Report to Congressional Requesters

United States General Accounting Office 

GAO 

July 2003 NO CHILD LEFT 

BEHIND ACT 

More Information 

Would Help States 

Determine Which 

Teachers Are Highly 

Qualified 

GAO-03-631 
GAO could not develop reliable data on the number of highly qualified 

teachers because states did not have the information needed to determine 

whether all teachers met the criteria. Officials from 8 states visited said they 

did not have the information they needed to develop methods to evaluate 

current teachers’ subject area knowledge and the criteria for some teachers 

were not issued until December 2002. Officials from 7 of 8 states visited said 

they did not have data systems that could track teacher qualifications for 

each core subject they teach. 

Source: U.S. Department of Education. 

Both state and district officials cited many conditions in the GAO survey that 

hinder their ability to have all highly qualified teachers. State and district 

officials reported teacher pay issues, such as low salaries and lack of 

incentive pay, teacher shortages, and other issues as hindrances. GAO’s 

survey estimates show that significantly more high-poverty than low-poverty 

districts reported hindrances, such as little support for new teachers. Rural 

district officials cited hindrances related to their size and isolated locations. 

State officials reported they needed assistance or information from 

Education, such as in developing incentives to teach in high-poverty schools, 

and Education’s strategic plan addresses some of these needs. 

To help meet the requirement for highly qualified teachers, state survey 

respondents reported they planned to spend about 65 percent of their Title II 

funds on professional development activities authorized under Title II, and 

districts planned to spend an estimated 66 percent on recruitment and 

retention. Both state and district officials planned to spend much larger 

amounts of funds from sources other than Title II funds on such activities. 

High-poverty districts planned to spend more Title II funds on recruitment 

and retention than low-poverty districts. State and district officials visited 

said that most activities were a continuation of those begun previously. 

In December 2001, Congress 

passed the No Child Left Behind 

Act (NCLBA). The act required that 

all teachers of core subjects be 

highly qualified by the end of the 

2005-06 school year and provided 

funding to help states and districts 

meet the requirement. In general, 

the act requires that teachers have 

a bachelor’s degree, meet full state 

certification, and demonstrate 

subject area knowledge for every 

core subject they teach. This 

report focuses on the (1) number of

teachers who met the highly 

qualified criteria during the 2002-03 

school year, (2) conditions that 

hinder states’ and districts’ ability 

to meet the requirement, and (3) 

activities on which states and 

districts were planning to spend 

their Title II funds. GAO surveyed 

50 states and the District of 

Columbia and a nationally 

representative sample of districts 

about their plans to implement the 

requirement. GAO also visited and 

interviewed officials in 8 states and 

16 districts to discuss their efforts 

to implement the law. 

To help states determine which 

teachers are highly qualified and 

the actions they need to take to 

meet the requirement, GAO 

recommends that the Secretary of 

Education provide more 

information to states, especially on 

ways to evaluate the subject area 

knowledge of current teachers. The 

Department of Education provided 

written comments on a draft of this 

report and generally agreed with 

GAO’s recommendation.

www.gao.gov/cgi-bin/getrpt?GAO-03-631.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Marnie S. 

Shaul, 512-7215, shaulm@gao.gov. 

Highlights of GAO-03-631, a report to 

Congressional Requesters 

July 2003

NO CHILD LEFT BEHIND ACT 

More Information Would Help States 

Determine Which Teachers Are Highly 

Qualified 
Page i GAO-03-631 No Child Left Behind 

Letter 1

Results in Brief 2

Background 5

Many States Were Uncertain about Numbers of Highly Qualified 

Teachers 10

State and District Officials Reported Many Conditions as 

Hindrances to Meeting the Law 13

To Help Teachers Meet the Requirement States Planned to Spend 

Most Title II Funds on Professional Development Activities, and 

Districts Will Spend Most on Recruitment and Retention 

Activities 23

Conclusions 29

Recommendation for Executive Action 29

Agency Comments and Our Evaluation 29

Appendix I Scope and Methodology 31 

Appendix II Activities on Which States Can Spend Title II, Part A 

Funds 37 

Appendix III Activities on Which Districts Can Spend Title II, 

Part A Funds 38 

Appendix IV Comments from the U.S. Department of Education 39 

Appendix V GAO Contacts and Staff Acknowledgments 42 

GAO Contacts 42

Staff Acknowledgments 42 

Contents 
Page ii GAO-03-631 No Child Left Behind 

Tables 

Table 1: Federal Criteria for a Highly Qualified Teacher 7

Table 2: Estimated Percentages of Districts That Will Have 

Difficulty Meeting the Requirement for Highly Qualified 

Teachers by Grade Level and Poverty 12

Table 3: Number of States Reporting on Conditions That Hinder 

Their Ability to Meet the Requirement for Highly Qualified 

Teachers (Ranked from Highest to Lowest) 17

Table 4: Estimated Percentages of Districts Reporting on 

Conditions That Hinder Their Ability to Meet the 

Requirement for Highly Qualified Teachers (Ranked from 

Highest to Lowest) 19

Table 5: Estimated Percentages of High- and Low-Poverty Districts 

with Significant Differences in the Hindrances to Meeting 

the Requirement 21

Table 6: Estimated Percent of Spending Title II Funds by Activities 

for All Districts, High-Poverty Districts, and Low-Poverty 

Districts 26

Table 7: Population and Sample by Stratum 32

Table 8: Sample Estimates Compared to Population Values 34

Table 9: Population and Sample by Region 35

Table 10: Title II, Part A State Activities 37

Table 11: Title II, Part A District Activities 38

Figures 

Figure 1: Education’s Assistance to States During Calendar Year 

2002 9

Figure 2: Planned Spending of Title II Funds by Reporting States 24

Figure 3: Sources of Funds for Planned Spending by States on Title 

II Activities 25

Figure 4: Estimated Spending of Title II Funds as a Percentage of 

Total Funds by Activities for All Districts, High-Poverty 

Districts, and Low-Poverty Districts 28

Figure 5: State Survey Respondents 31
Page iii GAO-03-631 No Child Left Behind 

Abbreviations 

CCD Core of Common Data 

CCSSO Council of Chief State School Officers 

CMSA Consolidated Metropolitan Statistical Area 

LEA Local Education Agency 

MSA Metropolitan Statistical Area 

NCLBA No Child Left Behind Act

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Page 1 GAO-03-631 No Child Left Behind 

July 17, 2003 

The Honorable Edward M. Kennedy 

The Honorable Jeff Bingaman 

United States Senate 

In December 2001, Congress passed the No Child Left Behind Act 

(NCLBA), which, among other things, focused attention on closing the 

achievement gaps among various groups of students. Recently, a body of 

research has shown that quality teachers play a significant role in 

improving student performance. However, research has also shown that 

many teachers, especially those in high-poverty and rural districts,1

 were 

not certified and lacked knowledge of the subjects they taught. NCLBA 

established the requirement that all teachers be highly qualified for each 

core subject they teach by the end of the 2005-06 school year.2

 The criteria 

for meeting this requirement vary somewhat by grade level and experience 

but generally require that teachers have (1) a bachelor’s degree, (2) state 

certification, and (3) subject area knowledge for each core subject they 

teach. This represents the first time the federal government has 

established specific criteria for teachers. Title II, Part A, of NCLBA 

replaced the Eisenhower Professional Development and Class Size 

Reduction programs with the Teacher and Principal Training and 

Recruiting Fund and Congress appropriated $2.85 billion to help states and 

districts meet the requirement. In addition, Title II directed these funds to 

be spent on specific activities to help states and districts recruit, retain, 

and develop highly qualified teachers. The Department of Education 

(Education) administers Title II and is responsible for oversight of states’ 

implementation of NCLBA. 

Given the need for states and districts to meet the requirement for highly 

qualified teachers by the end of the 2005-06 school year, you asked us to 

determine what they were doing to have their teachers meet the 

requirement. Specifically, this report focuses on the (1) number of 

teachers who met the highly qualified teacher criteria during the 

2002-03 school year, (2) conditions that hinder states’ and districts’ ability 

 1

In this report, the term “district” refers to local education agencies. 

2

Core subjects include English, reading or language arts, mathematics, science, foreign 

languages, civics and government, economics, arts, history, and geography. 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-03-631 No Child Left Behind 

to meet the requirement, and (3) activities on which states and districts 

were planning to spend their Title II funds. 

In conducting our work, we surveyed 50 states and the District of 

Columbia. We obtained responses for 37 of these 51 surveys and reported 

the results as representing only those that responded. The student 

enrollment for the responding states represented 85 percent of total 

student population in kindergarten through 12th grade. In addition, we 

surveyed a nationally representative sample of 830 school districts. We 

received a response from 511 or 62 percent. We compared relevant 

characteristics of these respondents to the universe of districts and found 

them to be similar, which along with the response rate allowed us to 

report national estimates.3

 For our comparisons of high- and low-poverty 

districts, we included responding districts that had 70 percent or more of 

their students approved for free and reduced-price meals as high-poverty 

and those with 30 percent or less of their students approved for free and 

reduced-price meals as low-poverty. We visited and interviewed officials in 

8 states selected with a range of characteristics that might affect their 

ability to meet the requirement—California, Connecticut, Illinois, Iowa, 

Maryland, North Carolina, Delaware, and Wyoming. We visited 2 districts 

in each of the states and 1 school in each district. We interviewed U.S. 

