionals. This team must meet to develop the 

initial IEP within 30 days of determining that a student needs special 

education and related services, and must review the IEP periodically, but 

not less than annually, to determine whether the annual goals have been 

achieved, and revise the IEP, as appropriate.9

To qualify for IDEA funding, states must also provide certain procedural 

safeguards to children and their parents. For example, these safeguards 

require that parents be provided with prior written notice a reasonable 

time before the LEA proposes or refuses to initiate or change the 

identification, evaluation, or educational placement of the child, or the 

 6

20 U.S.C. § 1412(a)(1), (5). Free appropriate public education means special education 

and related services that (a) are provided at public expense, under public supervision and 

direction, and without charge; (b) meet the standards of the state educational agency; (c) 

include an appropriate preschool, elementary school, or secondary school education in 

the state involved; and (d) are provided in conformity with the individualized education 

program (IEP) requirements of the IDEA. 20 U.S.C. § 1401(9). 

7

20 U.S.C. § 1412(a)(3)(A). 

8

20 U.S.C. §§ 1412(a)(4), 1414(d). 

9

34 C.F.R. §§ 300.323(c)(1), 300.324(b)(1)(i). 

Background
Page 5 GAO-16-25 Special Education

provision of a free appropriate public education to the child.10 IDEA also 

affords parents the right to request a due process hearing,11 as well as 

the right to bring a civil action in a state or federal district court.12 States 

must ensure that any state rules, regulations, and policies related to IDEA 

conform to the purposes of IDEA, and are required to identify in writing to 

Education and their LEAs any state-imposed requirement that is not 

required by IDEA.13

The 2004 reauthorization of IDEA included several provisions that were 

intended to help reduce administrative tasks and paperwork associated 

with documenting compliance with the law.14 Specifically, the law:

• Created two pilot programs: the Paperwork Waiver Demonstration 

Program (Paperwork Waiver Program), and the Multi-Year IEP 

Demonstration Program (Multi-Year IEP Program). Under the 

Paperwork Waiver Program, Education could waive statutory or 

regulatory requirements that states must comply with in order to 

receive funding under Part B for up to 4 years, for up to 15 states.15

The Multi-Year IEP Program authorized Education to allow up to 15 

states to give parents and LEAs the option of developing a 

 1020 U.S.C. § 1415(b)(3). 

1120 U.S.C. § 1415(f). 

1220 U.S.C. § 1415(i)(2). More specifically, IDEA affords parents who are aggrieved by a 

final decision in a due process hearing or a final decision in an appeal of a hearing 

decision, if applicable, the right to bring a civil action in a state court of competent 

jurisdiction or in a district court of the United States, without regard to the amount in 

controversy.

1320 U.S.C. § 1407(a)(1), (2). 

14In 2003, the House Committee on Education and the Workforce issued a report 

accompanying the House IDEA reauthorization bill (H.R. 1350) which stated that reducing 

paperwork burden was one of the central reform principles of the House reauthorization 

bill. H.R. Rep. No. 108-77, at 83 (2003). 

1520 U.S.C. § 1408(a)(2)(B) and (C)(ii). To qualify for the Paperwork Waiver Program, 

states needed to submit a proposal to reduce excessive paperwork and non-instructional 

time burdens that did not help improve educational and functional results for children with 

disabilities. States also needed to provide a list of federal statutory requirements the state 

wanted waived, as well as any state requirements the state planned on waiving. States 

could not request waivers for civil rights requirements or certain other procedural 

safeguards specified in Education’s regulations. 72 Fed. Reg. 36.970, 36.971. 
Page 6 GAO-16-25 Special Education

comprehensive IEP covering up to 3 years, rather than developing 

yearly IEPs, as currently required.16

• Required that Education publish and disseminate model forms, 

including forms for documenting IEPs, providing prior written notice, 

and providing procedural safeguards notice.17

• Introduced various administrative changes, including raising the 

amount of federal grant funds that states may set aside for 

administration and other state-level activities, and permitting states to 

use these funds for paperwork reduction, among other things;18

eliminating the requirement for benchmarks and short-term objectives 

in IEPs,19 and requiring that states identify in writing to LEAs and 

Education any state requirements that are not mandated by IDEA, 

and that they minimize requirements that LEAs and schools are 

subject to under IDEA.20

IDEA requires states to have a mechanism for interagency coordination 

between the state educational agency (SEA) and any other state 

agencies that provide or pay for any services that are considered special 

education or related services.21 For example, since 1988, costs of some 

related services provided to low-income children under IDEA may be 

covered by Medicaid.22 In 1999, GAO reported that Medicaid 

documentation requirements are more burdensome than those of IDEA, 

 1620 U.S.C. § 1414(d)(5). 

1720 U.S.C. § 1417(e). 

1820 U.S.C. § 1411(e)(2)(C)(ii). 

19However, these still must be included for students who take alternate assessments 

aligned to alternate achievement standards, including students with the most significant 

cognitive disabilities. See 20 U.S.C. § 1414(d)(1)(A)(i)(I)(cc), 34 C.F.R § 300.160(c). 

2020 U.S.C. § 1407(a). 

2120 U.S.C. § 1412(a)(12). 

22In 1988, section 1903(c) of the Social Security Act was amended to permit Medicaid 

payment for certain medical services provided to Medicaid eligible children under IDEA. 

Medicare Catastrophic Coverage Act of 1988, Pub. L. No. 100-360, § 411(k)(13)(A), 102 

Stat. 683, 798, codified at 42 U.S.C. § 1396b(c). 
Page 7 GAO-16-25 Special Education

leading states to cite this as an area of concern in coordinating Medicaid 

and IDEA services.23

Following the 2004 reauthorization, there has been little public debate on 

the issue of paperwork and administrative burdens associated with IDEA.