Department of Education officials, and officials from professional 

organizations and unions that represent teachers. Additionally, we 

analyzed the legislation, related reports, and relevant documents. See 

appendix I for detailed information on the methodology. We conducted 

our work from July 2002 through May 2003 in accordance with generally 

accepted government auditing standards. 

We could not develop reliable data on the number of highly qualified 

teachers because states did not have the information needed to determine 

whether all teachers met the criteria. During our visits state officials did 

not know the criteria for some of their teachers. Education’s draft 

guidance on the criteria for teachers in alternative certification programs 

changed between June and December of 2002, which meant that states had 

to reassess their teachers’ qualifications. Guidance for special education 

teachers was not available until December 2002, and it was contained in an 

 3

All percentage estimates produced from the district survey have sampling errors of no 

more than plus or minus 10 percentage points, at a 95 percent confidence level, unless 

otherwise noted. 

Results in Brief 
Page 3 GAO-03-631 No Child Left Behind 

appendix to the Title I regulations, but not in the federal regulations. Also, 

states did not have the information they needed to develop methods to 

evaluate subject area knowledge of their current teachers. In our survey, 

32 of 37 state respondents said that they needed clear and timely guidance 

from Education. Additionally, officials from 7 of the 8 states we visited 

said they did not have data systems that could track teacher qualifications 

by subject, which they needed to determine if a highly qualified teacher 

taught each core subject. One official added a comment to the survey that 

said the state data system on teachers “was designed years ago for state 

certification purposes...[and] has not yet been updated to include all 

NCLBA criteria for teachers.” Some state officials we interviewed also 

expressed reservations about changing their data systems before complete 

guidance was issued. Furthermore, 6 of the 8 state officials were reluctant 

to say that their certified teachers might not be highly qualified because 

they believed it would harm teacher morale. Thus, we concluded that the 

survey data related to the number of highly qualified teachers would not 

likely be reliable. 

Both state and district officials cited many conditions that hinder their 

ability to have all highly qualified teachers. Many state officials reported 

issues related to teacher pay, such as low salaries, lack of incentive pay 

programs, and a lack of career ladders as hindrances. For example, 32 of 

the 37 state officials responding to our survey said that teacher salaries 

were low compared with other occupations. During our visits officials said 

that salary issues particularly hindered their efforts to recruit and retain 

math and science teachers. Twenty-three of the 37 state officials reported 

teacher shortages in high need subject areas—mostly math, science, and 

special education. During the late 1990s, there was an increase in demand 

for workers with math and science backgrounds, especially in information 

technology, and these occupations generally paid higher salaries than 

teaching. Other hindrances cited by state officials included few programs 

to support new teachers, a lack of leadership from principals, and union 

agreements. Our survey estimates show that salary issues were also 

hindrances for the majority of the districts, and about 20 percent of all 

districts cited teacher development conditions such as (1) weak 

technology training for teachers, (2) few alternative certification 

programs, and (3) professional development programs of too short a 

duration to improve teacher quality. In addition, significantly more highpoverty than low-poverty districts identified some conditions as 

hindrances, according to our survey responses. For example, an estimated 

30 percent of high-poverty districts compared to 6 percent of low-poverty 

districts cited few programs to support new teachers. Officials in rural 

districts we visited and who commented on the survey said they faced 
Page 4 GAO-03-631 No Child Left Behind 

unusual conditions because some of them were very small, isolated, or had 

only one or two teachers in total at some schools. While many of the 

hindrances that state and district officials reported could not be addressed 

by Education, at least half of the state survey respondents indicated that 

Education could be more helpful. Specifically, they said they needed more 

information on, or assistance with, professional development programs, 

best practices related to teacher quality, and incentives for teachers to 

teach in high-poverty schools. Education has identified several steps it will 

take in its 2002-07 strategic plan related to these issues. 

Title II provided funds to help meet the requirement for highly qualified 

teachers, and state survey respondents said they planned to spend most of 

their Title II funds on professional development activities while districts 

planned to spend the majority of their funds on recruitment and retention 

activities authorized under Title II. Generally, state educational agencies 

could use up to 2.5 percent of the state’s Title II funds for authorized state 

activities. State officials reported they planned to spend 65 percent on 

professional development activities. These activities could help teachers 

enhance their subject area knowledge and complete state licensing 

requirements to meet the criteria for highly qualified teachers. States 

planned to spend much larger amounts of other federal and state funds 

than Title II funds on authorized state activities. For example, states 

reported that 85 percent of the total funds they planned to spend on 

professional development activities would come from other federal and 

state funds. Districts received about 95 percent of their state’s Title II 

funds for authorized district activities. From our survey we estimated that 

districts planned to spend about two-thirds of their Title II funds on 

activities to help recruit and retain highly qualified teachers, with the 

remaining funds on activities for professional development. High-poverty 

districts planned to spend a larger percentage of Title II funds on 

recruitment and retention activities than low-poverty districts. For 

example, high-poverty districts planned to spend 77 percent of their Title 

II funds for recruitment and retention while low-poverty districts planned 

to spend 59 percent. Recruitment and retention activities, such as 

establishing incentive pay programs and reducing class sizes, could help 

attract more highly qualified teachers to schools. Survey results also show 

that districts planned to spend much larger percentages of other federal, 

state, and local funds than Title II funds on authorized Title II activities. 

For example, an estimated 80 percent of the total funds all districts 

planned to spend on professional development came from other federal, 

state, and local funds. During our visits, both state and district officials 

said that most activities were a continuation of those begun in previous 

years. 
Page 5 GAO-03-631 No Child Left Behind 

In order to help states meet the requirement for highly qualified teachers 

by the end of the 2005-06 school year, we recommend that the Secretary of 

Education provide more information on methods to evaluate subject area 

knowledge of current teachers. 

Education provided written comments on a draft of this report including 

information on the guidance for special education teachers that we 

incorporated as appropriate. Additionally, Education indicated that it 

plans to take steps to address our recommendation. Our evaluation of 

their comments is in the report and Education’s comments are in appendix 

IV. 

Recently, a body of research has shown that quality teachers are 

significant to improving student performance. For example, a 1996 study 

by Sanders and Rivers4

 examined the effect of teacher quality on academic 

achievement and found that children assigned to effective teachers scored 

significantly higher in math than children assigned to ineffective teachers. 

Research has also shown that many teachers, especially those in highpoverty and rural districts, were not certified and lacked knowledge of the 

subjects they taught. For example, a report from The Education Trust 

found that in every subject area, students in high-poverty schools were 

more likely than other students to be taught by teachers without even a 

minor in the subjects they teach.5

States are responsible for developing and administering their education 

systems and most have delegated authority for operating schools to local 

governments. States and local governments provide most of the money for 

public elementary and secondary education. In 2002, Education reported6

that 49 percent of the revenue for education was from state sources, 

44 percent from local sources, and 7 percent from federal sources. 

Therefore, it is mostly state and local funds that are used to cover most of 

the major expenses, such as teacher salaries, school buildings, and 

transportation. Although the autonomy of districts varies, states are 

 4

Sanders, W. and Rivers, J., Cumulative and Residual Effects of Teachers on Future 

Student Academic Achievement. Knoxville, TN: University of Tennessee Value-Added 

Research and Assessment Center, November, 1996. 

5

Kati Haycock, Closing the Achievement Gap (The Education Trust, March 2001). 

6

National Center for Education Statistics, U.S. Department of Education, The Condition of 

Education 2002. 

Background 
Page 6 GAO-03-631 No Child Left Behind 

responsible for monitoring and assisting their districts that, in turn, 

monitor and assist their schools. 

The federal government plays a limited but important role in education. 

The Department of Education’s mission is to ensure equal access to 

education and promote educational excellence throughout the nation by, 

among other things, supporting state and local educational improvement 

efforts, gathering statistics and conducting research, and helping to make 

education a national priority. Education provides assistance to help states 

understand the provisions or requirements of applicable laws, as well as 

overseeing and monitoring how states implement them. With the passage 

of the No Child Left Behind Act, on January 8, 2002, the federal 

government intensified its focus on teacher quality by establishing a 

requirement in the act for teachers across the nation to be “highly 

qualified” in every core subject they teach by the end of the 2005-06 school 

year.7

While the act contains specific criteria for highly qualified teachers by 

grade and experience levels, in general, the act requires that teachers: 

(1) have a bachelor’s degree, (2) have state certification, and 

(3) demonstrate subject area knowledge for each core subject they teach. 

Table 1 lists the specific criteria by grade and experience levels as defined 

in the act. 

 7

Title I of NCLBA requires that every state that accepts Title I funds must ensure that all 

their teachers meet the requirement. All states and the District of Columbia have accepted 

the funds. Title I of NCLBA is designed to help educate disadvantaged children—those with 

low academic achievement attending schools serving high-poverty areas. Title I was 

appropriated funding of over $10 billion in fiscal year 2002. 
Page 7 GAO-03-631 No Child Left Behind 

Table 1: Federal Criteria for a Highly Qualified Teacher 

Grade level and experience Federal criteria 

Any public elementary school or 

secondary school teacher. 

Has obtained full state certification as a teacher (including alternative certification) or 

passed the state teacher licensing examination and holds a license to teach in the state; 

however, when teaching in a charter school,a

 the teacher may not be certified or licensed if 

the state does not require it. Further, the teacher has not had certification or licensure 

requirements waived on emergency, temporary, or provisional basis. 

Elementary school teacher new to the 

profession. 

Holds at least a bachelor’s degree; and has passed a rigorous state test to demonstrate 

subject knowledge and teaching skills in reading, writing, math, and other areas of the 

basic elementary school curriculum (these tests may be included in state certification or 

licensing tests). 

Middle or secondary school teacher new 

to the profession. 

Holds at least a bachelor’s degree and has passed a rigorous state academic subject test 

in each of the academic subjects in which the teacher teaches (this may be the state 

certification or licensure test) or for each academic subject taught, the teacher has 

successfully completed an academic major, a graduate degree, coursework equivalent to 

an undergraduate academic major, or advanced certification or credentialing. 

Elementary, middle, or secondary teacher 

not new to the profession. 

Has met the above standards for new elementary, middle, and secondary school teachers 

or demonstrates competence in all the academic subjects in which the teacher teaches 

based on a high objective, uniform state standard of evaluation that (1) is set by the state 

for both grade appropriate academic subject matter knowledge and teaching skills; (2) is 

aligned with challenging state academic content and student academic achievement 

standards and developed in consultation with core content specialists, teachers, 

principals, and school administrators; (3) provides objective, coherent information about 

the teacher’s attainment of core content knowledge in the academic subjects a teacher 

teaches; (4) is applied uniformly to all teachers in the same academic subject and the 

same grade level throughout the state; (5) takes into consideration, but not be based 

primarily on, the time the teacher has been teaching in the academic subject; (6) is made 

available to the public upon request; and (7) may involve multiple, objective measures of 

teacher competency. 

Source: NCLBA, Pub.L. No. 107-110, section 9101(2002). 

a

Charter schools are public schools that are exempt from a variety of local and state regulations. 

For Title II, Part A of the act, Congress appropriated $2.85 billion to the 

Teacher and Principal Training and Recruiting Fund in fiscal year 

2002—about $740 million more than states received in fiscal year 

2001 under the previous two programs that it replaced—the Eisenhower 

Professional Development and Class Size Reduction programs. The 

purpose of the fund is to increase student academic achievement by 

providing support for states and districts to implement authorized 

activities cited in Title II to help them meet the requirement for highly 

qualified teachers. (See apps. II and III for state and district authorized 

activities.) 

States had to complete an application in order to receive funds. All 

applications were due by June 2002, and states received the funds by 

August 2002. The funds were to be distributed according to the formula 

defined in the act. Specifically, states and districts received an amount 
Page 8 GAO-03-631 No Child Left Behind 

equal to what they received for fiscal year 2001 under the two previous 

programs. The additional $740 million was distributed to states and 

districts based on the number of families with children ages 5 to 17 who 

had incomes below the poverty threshold8

 and the relative population of 

children ages 5 to 17. The act requires states to ensure that districts target 

funds to those schools that have the highest number of teachers who are 

not highly qualified, the largest class sizes, or have been identified as in 

need of improvement. 

To help states understand and implement the new law, Education took a 

number of actions. The department established a Web site, developed an 

application package for the formula grant program, issued draft guidance, 

and held informational conferences for states and districts. Figure 1 

summarizes Education’s assistance to states. 

 8

For 2002, the poverty threshold was $18,556 annually for a family of four. 
Page 9 GAO-03-631 No Child Left Behind 

Figure 1: Education’s Assistance to States During Calendar Year 2002 

In June 2002, Education issued draft guidance entitled “Improving Teacher 

Quality State Grants” which has served as Education’s principle form of 

assistance to states. In December of 2002, Education expanded and 

modified the draft guidance and issued final regulations on NCLBA that 

included some criteria related to the requirement for highly qualified 

teachers. Education does not plan to issue a final version of its draft 

guidance; instead, the draft includes the statement that it “should be 

viewed as a living document” that will be updated (1) as new questions 

arise, (2) if there is a change in the program statute that requires 

modification, or (3) when Education determines that more information 

would be helpful. 

Date Events

April NCLBA Web site went online

May

Title II, Part A draft guidance issued 

First Annual Teacher Quality Evaluation Conference held, during 

which the draft guidance was discussed

June

Regional conferences held, during which Education officials reviewed 

the authorized activities listed in Title II, Part A and the criteria for 

highly qualified teachers

October

Title II, Part A draft guidance reissued

Final Title I Regulations issued that provide highly qualified criteria for 

some categories of teachers including those who are currently 

teaching, newly hired and in alternative certification programs; with 

an appendix discussing requirements for special education teachers 

December

Final Rule issued on how to apply for Title II, Part A Funds

Source: GAO analysis.
Page 10 GAO-03-631 No Child Left Behind 

In-depth discussions with officials in 8 states revealed that they could not 

determine the number of highly qualified teachers with accuracy because 

of one or more factors. All state officials said they did not know the 

criteria for some of their teachers because Education’s draft guidance 

changed and was not complete. Officials also did not have all the 

information they needed to develop methods to evaluate subject area 

knowledge for their current teachers. Accordingly, officials in all of the 

states interviewed and nearly all surveyed said they needed complete and 

clear guidance before they could comply with the law. Most of the states 

we visited also did not have data systems that could track teacher 

qualifications by core subject taught, which they would have to do to 

ensure that teachers were teaching only those subjects for which they had 

demonstrated subject area knowledge. Finally, many state officials we 

visited were reluctant to say that their certified teachers might not be 

highly qualified. 

During our review, Education changed its criteria for teachers who were 

in alternative certification programs and it reissued the draft guidance to 

qualify only teachers in certain programs.9

 The revised draft guidance 

stated that only those teachers enrolled in alternative certification 

programs with specific elements, such as teacher mentors, would be 

considered highly qualified. As a result, state officials had to recount this 

group of teachers by determining which alternative certification programs 

met the standard and then which teachers participated in those programs. 

In one state we visited, there were about 9,000 teachers in alternative 

certification programs and all were considered highly qualified until the 

revised draft guidance was issued. As of May 2003, an official said she was 

still trying to determine the number of teachers who were highly qualified. 

Also during our review, state officials were uncertain about the criteria for 

special education teachers. The draft guidance that was available during 

most of our visits did not address special education teachers. As a result, 

state officials could not know, for example, whether a special education 

 9

Many states have alternate routes to certification, referred to here as alternative 

certification programs, that allow an individual who has a bachelor’s degree from a college 

or university but who does not hold a degree in education, to receive a license to teach. 

Alternative certification programs range from those that place people in classrooms 

immediately to longer programs that delay placing people in classrooms until they have 

completed course work and received a mentor. While these programs vary within and 

among states, nearly all states have some type of alternative to the traditional path of 

majoring in education in order to become a teacher. 

Many States Were 

Uncertain about 

Numbers of Highly 

Qualified Teachers 

States Did Not Have 

Complete or Consistent 

Criteria to Determine the 

Number of Highly 

Qualified Teachers 
Page 11 GAO-03-631 No Child Left Behind 

teacher teaching math and reading would have to demonstrate subject 

area knowledge in both or neither of the subjects. For school year 

1999-2000, special education teachers represented about 11 percent of the 

national teacher population,10 so that, on average, state officials were 

unable to determine whether at least a tenth of their teachers met the 

highly qualified criteria. In some districts, special education teachers 

represented a larger portion of the workforce. For example, in one highpoverty urban district that we visited, special education teachers were 

21 percent of their teachers. Education issued final Title I regulations on 

December 2, 2002, with an appendix that discussed the highly qualified 

requirements for special education teachers, among other things. 

However, the requirements are not discussed in the federal regulations nor 

are they discussed in the Title II draft guidance that was issued December 

19, 2002. In addition, as of March 2003 some officials still had questions 

about the requirements. Perhaps because the guidance was issued in an 

appendix, it was not given the prominence needed to ensure that all 

officials would be aware of the information. 

Furthermore, neither Education’s draft guidance nor its regulations 

provided more information than the law to help state officials develop 

methods other than tests to evaluate their current teachers’ subject area 

knowledge. The law allows states to use a “high, objective uniform state 

standard of evaluation” instead of a test. Education’s draft guidance 

repeated the language of the law, but provided no further interpretation. In 

addition, Education officials said they would review states’ 

implementation of this provision when they conduct compliance reviews 

and then determine if the state evaluation is in compliance with the law. 

State officials said they needed more information, such as examples, to be 

confident of what Education would consider adequate for compliance with 

the law. State officials prefer evaluations instead of tests, according to an 

official at the Council of Chief State School Officers (CCSSO), because 

they expect evaluations to be less expensive, more flexible, and more 

acceptable to teachers and unions. Such evaluations might be done 

through classroom observations, examination of portfolios, and peer 

reviews. In March 2003, CCSSO held a conference attended by about 

25 state officials and several Education officials to discuss the 

implementation of state evaluations. At that conference, state officials said 

 10National Center for Education Statistics, Schools and Staffing Survey, 1990-2000, 

“Number and Percent of Public School Special Education Teachers Who Teach Special 

Education Classes as Their Main Assignment or as Their Second Assignment” (2002). 
Page 12 GAO-03-631 No Child Left Behind 

Education’s lack of specificity was particularly a problem for evaluating 

middle and high school teachers who had not demonstrated subject area 

knowledge. According to our survey data, 23 of 37 state officials said they 

would have difficulty fulfilling the highly qualified requirement for middle 

school teachers and 14 anticipated difficulty for high school teachers. 

According to district survey results, 20 percent anticipated difficulties in 

meeting the federal criteria for middle school teachers and 24 percent for 

high school teachers. Furthermore, as table 2 shows, a significantly higher 

percentage of high-poverty districts reported they would have greater 

difficulty fulfilling the requirement for teachers, especially at the middle 

and high school levels, than would low-poverty districts. 