In 2012, GAO reported information about the burden on states and school 

districts associated with federal education regulations and identified three 

IDEA requirements as being among the more burdensome: reporting 

IDEA performance indicators, IEP processing, and transitioning students 

into school-age programs from infant and toddler programs.24 We also

found that officials of states and school districts reported they generally 

did not collect information about the costs to comply with federal 

requirements, noting that states and school districts are not required to 

report compliance costs, the data are not useful to them, and collecting 

such data would in itself be burdensome. We recommended Education 

take additional steps to address duplicative reporting and data collection 

efforts across major programs. In addition, we recommended Education 

identify unnecessarily burdensome statutory requirements and develop 

legislative proposals to address these burdens, acknowledging that the 

agency’s ability to address burdens associated with some provisions of 

IDEA might be limited without statutory changes. Education agreed that it 

should take additional steps to address duplicative reporting and data 

collection efforts that are not statutorily required, and believed additional 

efficiencies could be achieved in its data collections.25 However, 

Education noted that some data elements are required under various 

program statutes and said it would work with Congress in the next 

 23GAO, Medicaid and Special Education: Coordination of Services for Children With 

Disabilities Is Evolving, GAO/HEHS-00-20 (Washington, D.C.: December 1999). 

24GAO, K-12 Education: Selected States and School Districts Cited Numerous Federal 

Requirements As Burdensome, While Recognizing Some Benefits, GAO-12-672 

(Washington, D.C.: June 2013). IDEA compliance indicators are data used by Education 

to help assess state compliance with IDEA.

25Education has subsequently reported taking steps to ensure that reporting and data 

collection requirements are consistent with its objectives and are not unduly burdensome. 

For example, Education revised its approach to collecting data for the Individuals with 

Disabilities Education Act Part B performance plan and report, resulting in a notable 

reduction in time spent to complete these documents. 
Page 8 GAO-16-25 Special Education

reauthorization of IDEA to address duplication or the appearance of 

duplication resulting from those requirements.26

Additionally, GAO has performed extensive work on the Paperwork 

Reduction Act (PRA), including the law’s effectiveness and approaches to 

reducing burden on the public. Under PRA, federal agencies are 

generally required to submit any proposed information collections to the 

Office of Management and Budget (OMB) for approval, including an 

estimate of the burden the information collections impose on the public.27

This submission certifies that the information collections meet the PRA 

standards that, among others, include taking steps to ensure the 

collection:

• avoids duplication,

• is necessary for agency performance, and

• minimizes burden on the public.

In response to PRA requirements, Education submits estimates of time 

needed to collect and report some IDEA related information, including 

state applications for IDEA funding, the State Performance Plan/Annual 

Performance Report, and SEA and LEA recordkeeping requirements. In 

our past work, we have noted potential discrepancies between 

Education’s estimates and reported burden as estimated by institutions of 

higher learning, making it difficult to know the actual burden imposed by 

these data collections.28

 26In response to this recommendation, Education proposed the consolidation of several 

programs, which may reduce burden. For example, Education proposed establishing the 

Successful, Safe, and Healthy Students program in order to consolidate three related 

programs. 

2744 U.S.C. § 3506(c). 

28GAO, Higher Education: Institutions’ Reported Data Collection Burden Is Higher Than 

Estimated but Can Be Reduced through Increased Coordination, GAO-10-871

(Washington, D.C.: August 2010). 
Page 9 GAO-16-25 Special Education

Education took several steps to design and implement two pilot programs, 

the Paperwork Waiver Program and Multi-Year IEP Program. To promote 

these pilot programs, Education conducted a national outreach tour to 

discuss the changes in the 2004 IDEA reauthorization and provide 

information about the pilot programs. In December 2005, Education also 

published notices of proposed requirements and selection criteria for both 

programs, and requested public comments by March 6, 2006.29 Education 

published the final requirements and selection criteria in July 2007,30 and 

made applications available to states in October 2007. Additionally, 

Education officials noted they held a teleconference for the state directors 

of special education describing the process for applying to participate in 

the pilot programs, which was also publicized through email and 

supported by the National Association of State Directors of Special 

Education, Inc. (NASDSE).31

Despite Education’s efforts, no state applied to participate in either of the 

pilot programs. NASDSE officials told us that the application requirements 

were much too resource-intensive for the potential value they would bring, 

and implementation of either pilot program would most likely require 

 2970 Fed. Reg. 75,158 (Dec. 19, 2005), 70 Fed. Reg. 75,161 (Dec. 19, 2005). 

3072 Fed. Reg. 36,970 (July 6, 2007), 72 Fed. Reg. 36,985 (July 6, 2007). 

31 NASDSE is a national membership organization comprised of state directors of special 

education from all states, the District of Columbia, the Department of Defense, which 

operates its own schools in some locations, and other jurisdictions that administer IDEA 

programs.

Education Has 

Implemented 

Provisions of IDEA 

Designed to Reduce 

Paperwork, but 

States Have Been 

Reluctant to Use 

Them

States Saw Little Benefit in 

Participating in Pilot 

Programs
Page 10 GAO-16-25 Special Education

additional staff that federal funding would not cover. Several states wrote 

letters to Education explaining their reasons for not applying for and

implementing the Paperwork Waiver Program in particular, noting that the 

program would require more paperwork and staff, but provide little in the 

way of additional federal funds. For example, New York’s letter listed as 

key reasons for not participating the extensive requirements for 

participation, limited funding for the pilots, and the staff commitment 

necessary for both development of the proposals and ongoing oversight 

of the pilot projects. In a similar letter, Rhode Island noted that 

implementing the Paperwork Waiver Program would likely result in more 

paperwork—not less—as well as taking more time from staff. Likewise, 

Wisconsin and Missouri expressed concerns about the number of 

requirements and constraints, coupled with inadequate funding.

Education officials said that the amount of funding that was offered to 

help states implement the Paperwork Waiver Program, $25,000 per state, 

was based on the amount of available funding at the time, and had taken 

into account the need to establish a sound evaluation design, as well as 

Education’s commitment to providing technical assistance, as needed.

States also might have been reluctant to participate in the Paperwork 

Waiver Program because Education cannot waive certain provisions 

states find most burdensome. For example, Education officials said that 

states and LEAs were most interested in Education waiving the 

requirements to notify parents of procedural safeguards and to provide 

parents prior written notice of certain actions taken with regard to their 

child’s education, both of which are procedural safeguards that Education 

is prohibited from waiving under IDEA.32 Furthermore, the National 

Association of Secondary School Principals (NASSP) told us that none of 

their members were in favor of the paperwork waivers, in part because of 

the perceived risk of exposing local districts to potential litigation if they 

were to eliminate any of the requirements that parents have come to 

expect.33

 32IDEA prohibits Education from waiving “any statutory requirements of, or regulatory 

requirements relating to, applicable civil rights requirements.” 20 U.S.C. § 1408(a)(2)(B). 

33The National Association of Secondary School Principals is a membership organization 

of junior high and high school principals, assistant principals, and school leaders that 

works to connect school leaders through advocacy, research, education, and student 

programs. 
Page 11 GAO-16-25 Special Education

Stakeholders cited similar reasons for not participating in the Multi-Year

IEP Program. Representatives from NASDSE and the Council for 

Exceptional Children (CEC)34 cited the costs associated with applying for 

the program absent sufficient additional federal funding.35 In its response 

to the proposed requirements for the pilot programs, the Statewide Parent 

Advocacy Network, Inc. commented that enabling states to participate in 

a multi-year IEP demonstration program would have primarily negative 

implications for families of children with disabilities.36

Although some states have adopted some of the model forms Education 

developed pursuant to the 2004 reauthorization’s attempt to reduce 

paperwork, they have used other model forms primarily as a reference 

tool to develop their own state forms.37 In a 2011 NASDSE survey of state 

directors of education, 18 of the 39 who responded said they had adopted 

one or more of the forms. Of those who did not adopt any of the forms, 17 

said they had used them to help guide revision of their own forms, and 

only 3 indicated they had not used the forms at all.38

Education officials and other stakeholders offered several reasons why 

some states have not adopted the model forms as written and instead 

 34CEC is a professional organization of special educators that works to improve the 

educational success of individuals with disabilities and/or gifts and talents. 

35Like the Paperwork Waiver Program, Education proposed funding the Multi-Year IEP 

Program at $25,000 per state. 

36The Statewide Parent Advocacy Network, Inc. is a chapter of the Federation of Families 

for Children’s Mental Health. It collaborates with other family advocacy organizations in 

providing training, information, technical assistance, and support to families of children 

with behavioral, emotional, and mental health challenges, and works to ensure that New 

Jersey provides effective and culturally competent services to children and youth with 

mental health needs and to their families. 

37In August 2006, Education published its Guidance on Required Content of Forms under 

Part B of the IDEA, along with these three model forms, as required. 20 U.S.C. § 1417(e). 

Education also developed a fourth form, a model individualized family service plan for 

infants and toddlers served under Part C of IDEA. Education’s guidance and each of these 

three model forms are available online at <http://idea.ed.gov/static/modelForms>. 

38NASDSE completed this survey about perceived paperwork burden as part of a 

Cooperative Agreement between NASDSE’s Project Forum and the Department of

Education’s Office of Special Education Programs. NASDSE received responses from 36 

states and three non-state jurisdictions. Note: The number of responses does not total 39 

because one respondent did not answer the relevant questions.

Some States and Local 

Districts Used Federal 

Model Forms Primarily to 

Help Develop Their Own 

Forms
Page 12 GAO-16-25 Special Education

used them as reference tools. Education officials said that some states 

find the model IEP form, for example, lacks the content necessary to 

meet state and local requirements. Several stakeholders agreed that the 

model IEP form does not cover all the information required by states, so 

even if states used a federal model form as a starting point, the state 

forms could all be different because the state requirements vary so 

widely. For example, officials from one stakeholder organization told us its 

state has its own model form for prior written notice because it includes 

additional procedural safeguards specific to that state. A different 

stakeholder noted that it would be a lot of work for states to switch from 

the state forms with which they are familiar to Education’s model forms; 

another stakeholder said that local school districts may also tailor the 

forms for local use. On the other hand, one stakeholder noted that the 

forms provided helpful models for states and districts, and said that 

further standardization of these forms would be particularly useful for 

students who move across districts and states because currently they 

must be reevaluated using different forms, which is resource-intensive 

and frustrating.

The states we visited used some of Education’s forms and not others. For 

instance, Arkansas has generally adopted Education’s model form for 

notice of procedural safeguards in its entirety, while New York has 

adopted most of this form, but has added state-specific information. Both 

Arkansas and New York have included most of Education’s model form 

on prior written notice, but with some modifications. Neither state has 

adopted the model IEP form. One Arkansas official suggested that the 

model IEP form does not adequately instruct those completing it to 

include details that could protect school districts from potential parental 

litigation. In contrast, the official said, the state form specifically calls for 

those details, which helps staff complete the form in keeping with 

Arkansas’ direction. New York officials told us they do not use the IEP 

form because they must include other items in their form to ensure 

compliance with both federal and state requirements.

Views on the effects of other IDEA provisions related to paperwork 

reductions are mixed, based on our conversations with focus group 

participants, representatives of education stakeholder organizations, and 

state and local officials in Arkansas and New York. For example, several 

focus group participants and stakeholders differed in their views of a 

Stakeholders Had Mixed 

Views on the Effects of 

Other Paperwork 

Reduction Provisions
Page 13 GAO-16-25 Special Education

provision allowing states to use set-aside funds for certain authorized 

state-level administrative activities, including paperwork reduction 

activities.39 Several participants in our state administrator focus groups 

reported that they have used the flexibility of this provision to help fund 

automated systems for preparing IEPs and for assisting in data collection 

and reporting. However, officials from NASDSE said that some states 

have restrictions on the amount of funds they can use for state 

administration, making the provision irrelevant to them for paperwork 

reduction purposes.

Stakeholders said that the effect of the revised IEP provision eliminating 

benchmarks and short-term objectives was mostly negligible. For 

instance, several stakeholders said that any potential reductions in 

paperwork were offset by what they described as a new statutory 

requirement that IEPs include a statement of measurable annual goals, 

including academic and functional goals.40 Although Education officials 

characterized that statutory language as clarifying a previously existing 

requirement rather than creating a new requirement, several stakeholders 

said the provision created additional work for those states and local 

districts that revised their local IEP forms to explicitly include the annual 

goal information.