Table 2: Estimated Percentages of Districts That Will Have Difficulty Meeting the 

Requirement for Highly Qualified Teachers by Grade Level and Poverty 

Type of school All districts 

High-poverty 

districts 

Low-poverty 

districts

Elementary 7 18 4

Middle/junior high 20 35 13

High 24 46a 15

Source: GAO survey. 

a

The percentage estimate for high schools in high-poverty districts has a 95 percent confidence 

interval of plus or minus 11 percentage points. 

State officials from the 8 states we visited said they could not determine 

the number of highly qualified teachers because the draft guidance was 

changing, not clear, or incomplete. Most, 32 of 37, state officials 

responding to our survey said they needed clear and timely guidance to 

help them meet the law. 

Officials from 7 of the 8 states we visited told us they did not have data 

systems that would allow them to track teachers’ qualifications according 

to the federal criteria by every subject taught. Officials in one state 

projected that it would take at least 2 years before the state could develop 

and implement a system to track teachers by the federal criteria. State 

officials we visited said since their state certifications had not required 

some teachers to demonstrate subject area knowledge as required in the 

federal criteria, their information systems did not track such information. 

In written comments to our survey, for example, one official said, 

“Questions [related to counting teachers] are impossible to answer at this 

point because we not have finished the identification of those who need to 

be tested or evaluated.” Another respondent wrote that the data system 

State Data Systems Did 

Not Track Federal Criteria 
Page 13 GAO-03-631 No Child Left Behind 

“was designed years ago for state certification purposes...[and] has not yet 

been updated to include all NCLBA criteria for teachers.” Other state 

officials also told us during our visits and through survey comments that 

their state certifications did not always require teachers to demonstrate 

subject area knowledge, so they did not have information on many 

teachers’ qualifications for this criteria. Another state official wrote, “[We] 

do not have data on teachers who were grand fathered in before 1991 or 

from out of state... who do not have subject matter competency.” Given 

the cost and time they thought it would take, some state officials 

expressed reservations about changing their data systems before 

Education provided complete guidance. 

Officials in 6 of the 8 states visited were reluctant to report their certified 

teachers might not be highly qualified. Three of these officials equated 

their state certification with the federal criteria for a highly qualified 

teacher even though they differed. They expressed a reluctance to say that 

their state certification requirements did not produce a highly qualified 

teacher even though the requirements did not match all the federal 

criteria, such as demonstration of subject area knowledge. Additionally, 

state officials expressed concern about the morale of teachers who are 

state certified but who would not meet the federal criteria. They were also 

concerned about how teachers and unions would react to testing already 

certified teachers. For example, in 5 states we visited officials told us that 

the unions in these states objected to the testing of certified teachers. 

Many state officials responding to our survey reported that teacher salary 

issues and teacher shortages were hindrances. State officials also 

identified other conditions such as few programs to support new teachers, 

lack of principal leadership, teacher training, and union agreements. 

District officials also cited teacher salary and teacher development issues 

as conditions that hindered them. Our district survey also shows that 

significantly more high-poverty districts reported some conditions as 

hindrances than low-poverty districts, and rural districts officials we 

visited cited hindrances specific to their small size and isolated locations. 

In our state survey, officials indicated that they needed more information 

from Education on professional development programs, best practices, 

and developing incentives for teachers to teach in high-poverty schools. 

Some State Officials 

Reluctant to Report 

Teachers Not Highly 

Qualified 

State and District 

Officials Reported 

Many Conditions as 

Hindrances to 

Meeting the Law 
Page 14 GAO-03-631 No Child Left Behind 

Many state officials responding to our survey reported that pay issues 

hindered their ability to meet the requirement to have all highly qualified 

teachers. These issues included low salaries, lack of incentive pay 

programs, and a lack of career ladders for teachers. For example, 

32 of 37 state respondents said low teachers’ salaries compared to other 

occupations was a hindrance. Officials we visited said that because of the 

low salaries it has been more difficult to recruit and retain some highly 

qualified teachers, especially math and science teachers. Several 

occupations are open to people with a bachelor’s degree in math and 

science, such as computer scientists and geologists. During the late 

1990s, there was an increase in demand for workers with math and science 

backgrounds, especially in information technology occupations. Between 

1994 and 2001, the number of workers employed in the mathematical and 

computer sciences increased by about 77 percent while the number of 

teachers increased by about 28 percent and total employment increased by 

about 14 percent. Furthermore, the math and science occupations have 

generally paid higher salaries than teaching positions. The U.S. 

Department of Labor’s Bureau of Labor Statistics data indicate that in 

2001 average weekly earnings was $1,074 for mathematical and computer 

scientist positions and $730 for teachers. Some research shows that 

teacher salary is only one of many factors that influence teacher 

recruitment and retention. For example, the American Association of 

School Administrators explained the relationship between pay and 

working conditions in a report on higher pay in hard-to-staff schools.11 The 

report stated “How money matters becomes much clearer if salary is 

viewed as just one of many factors that employees weigh when assessing 

the relative attractiveness of any particular job, such as opportunities for 

advancement, difficulty of the job, physical working conditions, length of 

commute, flexibility of working hours, and demands on personal time. 

Adjusting the salaries upward can compensate for less appealing aspects 

of a job; conversely, improving the relative attractiveness of jobs can 

compensate for lower salaries.” 

Many state survey respondents also cited teacher shortages as a 

hindrance. Specifically, 23 of the 37 state officials reported teacher 

shortages in high-need subject areas—such as, math, science, and special 

 11Cynthia Prince, Higher Pay in Hard to Staff Schools: The Case for Financial Incentives, 

American Association of School Administrators, June 2002. 

State Officials Cited 

Several Problems as 

Hindrances 
Page 15 GAO-03-631 No Child Left Behind 

education.12 Additionally, 12 state officials reported a shortage in the 

number of new highly qualified teachers in subject areas that are not high 

need, and 12 reported that having few alternative certification programs 

hindered their efforts. Education experts have debated the causes and 

effects of teacher shortages. Some experts argue that the problem is not in 

the number of teachers in the pool of applicants but in their distribution 

across the country. Others argue that poor retention is the real cause of 

teacher shortages. As for alternative certification programs, they were 

established to help overcome teacher shortages by offering other avenues 

for people to enter the teaching profession. However, in 1 state we visited 

officials said the success of these programs had been mixed because the 

content and length of the programs varied and some alternative 

certification teachers were better prepared than others. 

Although states have been facing teacher shortages in some subject areas 

for years, the new requirement for highly qualified teachers could make it 

even more difficult to fulfill the demand for teachers. The new law 

requires states to ensure that teachers only teach subjects for which they 

have taken a rigorous state test or evaluation, completed an academic 

major or graduate degree, finished course work equivalent to such 

degrees, or obtained advanced certification or credentialing in the 

subjects. Previously, states allowed teachers to teach subjects without 

such course work or credentials. From its Schools and Staffing Survey,13

the National Center for Education Statistics, within the Department of 

Education, reported that in 1999-2000, 14 to 22 percent of students in 

middle grades and 5 to 10 percent of high school students taking English, 

math, and science were in classes taught by teachers without a major, 

minor, or certification in the subjects they taught. Also, the report 

indicated that in the high school grades, 17 percent of students enrolled in 

physics and 36 percent enrolled in geology/earth/space science classes 

were taught by out-of-field teachers. 

Some states also cited several other conditions that might hinder their 

ability to meet the requirement for highly qualified teachers. For example, 

 12In this report, when discussing a shortage of teachers in the high need subject area of 

special education, we are referring to a shortage of persons qualified to be special 

education teachers to teach core subjects to children with disabilities as defined in Section 

602 of the Individuals with Disabilities Education Act Amendments of 1997. 

13Department of Education, Qualifications of the Public School Teacher Workforce: 

Prevalence of Out-of-Field Teaching 1987-88 and 1999-2000, Statistical Analysis Report, 

Schools and Staffing Survey, National Center for Education Statistics, 2002. 
Page 16 GAO-03-631 No Child Left Behind 

13 of the 37 state respondents reported few programs to support new 

teachers,14 and 9 reported large classes as hindrances. State respondents 

also cited work environment factors such as teacher performance 

assessments, a lack of principal leadership, and lack of school supplies 

and equipment as hindrances. See table 3 for more information on 

hindrances reported by state officials. 

Additionally, 7 state officials who responded to our survey cited union 

agreements as a hindrance. Officials in 5 states that we visited said that the 

teachers’ unions objected to testing currently certified teachers for subject 

area knowledge, and officials in 2 of these states also said that current 

teachers might leave rather than take a test. An official representing the 

American Federation of Teachers (AFT), an organization that represents 

teachers, school support staff, higher education faculty and staff, among 

others, said that AFT supports the federal definition for highly qualified 

teachers and incentive pay for teachers in high-need subject areas and that 

certified teachers should have a choice between taking a test and having a 

state evaluation to determine subject area knowledge. The National 

Education Association, an organization with members who work at every 

level of education, issued an analysis of the NCLBA that identified several 

changes it believes should be made in the law, including clarifying the 

requirement for highly qualified teachers. The union officials we spoke 

with from 2 states we visited said they also support the requirement for 

highly qualified teachers but expressed concerns about how their states 

would implement the legislation. One state union official said the current 

state process for certification requires multiple tests—more than is 

required in the legislation—and the union is concerned that the state will 

collapse the testing and streamline the teacher preparation process as part 

of its changes to meet the requirement. The union official from the other 

state said that his union was concerned because the state’s approach for 

implementing the requirement for highly qualified teachers has become a 

moving target and this causes frustration for teachers. 