The 2004 reauthorization also required states to identify any stateimposed special education rules, regulations, and policies not required by 

IDEA or federal regulations,41 and minimize the number of rules, 

regulations, and policies that districts and schools are subject to under 

IDEA,42 but it is not clear what effect this provision has had. Education 

facilitates compliance with this provision by directing states to list their 

state-imposed rules, regulations, and policies on their annual applications 

 3920 U.S.C. § 1411(e)(2)(C)(ii).

4020 U.S.C. § 1414(d)(1)(A)(i)(II). A Senate report accompanying the 2004 reauthorization 

noted that while benchmarks and short-term objectives are “thought by some to help track 

the child’s progress, their inclusion in IEPs contributes greatly to the paperwork burden on 

educators and parents and often bears no relationship to a child’s development,” and can 

lead to overemphasizing short term gains. S. Rept. No. 108-185, at 28-29 (2003). 

Benchmarks and short-term objectives are still required for those children who take 

alternate assessments aligned to alternate achievement standards. 20 U.S.C. § 

1414(d)(1)(A)(i)(I)(cc). 

4120 U.S.C. § 1407(a)(2). 

4220 U.S.C. § 1407(a)(3).
Page 14 GAO-16-25 Special Education

for federal IDEA funding. However, in our review of the information that 

states submit, we found it varies in detail and format. Education does not 

verify the accuracy of the information states provide, and the provision 

does not require Education to do so, making it difficult to determine the 

prevalence of state-imposed requirements based on state responses 

alone.

State and local officials with whom we spoke widely agreed that 

nonfederal IDEA-related requirements were burdensome. For example, 

participants across 6 of our 9 focus groups—3 with local administrators 

and 3 with educators—said that additional requirements imposed by 

states and localities contribute to the administrative and paperwork 

burden beyond that imposed by federal requirements. Similarly, based on 

our observations and interviews with state and local officials, the number 

of additional requirements can be considerable. New York listed over 200 

state-imposed requirements in 2014. For example, when a student is 

referred for special education, the school must provide a copy of the 

state’s 46-page handbook for parents of students with disabilities. If a 

student is at risk of being placed in a residential facility, the school must 

provide the parent with information about community support services, 

including how to obtain an assessment of the family’s service needs, and 

placement alternatives. New York officials reported that they attempted to 

identify state administrative requirements that did not add value to the 

special education process but did not find many items to remove. Further, 

although Arkansas listed no state-imposed requirements on its federal

IDEA funding application, during our visit we observed several required 

forms imposed by the state. States are not prohibited under IDEA from 

using their own forms, and Arkansas state officials told us they did not list 

Stakeholders Said 

Additional State and 

Local Requirements 

Contribute to Burden, 

but Differed on the 

Burdens and Benefits 

of Federal 

Requirements

States and Localities 

Described Additional 

Requirements that 

Contribute to 

Administrative and 

Paperwork Burden
Page 15 GAO-16-25 Special Education

the forms because they did not believe they were doing anything more 

than what was required under IDEA. This example, however, highlights 

the difficulty in determining what state-imposed requirements should be 

reported.

In both local school districts we visited in New York and Arkansas, IEPs 

are electronic, and each district contracts with a vendor to develop and 

maintain the software used to guide IEP preparation, tailored to local 

preferences and needs. However, in the Rochester, N.Y. district, the 

electronic IEP includes state-required data elements in addition to those 

required by federal law. Further, the district has added at least one 

additional requirement that teachers include the student’s latest report 

card results—even though the information is available in the student’s 

official school file. Although this approach is typical of many school 

districts, these systems are tailored to local requirements and the IEPs 

themselves are formatted differently, making it difficult to transfer 

students’ records when they move from one district to another within each 

state, let alone across states with differing laws and administrative 

requirements.

Stakeholders said that the additional requirements can make it difficult to 

isolate the contribution of IDEA requirements to administrative burdens. 

One official commented that it is nearly impossible to isolate the 

contribution of IDEA requirements to administrative burdens at the state 

and local levels because there are so many other requirements placed on 

states and local districts related to education by other sources. In a 2015 

issue paper, the American Speech-Language-Hearing Association noted 

that although federal statutes and regulations generate paperwork and 

administrative burdens for their members, all levels of government 

contribute to the total burden shouldered by their members. In addition to 

IDEA requirements, there are those mandated under the Elementary and 

Secondary Education Act of 1965, as amended, Medicaid, and various 

smaller programs, as well as those added by state law and local school 

districts, which further exacerbate the problem, whether in anticipation of, 

or due to compliance with, litigation and court decisions.43

 43American Speech-Language-Hearing Association, “Excessive Paperwork Burden: 

Impact on School-Based Audiologists and Speech-Language Pathologists,” Washington, 

D.C., 2015.
Page 16 GAO-16-25 Special Education

While many stakeholders agreed that special education requirements 

contribute to administrative and paperwork burden, they differed in their 

views on the burdens and benefits of specific IDEA requirements. 

Participants across educator and local administrator focus groups cited 

more tasks as being particularly burdensome than did those in the state 

administrator groups. Common areas of concern for participants across 

all 3 educator focus groups and all 3 local administrator focus groups 

included preparing IEP documents, focusing on compliance, using 

technology, and identifying students with special needs or determining 

eligibility. In focus group discussions with state administrators, the only 

specific administrative task they reported as particularly burdensome was 

preparing state performance plans and annual performance reports for 

Education. (See table 1.)

Table 1: Administrative Tasks Perceived to Be Particularly Burdensome under the 

Individuals with Disabilities Education Act (IDEA), as Cited in GAO Focus Groups 

Burdensome tasks

Cited in all focus groups with:

Educators Local 

administrators

State 

administrators

Preparing individualized education 

program (IEP) documents

 

Focusing too much on compliance  

Meeting state or local special 

education requirements

 

Using technology  

Engaging in child find or 

determining eligibility

 

Monitoring or reporting student 

progress



Ensuring due process 

Documenting behavioral problems 

Implementing IEPs 

Preparing State Performance 

Plan/Annual Performance Report



Source: GAO analysis of focus group comments. | GAO-16-25

Note: The categories presented in this table reflect only those for which one or more participants cited 

the relevant task across all focus groups in a particular category—educators, local administrators, or 

state administrators. Although we identified additional task categories, these were not cited across all 

focus groups, and therefore have been excluded from this table.