 14As provided in Title II of NCLBA, programs to support new teachers include teacher 

mentoring, team teaching, reduced class schedules, and intensive professional 

development. 
Page 17 GAO-03-631 No Child Left Behind 

Table 3: Number of States Reporting on Conditions That Hinder Their Ability to 

Meet the Requirement for Highly Qualified Teachers (Ranked from Highest to 

Lowest) 

Number of states 

reporting this 

condition to be a 

hindrancea (n=37) Condition 

32 Teachers’ salaries low compared to other occupations. 

23 

Shortage in the number of teachers who meet the Title II 

requirement for highly qualified teachers in subject areas where 

there is high need. 

21 Teachers’ salaries low compared to teachers elsewhere. 

18 Lack of incentive pay programs. 

17 Lack of a career ladder for teachers. 

14 

Professional development programs not of sufficient duration to 

have an effect on teacher quality. 

13 Few programs to support new teachers. 

12 Few alternative certification programs. 

12 

Shortage in the number of new teachers who meet the Title II 

requirement for highly qualified teachers in subject areas that are 

not high need. 

12 School lacks supplies and equipment. 

11 Lack of leadership on the part of principals. 

9 

College of Arts and Science Departments do not work with college 

Education Departments to develop teacher preparation programs. 

9 Large class sizes resulting in teacher retention problems. 

9 

Many currently employed teachers do not meet the Title II 

requirement for highly qualified teachers in areas that are not high 

need. 

 7 Teacher assessments not based on the Title II requirement for 

 highly qualified teachers. 

7 Weak training for teachers in the use of technology. 

7 Union agreements inhibit implementing activities encouraged by 

Title II to develop highly qualified teachers. 

7 Professional development programs not based on recent scientific 

research on teaching methods or subject matter. 

4 State certification requirements not meeting the Title II requirement 

for highly qualified teachers. 

3 Alternative certification programs not providing teachers with 

adequate teaching skills. 

3 Teacher preparation programs not aligned with state subject 

content standards. 

3 State and local laws and regulations inhibit implementing activities 

encouraged by Title II to develop highly qualified teachers. 

2 Teacher preparation programs not providing teachers with 

adequate subject matter expertise. 

Source: GAO survey. 

a

These numbers include states that reported these conditions as a moderate, great, or very great 

hindrance. 
Page 18 GAO-03-631 No Child Left Behind 

School district estimates from our survey show that, similar to state 

respondents, salary issues hinder districts’ efforts to meet the requirement 

for highly qualified teachers. Almost 60 percent of district officials cited 

low teacher salaries compared to other occupations as a hindrance, with a 

significantly higher number of high-poverty than low-poverty district 

officials reporting this as a hindrance. During our site visits to 4 rural 

districts, officials said that their salaries could not compete with salaries 

offered in other occupations and locations. One official said that pay in the 

rural districts was low compared to teacher salaries in surrounding states. 

Both state and district officials also said that these salary conditions affect 

the recruitment and retention of highly qualified teachers. 

Our survey estimates also show that conditions related to teacher 

development were hindering districts’ ability to meet the highly qualified 

teacher requirement. The conditions reported by districts included 

(1) weak training for teachers in the use of technology (28 percent), 

(2) few alternative certification programs (18 percent), and 

(3) professional development programs that are not of sufficient duration 

to improve teacher quality (23 percent). Weak training programs can leave 

teachers unprepared to deal with all the challenges of teaching and lead to 

job dissatisfaction. Table 4 provides estimates of the percentages of 

districts reporting conditions that hinder their ability to meet the 

requirement for highly qualified teachers. 

School Districts Reported 

Hindrances Similar to 

Those Reported by States 

and More High-Poverty 

Districts Reported Certain 

Hindrances 
Page 19 GAO-03-631 No Child Left Behind 

Table 4: Estimated Percentages of Districts Reporting on Conditions That Hinder 

Their Ability to Meet the Requirement for Highly Qualified Teachers (Ranked from 

Highest to Lowest) 

Percent of all 

districts 

reporting this 

condition to be 

a hindrancea

 Condition 

57 Teachers’ salaries low compared to other occupations. 

37 Teachers’ salaries low compared to teachers elsewhere. 

28 Training for teachers in the use of technology is weak. 

25 Lack of incentive pay programs. 

23 

Professional development programs not of sufficient duration to 

have an effect on teacher quality. 

19 

Shortage in the number of teachers who meet the Title II 

requirement for highly qualified teachers in subject areas where 

there is high need. 

18 

Teacher preparation programs not providing teachers with adequate 

subject matter expertise. 

18 Few alternative certification programs. 

17 

College of Arts and Science Departments not working with college 

Education Departments to develop teacher preparation programs. 

16 

Alternative certification programs not providing teachers with 

adequate teaching skills. 

16 Few programs to support new teachers. 

16 Lack of a career ladder for teachers. 

16 

Shortage in the number of new teachers who meet the Title II 

requirement for highly qualified teachers in low achieving schools. 

15 

Teacher preparation programs not aligned with state subject content 

standards. 

14 School lacks supplies and equipment. 

12 

Teacher assessments not based on the Title II requirement for 

highly qualified teachers. 

10 

Union agreements that inhibit implementing activities encouraged by 

Title II to develop highly qualified teachers. 

7 Lack of leadership on the part of principals. 

7 Large class sizes resulting in teacher retention problems. 

7 

Professional development programs not based on recent scientific 

research on teaching methods or subject matter. 

7 

State certification requirements not meeting the Title II requirement 

for highly qualified teachers. 

6 

Many currently employed teachers not meeting the Title II 

requirement for highly qualified teachers in areas that are not high 

need. 

4 

State and local laws and regulations inhibit implementing activities 

encouraged by Title II to develop highly qualified teachers. 

Source: GAO survey. 

a

These percentages include districts that reported these conditions as a moderate, great, or very 

great hindrance. 
Page 20 GAO-03-631 No Child Left Behind 

While the ranking of most of the hindrances reported by districts and 

states were similar, three conditions were reported among the top third of 

hindrances for districts but among the bottom third for states. Specifically, 

these conditions were (1) alternative certification programs do not provide 

teachers with adequate teaching skills, (2) teacher preparation programs 

do not provide teachers with adequate subject matter expertise, and 

(3) training for teachers in the use of technology is weak. The first two of 

these conditions relate to programs that are usually responsibilities of the 

state departments of education. States or districts can address the third 

condition, technology training. These conditions indicate areas in which 

states and districts can work together to improve programs and help meet 

the requirement for highly qualified teachers. 

A significantly higher number of high-poverty districts than low-poverty 

districts identified some conditions as hindrances. As table 5 shows, in 

addition to teacher shortages and pay issues, a larger percentage of highpoverty districts cited few programs to support new teachers and few 

alternative certification programs, among others, as hindrances to meeting 

the requirement. 
Page 21 GAO-03-631 No Child Left Behind 

Table 5: Estimated Percentages of High- and Low-Poverty Districts with Significant 

Differences in the Hindrances to Meeting the Requirement 

Condition 

Percent of 

high-poverty 

districts

Percent of 

low-poverty 

districts

Teachers’ salaries are low compared to other 

occupations. 75 50

Teachers’ salaries are low compared to teachers 

elsewhere. 57 33

Lack of incentive pay programs. 32 17

Few programs to support new teachers. 30 6

Shortage in the number of teachers who meet the 

Title II requirement for highly qualified teachers in 

subject areas where there is a high need. 29 13

Shortage in the number of new teachers who meet 

the Title II requirement in low achieving schools. 26 10

Lack of career ladder for teachers. 25 8

Few alternative certification programs. 24 11

Teacher preparation programs do not provide 

adequate subject matter expertise. 24 13

Many currently employed teachers do no meet the 

Title II requirement in areas that are not high need. 13 4

Large class sizes resulting in teacher retention 

problems. 12 4

Lack of leadership on the part of principals. 12 3

Source: GAO survey. 

Note: Each difference between high- and low-poverty districts in this table is significant at the 95 

percent confidence interval. 

During our site visits, officials from high-poverty districts told us they had 

great difficulty retaining teachers. For example, officials in one district 

said that although the district provided training for new teachers in the 

skills they needed, these teachers became more marketable after they 

completed the training and often left for higher paying teaching positions. 

According to these officials, the schools in this district did not always 

benefit from the district’s training programs. High-poverty district officials 

also said they could not compete with surrounding, wealthier districts in 

teacher pay. Officials in these districts and at the American Association of 

School Administrators also said that some unions do not support the use 

of incentive pay for high-poverty schools because they believe that salary 

scales should be equal for all schools within a district. 

Rural district officials we visited and also those who provided survey 

comments said they faced unusual hindrances because some of them were 

very small, isolated, or had only one or two teachers in total at some 

schools. During our site visits, some officials from rural districts also said 
Page 22 GAO-03-631 No Child Left Behind 

that they were facing teacher shortages because not enough teachers were 

willing to teach in rural districts. For example, one official in a large, rural 

state said that the state had only one university, which makes it difficult 

for teachers to obtain further course work to meet the federal criteria for 

subject area knowledge. Since many teachers in this state’s rural districts 

had to teach more than one core subject, with limited access to subject 

area training, they may not meet the highly qualified criteria for all 

subjects they teach. One survey respondent also wrote, “Rural schools 

have to assign teachers to several subject areas at [the] secondary level. 