Our focus group results are consistent with previous findings from a GAO 

review of federal education requirements in which education stakeholders 

identified two IDEA requirements— processing IEPs and collecting and 

Stakeholders Differed on 

the Specific Burdens and 

Benefits of IDEA 

Requirements
Page 17 GAO-16-25 Special Education

reporting performance data to Education—as being among the more 

burdensome for states and districts.44 More specifically, stakeholders said 

in our prior work that IEP processing was complicated, time and 

paperwork intensive, and vague. They also said that IDEA indicators—

performance measures that Education uses to monitor state compliance 

with IDEA—were complicated, time and resource and paperwork 

intensive, and duplicative. Similarly, participants in our focus groups for 

this review identified preparing IEPs and reporting annually to Education 

as being particularly burdensome, and described similar types of burdens 

to those previously identified when explaining why these tasks are 

particularly burdensome. (See table 2.)

Table 2: Types of Burdens Associated with Administrative Tasks under the Individuals with Disabilities Education Act (IDEA), 

as Identified by GAO Focus Group Participants 

Administrative Tasks Types of burdens

Complicateda Timeintensiveb Paperworkintensivec Resourceintensived Duplicativee Vaguef

Preparing individualized education program (IEP) 

documentsg    h i

Focusing too much on compliance     

Meeting state or local special education requirements     

Using technology    

Engaging in child find or determining eligibility    

Monitoring or reporting student progress   

Ensuring due process    

Documenting behavioral problems  

Implementing IEPs    

Preparing State Performance Plan/Annual Performance 

Report

j

  k  l

Source: GAO analysis of focus group comments. | GAO-16-25

Note: A checkmark indicates, for the tasks cited as particularly burdensome in table 1, the nature of 

the burden as described by one or more focus group participants. 

 44See GAO-12-672. Processing IEPs can include numerous tasks, such as obtaining and 

documenting assessments of student strengths and limitations, writing the plan for 

delivering services, and scheduling IEP meetings to discuss recommended education 

programs with multiple participants. Education stakeholders in our prior report also cited a 

third IDEA requirement regarding the transition from IDEA Part C programs into IDEA Part 

B programs as being burdensome for states and school districts. However, we did not 

include requirements related to IDEA Part C programs in this review; therefore the 

transition between programs is beyond the scope of the current analysis.
Page 18 GAO-16-25 Special Education

a

Complicated: Requirements change often, include varying or conflicting definitions, involve multiple 

steps, or have processes, deadlines, or rules that make compliance difficult or that result in 

unintended consequences.

b

Time-intensive: Compliance is time-consuming. c

Paperwork-intensive: Documentation is excessive. d

Resource-intensive: Compliance is costly or requires a substantial amount of technical support. e

Duplicative: Requirements from different agencies or offices within the same agency were poorly 

coordinated or requested redundant information (similar or exact).

f

Vague: States or school districts lacked knowledge or guidance related to the requirement, or certain 

processes were unknown or unclear.

g

This task is similar to the previously identified requirement “IEP processing,” as reported in 

GAO-12-672. h

Not previously identified as a type of burden related to the category “IEP processing,” as reported in 

GAO-12-672. i

Previously identified as a type of burden related to the category “IEP processing,” as reported in 

GAO-12-672. j

This task is similar to the previously identified requirement “IDEA indicators,” as reported in 

GAO-12-672. k

Previously identified as a type of burden related to the category “IDEA indicators,” as reported in 

GAO-12-672. l

Previously identified as a type of burden related to the category “IDEA indicators,” as reported in 

GAO-12-672.

Aside from their views on IDEA requirements they regard as particularly 

burdensome, stakeholders across all 9 focus groups acknowledged that 

administrative tasks and paperwork play an important role in helping 

ensure accountability and transparency in the special education process, 

among other benefits. (See table 3.)

Table 3: Perceived Benefits of Administrative Tasks and Paperwork under the 

Individuals with Disabilities Education Act (IDEA), as Cited in GAO Focus Groups

Benefits

Cited in all focus groups with:

Educators

Local 

administrators

State 

administrators

Ensures 

accountability/transparency

  

Promotes collaboration  

Facilitates individualization of 

instruction

 

Provides information that allows 

for better understanding of 

students



Facilitates planning and program 

development



Source: GAO analysis of focus group comments. | GAO-16-25

Note: The categories presented in this table reflect only those in which one or more participants cited 

the relevant benefit across all focus groups in a particular category—educators, local administrators, 

or state administrators. Although we identified additional benefit categories, these were not cited 

across all focus groups, and therefore have been excluded from this table.
Page 19 GAO-16-25 Special Education

Although the parents that we spoke with during our site visit in New York 

did not express any positive views of the administrative requirements, 

parents in Arkansas said the IEP is useful in guiding discussions with 

school district staff, and serves as a record of what the district is doing for 

their child. Based on our discussions with groups that represent the 

interests of parents with children who receive special education services, 

evaluation reports, which provide information about a student’s limitations 

and strengths, can facilitate individualization of instruction by providing a 

baseline for performance that can be used to measure student progress.

Officials from these organizations also noted that administrative 

requirements that safeguard procedural rights, such as prior written 

notice, benefit parents by helping them understand how to help their 

children receive special education services.

Additionally, based on our discussions with parents and representatives 

of parent organizations, we found that administrative requirements in 

special education can be helpful to parents, but only to the extent that the 

information generated is accessible, and requirements are enforced. In 

particular, the language used to document students’ current levels of 

performance poses a challenge for many parents, who sometimes find 

the language complicated and confusing, making it difficult to understand 

important information about their children. In another example, while 

parents noted that certain administrative requirements, such as IEPs and 

parent meetings, can be useful tools to share information and promote 

collaboration among those involved in a child’s education, they did not 

find them helpful when used incorrectly. For example, parents expressed 

some frustration with IEPs they felt were not being followed, as well as 

IEP meetings they felt were sometimes used to justify a course of action 

rather than to determine the best course of action for their child.
Page 20 GAO-16-25 Special Education

Available research supports what stakeholders told us about special 

education administrative burden. Specifically:

• The 2002 Study of Personnel Needs in Special Education 

(SPeNSE),45 commissioned by Education, found that elementary and 

secondary special education teachers reported spending an average 

of 1 hour per day completing forms and paperwork—as much time as 

they spent preparing for lessons.46

• A 2008 time-use study found that special education teachers in five 

Texas school districts spent an average of almost 2 hours per day (1 

hour and 51 minutes) on administrative tasks—more time than they or 

their principals thought they were spending.47

• A 2012 study of how preventive services are implemented by special 

education teachers found that special education teachers across 

seven elementary schools in Kansas spent about 1 hour per day, on 

average, doing managerial tasks that involved paperwork.48

• In an American Speech-Language-Hearing Association biannual 

survey of school-based speech-language pathologists and 

educational audiologists, respondents listed paperwork as their top 

challenge in each survey from 2004 through 2014.