We do not have large numbers of students, and teachers have to wear 

more than one hat. Rural schools are also a long way from colleges and to 

require licensure in every subject they teach is ludicrous.” In a 2001 report 

to Congress, Education estimated that 84 percent of 4-year institutions 

would offer distance education courses15 in 2002. Such courses may help 

address this hindrance. 

As districts work to address the conditions that affect their ability to meet 

the new federal requirement, they look to their state officials for guidance 

and technical assistance. In turn, states look to Education for help. Many 

of the hindrances that state and district officials reported related to 

conditions that they could address such as teachers’ salaries, the number 

of alternative certification programs, and certification requirements. 

However, states indicated they needed some additional information and 

assistance from Education. At least half of the 37 state respondents 

reported needing (1) information or other assistance to meet the 

requirement that professional development programs be based on recent 

scientific research and be of sufficient duration to have an effect on 

teacher quality, (2) information on best practices in the area of teacher 

quality, and (3) assistance in developing incentives for teachers to teach in 

high-poverty schools. Education’s 2002-07 strategic plan identifies several 

steps it will take to work with states. Specifically, the strategies listed 

under the plan’s goal for improving teacher and principal quality include 

supporting professional development in research-based instruction and 

encouraging innovative teacher compensation and accountability systems. 

Additionally, in December 2002, Education reorganized and established a 

new office to administer the Title II program. 

 15The Higher Education Act defines distance education as an educational process where 

the student is separated in time or place from the instructor. 

States Say They Need 

More Information from 

Education and Education 

Plans to Work with States 

on Some Issues 
Page 23 GAO-03-631 No Child Left Behind 

To help meet the requirement for highly qualified teachers, state officials 

planned to spend most of their Title II funds on professional development 

activities, and district officials planned to spend a majority of their Title II 

funds on recruitment and retention activities. State and district officials 

planned to spend much larger amounts of other federal,16 state, and local 

funds than Title II funds on the activities authorized in the act. Generally, 

state and district officials told us they were continuing activities from 

previous years. The survey data also indicated high-poverty districts relied 

more on Title II funds for recruitment and retention activities than lowpoverty districts. In addition, while the act requires districts to target their 

Title II funds to schools that meet certain criteria, until district officials 

know the number of highly qualified teachers and where they are located, 

they cannot fully comply with this requirement. 

Generally, state educational agencies could use up to 2.5 percent of the 

state’s Title II funds for authorized state activities. 17 Twenty-four state 

officials responding to our survey planned to spend about 65 percent of 

their Title II funds on professional development activities to develop and 

support highly qualified teachers and principals. For example, professional 

development activities could help teachers enhance their subject area 

knowledge and complete state licensing requirements to meet the criteria 

for highly qualified teachers. During our site visits, state officials described 

their professional development activities as seminars, conferences, and 

various instructional initiatives. For example, in one state we visited, 

officials planned to hold a workshop to provide middle and high school 

math teachers with technology training so that they could incorporate 

interactive Web sites in their instruction. Generally, state officials said 

 16For example, districts must use 5 to 10 percent of their Title I-A funds in fiscal years 2002 

and 2003 for professional development activities to ensure that teachers become highly 

qualified. 

17State education agencies receive 5 percent of the total grant funds and can retain up to 1 

percent of these funds for administrative costs. Of the remaining funds, 2.5 percent must be 

spent on subgrants to eligible partnerships and the remaining funds are to be used for 

authorized activities. We grouped the Title II activities into five categories: (1) 

accountability, (2) certification, (3) professional development, (4) recruitment and 

retention, and (5) technical assistance. Appendix II lists all 18 activities. 

To Help Teachers 

Meet the Requirement 

States Planned to 

Spend Most Title II 

Funds on Professional 

Development 

Activities, and 

Districts Will Spend 

Most on Recruitment 

and Retention 

Activities 

States Planned to Spend 

the Majority of Title II 

Funds on Professional 

Development 
Page 24 GAO-03-631 No Child Left Behind 

they planned to use Title II funds to continue activities that were begun in 

previous years. 

While professional development activities were to receive the largest share 

of funds, survey results show state officials planned to also spend Title II 

funds on other activities cited in the act. Officials in 28 states planned to 

spend about 18 percent on technical assistance activities, such as 

providing information about the requirement for highly qualified teachers 

to districts via the state Web site. Certification activities received the 

smallest percentage of Title II funds–2 percent. These activities include 

efforts to promote certification reciprocity with other states and efforts to 

establish, expand, or improve alternative routes for certification. (See fig. 

2.) 

Figure 2: Planned Spending of Title II Funds by Reporting States 

State officials reported they planned to spend much larger amounts of 

other federal and state funds than Title II funds on nearly all of the 

authorized Title II activities. For example, states reported that 85 percent 

of the total funds they planned to spend on professional development 

activities would come from other federal and state funds. The one 

exception was technical assistance activities, where Title II funds 

Title II Funds Are a Small 

Part of Total Funds 

2%

Certification

6%

9%

18% 65%

Recruitment and retention

Accountability

Technical assistance

Professional development

Source: The 37 states that responded to GAO survey.
Page 25 GAO-03-631 No Child Left Behind 

accounted for 77 percent of the total. (See fig. 3.) Providing technical 

assistance to districts is an important role for states. In our visits to 

districts, several officials said they needed more information and technical 

assistance from their state to understand and implement the law. 

Figure 3: Sources of Funds for Planned Spending by States on Title II Activities 

Districts received about 95 percent of their state’s Title II funds for 

authorized activities.18 Based on our survey, district officials planned to 

spend an estimated 66 percent of their Title II funds on recruitment and 

retention activities and 34 percent on activities related to professional 

development. Class size reduction activities were the largest funded 

recruitment and retention activity and accounted for 56 percent of total 

Title II funds. In a majority of our site visits we learned that district 

officials used these funds to hire additional highly qualified teachers to 

 18Districts are to spend their Title II funds on 9 authorized activities that we grouped into 

2 categories: (1) professional development and (2) recruitment and retention. Appendix III 

lists all 9 activities. 

Districts Planned to Spend 

a Majority of Their Title II 

Funds on Recruitment and 

Retention Activities 

Percent of planned spending on activities

0

10

20

30

40

50

60

70

80

90

100

Accountability

6

94

5

95

15

85

13

87

77

23

Title II funds

Other federal and state funds

Certification Professional

development

Recruitment

and retention

Technical

assistance

Source: The 37 states responding to GAO survey.
Page 26 GAO-03-631 No Child Left Behind 

continue activities developed under the previous Class Size Reduction 

Program. Class size reduction activities may help improve teacher 

retention because, according to an Education report,19 teachers in small 

classes spend less time on classroom management and more time 

providing instruction, thus raising the teacher’s level of job satisfaction. 

While class size reduction activities can be seen as a retention tool, they 

may also increase the number of highly qualified teachers that need to be 

hired. This may be a problem for some districts and states. In fact, officials 

in one large state we visited said class size reduction activities presented a 

challenge by increasing the number of classes not being taught by a highly 

qualified teacher. 

Additionally, district officials in our site visits said that they implemented 

or planned to implement a broad range of professional development 

activities. For example, one district had a teacher-coach program for its 

math and science teachers. This program used senior teachers as full-time 

coaches to assist less experienced teachers with instructional strategies 

and curriculum preparation. Other programs focused on math and reading, 

varied instructional strategies for different types of students, and use of 

technology. District officials in our site visits said most activities were in 

place prior to the act. 

While all districts spent more on recruitment and retention activities than 

professional development, there were differences between high- and lowpoverty districts. From our survey, we estimate that high-poverty districts 

planned to spend a significantly larger percentage of Title II funds on 

recruitment and retention and a smaller percentage on professional 

development activities than low-poverty districts. (See table 6.) 

Table 6: Estimated Percent of Spending Title II Funds by Activities for All Districts, 

High-Poverty Districts, and Low-Poverty Districts 

Activity All districts

All high-poverty 

districts 

All low-poverty 

districts

Professional development 

activities 34 23 41 

Recruitment and 

retention/class size reduction 66 77 59 

Source: GAO survey. 

 19U. S. Department of Education, The Class-Size Reduction Program: Boosting Student 

Achievement in Schools Across the Nation, A First-Year Report, September 2000. 
Page 27 GAO-03-631 No Child Left Behind 

Note: Each difference between high- and low-poverty districts in this table is significant at the 

95 percent confidence interval. 

From our survey, we estimated all districts planned to spend much larger 

percentages of other federal, state, and local funds than Title II funds on 

authorized activities but in high-poverty districts the share of the funds 

was lower. Overall, 80 percent of the total funds districts planned to spend 

on professional development activities came from other federal, state, and 

local funds. Title II funds represented a larger percentage of total funds 

spent on authorized activities for high-poverty districts than low-poverty 

districts. For example, in high-poverty districts Title II funds were 

48 percent of the funds they planned to spend for recruitment and 

retention activities compared to 15 percent in low-poverty districts. There 

may be several reasons for these differences. For example, Title II 

allocated more funds to those districts with more high-poverty families, 

and low-poverty districts may have had more local funds to contribute to 

the total. Figure 4 shows the Title II percentage of total funds for 

professional development activities and recruitment and retention 

activities, for all, high-poverty, and low-poverty districts. A majority of 

district officials said they planned to fund activities that were begun in 

previous years. 