 45Elaine Carlson, et al (Westat, Inc., Rockville, MD). Study of Personnel Needs in Special 

Education, Washington: U.S. Department of Education, Office of Special Education 

Programs; 2002. The study included a survey of a nationally representative sample of 

1,333 special education teachers on the topic of time spent on administrative duties and 

paperwork.

46Estimated time spent per week on paperwork varied from 1 hour or less (reported by 14 

percent) to more than 14 hours (reported by 8 percent). Variations in time spent on 

paperwork appear to be related to geography and grades taught. 

47Dana Pomykal Franz, et al, “Time Use by Special Educators and How It Is Valued,”

Journal of School Leadership, 18 (September 2008): 551-576. The study involved 13 

elementary resource teachers and their principals. In addition to observing the actual time 

spent on administrative tasks, researchers asked special education teachers and their 

principals to estimate the amount of time per day that the teachers spent on administrative 

tasks. On average, the teachers estimated they spent 1 hour and 10 minutes, whereas 

principals estimated the teachers spent 49 minutes on these tasks. 

48Belinda B. Mitchell, Donald D. Deshler, and B. Keith Ben-Hanania Lenz, “Examining the 

Role of the Special Educator in a Response to Intervention Model,” Learning Disabilities: 

A Contemporary Journal 10(2) (2012): 53-74. This study involved seven special education 

teachers. 

Available Research Shows 

Administrative and 

Paperwork Tasks Take 

Time Away from Teaching 

and Training
Page 21 GAO-16-25 Special Education

Consistent with this research, participants across our 3 educator focus 

groups estimated that they spend between 2 to 3 hours per day on 

administrative tasks, or roughly 20 to 35 percent of their time, and said 

that these tasks take away time needed to complete other required tasks.

In particular, they said they do not have enough time to complete 

paperwork during their regular work hours, which means they complete it 

on their own time. Participants across the educator focus groups also 

reported that paperwork and administrative tasks take time away from the 

classroom and other important tasks, such as academic planning and 

performing assessments.

Although local administrators would reasonably be expected to spend 

more time on administrative tasks due to the nature of their jobs, they still 

shared similar concerns regarding administrative and paperwork burdens 

crowding out important, non-administrative responsibilities, such as 

providing training or observing classrooms.49

 49Local administrators’ estimates of time spent on administrative tasks ranged from 45 to 

100 percent.

Education and States 

Stated that They 

Have Adopted 

Computer Technology 

and Other Steps that 

Reduce 

Administrative 

Burdens, but These 

Efforts Have 

Limitations
Page 22 GAO-16-25 Special Education

Some participants in all of our focus groups said that computer 

technology and the availability of electronic data sets have reduced 

administrative burdens associated with IDEA. In particular, some 

participants in focus groups stated that they found electronic IEPs to be 

helpful in ways such as making data input easier, reducing the chance for 

data entry errors, and pulling data together from different sources.

According to several SEA officials in our focus groups, the linkage of IEPs 

with automated data systems assists SEAs in their monitoring and 

compliance activities with local school districts.

Education has developed a data system called EDFacts which it believes 

will help reduce administrative burden. According to Education, EDFacts 

is a system designed to centralize data provided by SEAs and LEAs and 

to streamline data processes at the federal, state, district, and school 

levels. SEAs transmit data to Education via the EDFacts Submission 

System, an electronic system designed to help SEAs transmit data in a 

timely and efficient manner through the use of a file submission 

application. It includes data required by IDEA and is comprised of six data 

collections. To further ease the data submission process, Education has 

developed a web-based Data Submission Organizer tool that provides 

information about how and when to submit IDEA and other K-12 data.

Members of our focus groups also said that GRADS360, an IDEA-specific 

data system unveiled in October 2014 by the Office of Special Education 

Programs (OSEP), has effectively reduced the reporting burdens 

associated with IDEA. GRADS360 is the electronic platform for states to 

submit data which is then used to create states’ annual IDEA Part B and 

Part C State Performance Plan/Annual Performance Report (SPP/APR). 

The SPP/APR evaluates a state’s efforts to implement the requirements 

and purposes of IDEA, and describes how a state will improve its 

implementation. Education’s GRADS360 website contains, among other 

things, profiles on states’ previous data submissions, tools on how to 

submit data to the system, and a calendar that specifies data submission 

deadlines. Some focus group participants said GRADS360 has reduced 

the burden associated with completing the SPPs and APRs. One 

participant asserted that GRADS360 reduced the administrative burdens 

of producing these reports by 50 percent.

In addition to EDFacts and GRADS360, Education’s OSEP has funded 

four technical assistance centers intended to help states produce and 

submit high quality IDEA-related data. The centers focus on (1) IDEA’s 

data collecting and reporting requirements (The IDEA Data Center), (2) 

the development or enhancement of longitudinal data systems (The 

Center for IDEA Early Childhood Data Systems for children from birth 

Computer Technology and 

Data Systems Have 

Reportedly Helped Ease 

Some Administrative 

Burdens Related to 

Special Education 

Requirements
Page 23 GAO-16-25 Special Education

through age 5), (3) support for combining IDEA data with the Educationfunded State Longitudinal Data System (Center for the Integration of 

IDEA Data), and (4) assistance to SEAs on their federal special education 

fiscal data collection and reporting obligations (Center for IDEA Fiscal 

Reporting).