Districts Planned to Spend 

Larger Amounts of Other 

Funds and Title II Funds 

Are a Larger Percentage of 

Total for High-Poverty 

Districts 
Page 28 GAO-03-631 No Child Left Behind 

Figure 4: Estimated Spending of Title II Funds as a Percentage of Total Funds by 

Activities for All Districts, High-Poverty Districts, and Low-Poverty Districts 

We estimated about one-third of all districts (34 percent) were targeting 

their Title II funds as required by the act. The act requires districts to 

target funds to those schools (1) with the highest number of teachers who 

are not highly qualified, (2) with the largest class sizes, or (3) in need of 

improvement. There was little difference between the percentages of highand low-poverty districts that targeted their funds or between urban and 

rural districts. For example, 29 percent of high-poverty districts and 

30 percent of low-poverty districts reported targeting some of their Title II 

funds. Additionally, some district officials we visited said they did not 

target funds according to the criteria listed in the act but that they targeted 

funds in other ways such as to support math and science programs for 

teachers and for administrative leadership programs. It may be too early 

for district officials to fully implement this targeting requirement. Until 

they know the true number of teachers who are highly qualified, they 

cannot target the schools with the highest numbers of teachers who are 

not highly qualified. 

Approximately One-Third 

of All Districts Were 

Targeting Funds 

Title II percentage of total funds

0

5

10

15

20

25

30

35

40

45

50

Professional

development

Recruitment

and retention

All districts

All high-poverty districts

All low-poverty districts

20 21

15

28

48

15

Source: GAO district survey.
Page 29 GAO-03-631 No Child Left Behind 

Education officials have had to interpret and help states implement many 

new requirements established by the NCLBA, including the highly qualified 

teacher requirement. During this first year of implementation, state 

officials were still determining how they could assess whether their 

teachers met all the criteria and identifying steps they needed to take to 

meet the new requirement. Generally, state and district officials continued 

to be challenged by many longstanding hindrances and they continued to 

fund activities from previous years. 

Education issued regulations and draft guidance to help states begin to 

implement the requirement for highly qualified teachers and has plans to 

help states with some of their challenges. However, state officials need 

more assistance from Education, especially about methods to evaluate 

current teachers’ subject area knowledge. Without this information state 

officials are unsure how to assess whether their current teachers meet the 

highly qualified requirement. This would also help them accurately 

determine the number of teachers who are highly qualified and take 

appropriate steps, such as deciding on which activities to spend Title II 

funds and targeting Title II funds to schools with the highest numbers of 

teachers who are not highly qualified. It is important that states have the 

information they need as soon as possible in order to take all necessary 

actions to ensure that all teachers are highly qualified by the 2005-06 

deadline. 

In order to assist states’ efforts to determine the number of highly qualified 

teachers they have and the actions they need to take to meet the 

requirement for highly qualified teachers by the end of the 2005-06 school 

year, we recommend that the Secretary of Education provide more 

information to states. Specifically, information is needed about methods to 

evaluate subject area knowledge of current teachers. 

We received written comments on a draft of this report from Education. 

These comments are reprinted in appendix IV. In response to our 

recommendation related to requirements for special education teachers, 

Education stated that the appendix of the Title I Final Regulations clarifies 

how the highly qualified requirements apply to special education teachers. 

Consequently, we modified the report to reflect this information and we 

withdrew this recommendation. 

Education indicated it plans to take steps to address our recommendation 

on the need for information about methods to evaluate subject area 

Conclusions 

Recommendation for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 30 GAO-03-631 No Child Left Behind 

knowledge of current teachers. Education stated that it will continue to 

work with state officials and will actively share promising strategies and 

models for “high objective uniform State standard of evaluation” with 

states to help them develop ways for teachers to demonstrate subject area 

competency. 

Also, Education commented that it views a “one–size fits all” approach to 

addressing many of the issues raised in the report as undesirable because 

states and districts will have to meet the requirement highly qualified 

teachers in a manner that is compatible with their teacher certification, 

assessment and data collection processes. Education stated that it will 

provide assistance wherever possible to help states meet the requirement. 

We generally agree that this is an appropriate approach. 

Additionally, Education provided technical comments and we made 

changes as appropriate. 

We are sending copies of this report to appropriate congressional 

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

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

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

http://www.gao.gov. If you have any questions about this report, please 

call me at (202) 512-7215. Key contributors are listed in appendix V. 

Marnie S. Shaul, Director 

Education, Workforce, and 

 Income Security Issues 
Appendix I: Scope and Methodology 

Page 31 GAO-03-631 No Child Left Behind 

In conducting our work, we administered a Web survey to the 50 states 

and the District of Columbia, and a separate Web survey to a nationally 

representative sample of 830 school districts, that included strata for highpoverty, low-poverty, rural, and urban districts. The response rate for the 

state survey was 71 percent and for the district survey 62 percent. The 

surveys were conducted between December 4, 2002, and April 4, 2003. We 

analyzed the survey data and identified significant results. See figure 5 for 

a geographic display of responding and nonresponding states. 

Figure 5: State Survey Respondents 

The study population for the district survey consisted of public school 

districts contained in the Department of Education’s Core of Common 

Data (CCD) Local Education Agency (LEA) file for the 2000-2001 school 

year. From this, we identified a population of 14,503 school districts in the 

50 states and the District of Columbia. 

Appendix I: Scope and Methodology 

Source: The 37 states that responded to GAO survey.

Did not complete survey (14)
Appendix I: Scope and Methodology 

Page 32 GAO-03-631 No Child Left Behind 

Sample Design. The sample design for this survey was a stratified sample 

of 830 LEAs in the study population. This sample included the 100 largest 

districts and a stratified sample of the remaining districts with strata 

defined by community type1

 (city, urban, and rural) and by the district’s 

poverty level.2

 Table 7 summarizes the population, sample sizes, and 

response rates by stratum. 

Table 7: Population and Sample by Stratum 

Stratum 

number Description 

Districts in 

population

Districts in 

sample 

Districts 

responding

Response 

rate

1 Largest 100 districts 100 100 64 64%

2 City, low poverty 648 120 76 63%

3 City, high poverty 210 94 35 37%

4 Urban, low poverty 5,264 135 87 64%

5 Urban, high poverty 648 120 79 66%

6 Rural, low poverty 6,515 135 87 64%

7 Rural, high poverty 1,118 126 83 66%

Total 14,503 830 511 62%

Source: GAO analysis of Education’s 2000-1 CCD data 

Estimates. All estimates produced from the district sample in this report 

are for a target population defined as all public school districts in the 

50 states and the District of Columbia for the 2002-03 school year. 

Estimates to this target population were formed by weighting the survey 

data to account for both the sample design and the response rates for each 

stratum. For our estimates of high- and low-poverty districts, we defined 

high-poverty districts as those with participation rates in the free and 

 1

“City” is defined as a central city of Consolidated Metropolitan Statistical Area (CMSA) or 

as a central city of a Metropolitan Statistical Area (MSA). “Urban” refers to Urban Fringe 

(an incorporated place, Census Designated Place, or nonplace territory within a CMSA or 

MSA of a city and defined as urban by the Census Bureau), to a large town (an 

incorporated place or Census Designated Place with a population greater than or equal to 

25,000 and located outside a CMSA or MSA), or to an incorporated place or Census 

Designated Place with a population less than 25,000 and greater than 2,500 located outside 

a CMSA or MSA. A “rural community” is any incorporated place, Census Designated Place, 

or nonplace territory designated as rural by the Census Bureau. 

2

Poverty level was not available on the CCD data files; however, as a proxy for poverty, we 

stratified based on participation in the free/reduced student meals program. For sample 

selection, high-poverty districts are those districts having at least 60 percent participation 

in free/reduced meals programs. Less than 60 percent participation in this program 

identifies a district as a low-poverty district for stratification purposes. 
Appendix I: Scope and Methodology 

Page 33 GAO-03-631 No Child Left Behind 

reduced meals program of 70 percent or above. Low-poverty districts were 

defined as those with free and reduced meals program rates at 30 percent 

and below. One of the advantages of this approach was that it allowed for 

a sufficient number of cases in each category to conduct statistical 

analyses. 

Sampling Error. Because we surveyed a sample of school districts, our 

results are estimates of a population of school districts and thus are 

subject to sampling errors that are associated with samples of this size and 

type. Our confidence in the precision of the results from this sample is 

expressed in 95 percent confidence intervals. The 95 percent confidence 

intervals are expected to include the actual results for 95 percent of the 

samples of this type. We calculated confidence intervals for our study 

results using methods that are appropriate for a stratified, probability 

sample. For the percentages presented in this report, we are 95 percent 

confident that the results we would have obtained if we had studied the 

entire study population are within plus or minus 10 percentage points of 

our results, unless otherwise noted. For example, we estimate that 

34 percent of the districts target at least some funds to specific types of 

schools. The 95 percent confidence interval for this estimate would be no 

wider than plus or minus 10 percent, or from 24 percent to 44 percent. 

Nonsampling Error. In addition to these sampling errors, the practical 

difficulties in conducting surveys of this type may introduce other types of 

errors, commonly referred to as nonsampling errors. For example, 

questions may be misinterpreted, the respondents’ answers may differ 

from those of districts that did not respond, or errors could be made in 

keying questionnaire data. We took several steps to reduce these errors. 