Some focus group participants said SEAs are implementing computer 

systems that they believe help ease administrative burden. Most of these 

efforts involve computer data and system consolidation. For example, 

several participants said their states have activated systems in which 

electronic IEP data and other student data can be integrated with the 

state’s student data management system. Participants cited benefits to 

this integration including making it easier for LEAs to upload participants’

data to the state system, and enabling the state to have data related to 

IDEA requirements. One focus group participant said her state has a 

single computer system so that the SEA and LEAs within the state can 

use the same system.

Some participants in our focus groups said the computer systems used in 

their states need to be improved to further reduce burdens associated 

with IDEA requirements. Several participants said existing computer 

systems are not well integrated and thus do not exchange data across 

systems. For example, two LEA participants said they must each work 

with separate computer systems or databases that do not allow automatic 

data transfers. In one instance, the participant noted having to pull down 

data from an IEP system and then upload it to another system. In the 

other case, the participant said data from each database in the system 

had to be uploaded separately because none of the data had been 

collated across databases. Another participant noted having to use five 

different federal log-ons and yet still could not find the information sought.

One participant also said that reporting the same information multiple 

times across different computer systems (federal and state) was a 

burden.

Other focus groups members told us that technical problems can make 

using automated systems difficult. Some of these technical problems 

included system crashes, losing data when attempting to save the data 

into the system, major technical “glitches,” and a lack of computer system 

capacity. In addition, one educator cited the burden of having to learn a 

new computer system, only to have the system replaced with another 

shortly thereafter.

Despite Benefits, Existing 

Technology Reportedly 

Has Limitations in 

Addressing Burdens
Page 24 GAO-16-25 Special Education

Focus group participants, stakeholders in New York and Arkansas, and 

other special education officials said adopting certain types of noncomputer-related practices had reduced the burdens faced by SEAs, 

LEAs, and educators generally fell into three categories: administrative 

support, IEP management, and communication strategies.

• Administrative support. One practice was to assign one or more 

individuals to perform or monitor administrative duties related to IDEA. 

According to state special education officials from our site visits, many 

of the larger school districts hire due process clerks to handle 

logistics. These are teachers who may continue to teach part time or 

take on the special education administrative role full time. This frees 

special education teachers from some of the required paperwork.

Some participants from our focus groups said that having 

administrative clerks reduced the time and burdens associated with 

administrative tasks. One educator from a focus group said hiring a 

paraprofessional to set up all IEP meetings, contact parents, and send 

out meeting notices proved helpful in reducing administrative burden.

Another practice favored by one focus group member was 

establishing dedicated time periods in which a teacher would 

exclusively teach for 3 weeks and then complete administrative tasks 

for 1 week.

• IEP management. Some focus group participants said that using 

amended or draft IEPs (rather than creating completely new IEPs) can 

reduce burden. According to the participants, amended IEPs have 

advantages such as allowing an IEP team to make minor IEP 

changes without having to call a meeting or redo the entire IEP, 

making it easier to update or change goals, and reducing the time and 

impact on staff. One participant said using a draft IEP provides 

information so everyone attending an IEP meeting is better prepared.

• Communication strategies. According to participants in several 

focus groups, practices that foster communication among educators 

and specialists who work with special education students can reduce 

burden. For example, one participant said creating a triad relationship 

with a student’s general education teacher, special education teacher, 

and case manager can be very important and beneficial to the 

student. Another participant noted the importance of everyone who 

works with a special education student collaborating to make a plan 

so that the student can make progress. In addition, one participant 

stated that, to reduce burdensome redundancies created by the “dualtrack” paperwork systems for special education and general 

education, those working with a student should have a conversation 

Stakeholders Also 

Reported Using Nontechnology Strategies that 

Help Ease IDEA’s 

Administrative Burdens
Page 25 GAO-16-25 Special Education

and reach agreement on whether special education or general 

education is in that student’s best interests.

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

review and comment. In its written comments, reproduced in appendix II, 

Education neither agreed nor disagreed with our findings. Education also 

provided technical comments that were incorporated, as appropriate.

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from its 

issue date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Education, and 

other interested parties. 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 should have any questions about this report, please 

contact me at (617) 788-0580 or nowickij@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix III.

Jacqueline M. Nowicki

Director, Education, Workforce,

and Income Security Issues

Agency Comments 
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-16-25 Special Education

The objectives of this report were to examine (1) what Education and 

states have done to implement selected provisions of the law to help 

minimize the burden associated with administrative and paperwork 

requirements under the Individuals with Disabilities Education Act (IDEA), 

(2) stakeholder views about IDEA’s administrative and paperwork 

requirements, and (3) the steps Education and others have taken to 

minimize IDEA-related burden.

To address our first objective, we reviewed relevant laws, regulations, 

and published studies. We interviewed officials from Education and 

organizations representing education stakeholder groups, including 

special education administrators at the state and district levels, parents of 

students with disabilities, and educators. Some of these groups included 

the National Association of State Directors of Special Education, Inc.; 

American Speech-Language-Hearing Association; Council for Exceptional 

Children; Council of Administrators of Special Education; National 

Education Association; National Association of Secondary School 

Principals; and PACER Center. To identify specific provisions of the 2004 

IDEA reauthorization intended to reduce the burden associated with 

administrative and paperwork requirements, we reviewed a 

Congressional Research Service analysis of the law as well as the results 

of our literature search.

To address our second objective, we conducted a series of 9 focus group 

discussions—3 with state administrators from 18 states, 3 with local 

administrators from 14 states, and 3 with educators from 15 states. 

Overall, participants came from 37 separate states, and though their 

comments are not generalizable, they represented a broad range of 

experiences from across all regions of the country and all types of school 

districts. To identify potential participants for our focus groups, which 

consisted of at least six participants each, we worked with the National 

Association of State Directors of Special Education, Inc., Council of 

Administrators of Special Education, National Education Association, and 

other professional organizations representing education stakeholder 

groups, including educators and special education administrators at the 

state and district levels. The organizations we contacted that represent 

parents of students with disabilities included the Statewide Parent 

Advocacy Network, Inc. and the Council of Parent Attorneys and 

Advocates. In addition to contacting these organizations, we posted 

information in a National Association of Special Education Teachers’

newsletter to identify potential focus group participants. In order to 

maximize the diversity of our sample of participants, we extended 

invitations to participants based on the state in which they were 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-16-25 Special Education

employed, type of position, years of experience, and type of school 

district (rural or urban). We documented these characteristics via a 

participant questionnaire. Using a combination of these methods for 

identifying potential participants ensured that all of the participants in one 

strata of the focus groups did not come from a single source, mitigating 

potential bias toward a specific organization. Once the list of potential 

participants was compiled, we emailed the potential participants to 

confirm that they currently worked or had worked previously in the 

relevant organization in the area of special education, and to inquire if 

they wished to participate.

In addition to gaining the perceptions of special education administrators 

and educators on IDEA administrative and reporting requirements, we 

also obtained information on how another key stakeholder group—

parents of students with disabilities—perceive these requirements. 

Although parents of such students do not directly complete IDEA 

paperwork, we gathered information on how they perceive IDEA 

administrative and paperwork requirements from our discussions with 

organizations representing them and from results of their literature on the 

subject.

We analyzed the content of our 9 focus group discussions to identify 

similarities and differences within and across these groups regarding time 

spent on IDEA administrative tasks, perceived benefits and burdens 

associated with administrative requirements, and potential solutions and 

strategies about how to minimize time spent on administrative tasks. To 

achieve consensus on this identification, two analysts independently 

reviewed focus group transcripts and categorized relevant discussions 

across four different topics:

• Time Spent on Paperwork

• Perceived Burdens

• Perceived Benefits of Administrative Tasks

• Model Practices and Potential Solutions

For burdens specifically, we further categorized the reasons why focus 

group participants considered administrative and paperwork tasks 
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-16-25 Special Education

burdensome, using categories we previously developed.1 These reasons 

include and are defined as follows:

• Complicated: Requirements change often, include varying or 

conflicting definitions, involve multiple steps, or have processes, 

deadlines, or rules that make compliance difficult or that result in 

unintended consequences.

• Time-intensive: Compliance is time-consuming.

• Paperwork-intensive: Documentation is excessive.

• Resource-intensive: Compliance is costly or requires a substantial 

amount of technical support.

• Duplicative: Requirements from different agencies or offices within 

the same agency were poorly coordinated or requested redundant 

information (similar or exact).

• Vague: States or school districts lacked knowledge or guidance 

related to the requirement, or certain processes were unknown or 

unclear.

To illustrate the administrative processes in different school districts in 

different areas of the country, and to identify how differences in state and 

local requirements may contribute to differences in burden, along with 

common concerns and suggestions for addressing them, we completed 

site visits in Clinton, Arkansas and Rochester, New York. We selected 

these two school districts to highlight different experiences in how urban 

and rural school districts manage administrative requirements, and how 

parents in these districts perceive the requirements. We first selected 

Arkansas and New York to provide diverse geographic locations, number 

of state-imposed special education requirements listed on the state 

application for IDEA funding, and incidence of dispute resolutions as 

reported by a GAO special education report.2 Specifically, New York, in 

the northeast region, listed over 200 state-imposed special education 

 1

GAO- K-12 Education: Selected States and School Districts Cited Numerous Federal 

Requirements As Burdensome, While Recognizing Some Benefits, GAO-12-672

(Washington, D.C.: June 2012). 

2

GAO, Special Education: Improved Performance Measures Could Enhance Oversight of 

Dispute Resolution, GAO-14-390 (Washington, D.C.: August 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-16-25 Special Education

requirements on its IDEA funding application, and also had a high 

incidence of dispute resolutions.3 Arkansas, in the southeast region, listed 

no state-imposed special education requirements on its IDEA funding 

application, and was not identified in the GAO special education report on 

dispute resolution. Within each state, we chose the LEAs and schools to 

achieve diversity across urban and rural districts and primary and 

secondary schools, and large enough to have with some experience with 

special education needs.

These site visits provided opportunities to understand and document local 

efforts to manage administrative requirements and to speak with parents 

about how they perceive special education procedures. The visits also 

allowed us to explore how differences in state and local requirements 

may contribute to differences in perceptions of the relative benefits and 

challenges associated with meeting key federal requirements. At each 

site, we interviewed the relevant state and local special education 

administrators, and those who work directly with special education 

students. We also obtained state and local policies and procedures, 

enabling us to develop a narrative about the types of paperwork various 

individuals are responsible for and any additional requirements imposed 

by the state or LEA. At each location, we also met with parents whose 

children were receiving special education services. Parents were 

informed of these meetings by the local districts, and attendance was 

voluntary. We compared these narratives to understand various 

differences across the locations.

To address our third objective, we spoke with Education officials about 

steps the agency had taken to reduce the associated burden of 

administrative and reporting requirements under IDEA, and reviewed the 

agency’s Paperwork Reduction Act (PRA) burden estimates for proposed 

amendments to data collections related to IDEA implementation. We also 

spoke with state and local officials in New York and Arkansas about steps 

taken to minimize burden, and included a question on this subject in our 

focus group discussions. Finally, we gathered information on efforts to 

minimize burden from our discussions with officials from the previouslylisted organizations representing education stakeholders and 

organizations representing parents of students with disabilities, and from 

 3

GAO used the geographic categories from the 2002 Study of Personnel Needs in Special 

Education (SPeNSE) commissioned by Education. SPeNSE reported teachers in the 

northeast region spent a median 3.3 hours per week on special education paperwork, the 

least of any region. 
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-16-25 Special Education

results of our literature search. We selected these organizations to 

provide a range of views on the benefits and burdens of IDEA 

requirements.
Appendix II: Comments from the U.S. 

Department of Education

Page 31 GAO-16-25 Special Education

Appendix II: Comments from the U.S. 

Department of Education
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 32 GAO-16-25 Special Education

Jaqueline M. Nowicki, (617) 788-0580 or nowickij@gao.gov.

In addition to the contact named above, Mary Crenshaw, Assistant 

Director; Regina Santucci, Analyst-in Charge; Betty Ward-Zukerman, 

Justin Riordan, Tyne McGee, Daren Sweeney, Andrew Nelson, Susanna 

Clark, Laurel Beedon, and Sheranda Campbell made significant 

contributions to this report. Also contributing to this report were Walter 

Vance, James Rebbe, Charlie Willson, Tim Bober, Carolyn Yocom, David 

Forgosh, and Nyree Ryder Tee.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(131324)
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-16-25 Special Education

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