To minimize some of these errors, the state and district questionnaires 

were each pretested three times to ensure that respondents would 

understand the questions and that answers could be provided. To increase 

the response rate, sampled districts received two calls encouraging them 

to complete and return the questionnaire. 

We also performed an analysis to determine whether some sample-based 

estimates compared favorably with known population values.3

 We 

performed this analysis for 12 estimates providing information on 

 3

This was possible because the CCD population file contains certain data elements for the 

universe of districts from which we drew our sample. 
Appendix I: Scope and Methodology 

Page 34 GAO-03-631 No Child Left Behind 

students, teachers, number of schools, and administrators that covered 

major segments those groups. For example, we did an analysis on all fulltime equivalent classroom teachers but not on teachers of ungraded 

students, which is a very small proportion of all teachers. We used these 

values for the 511 sample respondents to produce sample estimates to the 

total population of all 14,503 districts. These estimated values, their 

associated 95 percent confidence intervals, and their true population 

values are presented in table 8. 

Table 8: Sample Estimates Compared to Population Values 

Description of estimate 

Mean per district 

estimated from 

survey 

respondents

Lower bound of 95 

percent confidence 

interval

Upper bound

of 95 percent 

confidence interval

Mean per district 

for population

Students with Individualized Education Programs 455.6 391.8 519.5 424.8

Full-time equivalent classroom teachers 186.0 157.8 214.2 180.8

Students in Pre-Kindergarten to 12th grade 3,306.8 2,851.2 3,762.3 3,168.1

Total diploma recipients 198.5 169 227.9 201.4

Limited English proficient students 268.9 210.5 327.3 340.9

Schools in district 6.7 5.9 7.5 6.2

Local Education Authority administrators 4.2 3.6 4.8 3.7

LEA support staff 11.8 9.8 13.9 10.9

School administrators 10.4 8.9 11.9 9.7

School administrative support staff 17.3 14.6 19.9 16.5

Student support services staff 10.8 9.3 12.2 10.6

Instructional coordinators and supervisors 2.9 2.2 3.6 2.5

Source: GAO analysis of Education’s 2000-1 CCD data 

Note: LEAs are also known as school districts. 

For 11 out of the 12 estimates we examined, the population value falls 

within the 95 percent confidence interval for the estimate, thus providing 

some indication that respondents to this survey reflect the 

12 characteristics we examined in the population. Although these 

characteristics were selected because they might be related to other 

characteristics of district teachers and district administration, we do not 

know the extent to which the survey respondents would reflect the 

population characteristics for the specific questions asked on our survey. 

For example, we are not certain whether districts responding to the survey 

were further along in the implementation of Title II requirements than the 

districts that did not respond. 
Appendix I: Scope and Methodology 

Page 35 GAO-03-631 No Child Left Behind 

Our sample was not designed to produce geographical area estimates, and 

we did not explicitly stratify our sample by state or region. However, our 

sample was selected nationally and all regions are represented in our 

sample. The following table summarizes sample size and responses for 

10 regions. 

Table 9: Population and Sample by Region 

Region 

number State in each region 

Districts in 

population 

Districts in 

sample

Districts 

responding

1 CT, ME, MA, NH, RI, and VT 1,079 42 25

2 NY and NJ 1,281 49 27

3 DE, DC, MD, PA, VA, and WV 731 41 26

4 AL, FL, GA, KY, MS, NC, SC, and TN 1,049 113 76

5 IL, IN, MI, MN, OH, and WI 3,413 179 111

6 AR, LA, NM, OK, and TX 2,061 144 100

7 IA, KS, MO, and NE 1,744 54 30

8 CO, MT, ND, SD, UT, and WY 1,111 42 32

9 AZ, CA, HI, and NV 1,375 135 62

10 AK, ID, OR, and WA 659 31 22

Total 14,503 830 511

Source: 

Note: for this table, we adopted the Department of Education’s region definitions as provided at 

http://www.ed.gov/offices/OIIA/Regions. 

On the basis of the national distribution of our sample and on the result of 

our comparison of a set of survey estimates to known population values 

from the CCD file, we chose to include the survey results in our report and 

to produce sample based estimates to the total population of school 

districts in our study population. 

We chose not to report the survey responses to questions asking about the 

number of highly qualified teachers because other information from the 

survey and our in-depth discussions with officials during our site visits 

indicated that the respondents could not accurately answer the question. 

For example, three of five officials who completed the survey but did not 

answer this question commented in the survey that they could not answer 

because they could not count the number of teachers. Additionally, one 

official who reported that 100 percent of the teachers were highly qualified 

and another who reported 94 percent, also commented that they were 

unable to count their teachers. During our site visits we learned that 

officials did not have know the criteria for some groups of teachers, did 

not have data systems to allow them to track teachers by class and 
Appendix I: Scope and Methodology 

Page 36 GAO-03-631 No Child Left Behind 

therefore, could not accurately determine how many teachers were highly 

qualified. 

We also visited 8 states with a range of characteristics that might affect 

their meeting Title II requirement for highly qualified teachers. Those 

states were California, Connecticut, Illinois, Iowa, Maryland, North 

Carolina, Delaware, and Wyoming. We visited and interviewed officials in 

2 districts in each state, one of which was a high-poverty district, and one 

school in each district. We interviewed Department of Education officials, 

and officials and representatives from several professional organizations. 

We also reviewed the legislation, the regulations, and guidance as well as 

related reports and other relevant documents. We conducted our work 

between July 2002 and May 2003 in accordance with generally accepted 

government auditing standards. 

Other Methodology 
Appendix II: Activities on Which States Can 

Spend Title II, Part A Funds 

Page 37 GAO-03-631 No Child Left Behind 

Table 10 lists our summaries of the authorized activities on which states 

can spend Title II funds and shows the five categories we used to group 

them. 

Table 10: Title II, Part A State Activities 

Category Activity 

Accountability 1. Developing systems to measure the effectiveness of professional development programs and 

strategies to document improvements in students’ academic achievement. 

 2. Ensuring that teachers use challenging state academic content standards, assessments, and 

student achievement standards to improve their teaching practices and their students’ achievement.

Certification 3. Reforming teacher and principal certification. 

 4. Reforming tenure and implementing tests for subject matter knowledge. 

 5. Promoting license and certification reciprocity agreements with other states for teachers and 

principals. 

 6. Providing programs that establish, expand, or improve alternative routes for state certification, 

especially for highly qualified individuals in the areas of mathematics and science. 

Professional development 7. Conducting programs that provide support to teachers, such as those that provide teacher 

mentoring 

and use assessments that are consistent with student academic achievement standards. 

 8. Providing professional development for teachers and principals. 

 9. Developing or assisting local educational agencies (LEAs) in developing and using, proven 

innovative strategies for intensive professional development programs that are both cost effective 

and easily accessible. 

 10. Encouraging and supporting the training of teachers and administrators to integrate technology into 

curricula and instruction, including training to improve their ability to use data to improve their 

teaching. 

 11. Providing assistance to teachers to enable them to meet certification, licensing, or other Title II 

requirements needed to become highly qualified. 

Recruitment and retention 12. Developing or assisting LEAs to develop, merit-based performance systems and strategies that 

provide pay differentials and bonus pay for teachers in academic subjects in which there is high 

need. 

 13. Developing projects and programs to encourage men to become elementary teachers. 

 14. Establishing and operating a statewide clearinghouse and programs for the recruitment, placement, 

and retention of teachers. 

 15. Assisting LEAs and schools in recruiting and retaining highly qualified teachers, including 

specialists in core subjects. 

 16. Developing or assisting LEAs to develop, teacher advancement initiatives that promote professional 

growth, and emphasize multiple career paths and pay differentiation. 

Technical assistance 17. Fulfilling the state agency’s responsibility to properly and efficiently carry out the administration of 

programs, including providing technical assistance to LEAs. 

 18. Assisting LEAs to develop and implement professional development programs and school 

leadership academies for principals and superintendents. 

Source: NCLBA Pub.L. No. 107-110, section 2113 (2002). 

Appendix II: Activities on Which States Can 

Spend Title II, Part A Funds 
Appendix III: Activities on Which Districts 

Can Spend Title II, Part A Funds 

Page 38 GAO-03-631 No Child Left Behind 

Table 11 lists our summaries of the authorized activities on which districts 

can spend Title II funds and shows the two categories we used to group 

them. 

Table 11: Title II, Part A District Activities 

Category Activity 

Professional development 1. Providing professional development activities for 

teachers and principals that improve their knowledge 

of their core subjects and effective instructional 

strategies. 

 2. Carrying out professional development activities 

designed to improve the quality of principals and 

superintendents . 

 3. Carrying out teacher advancement initiatives to 

promote professional growth and to emphasize 

multiple career paths and pay differentiation. 

 4. Carrying out programs and activities that are designed 

to improve the quality of teachers, such as 

professional development programs, merit pay 

programs, and testing teachers in the subjects they 

teach. 

Recruitment and retention 5. Developing and implementing mechanisms to assist 

schools in effectively recruiting and retaining highly 

qualified teachers and principals. 

 6. Developing and implementing initiatives to retain 

highly qualified teachers and principals, particularly in 

schools with a high percentage of low-achieving 

students; including programs that provide teacher 

mentoring and incentives. 

 7. Carrying out programs and activities related to 

exemplary teachers. 

 8. Developing and implementing initiatives to assist 

schools in recruiting and hiring teachers, including 

providing financial incentives, and establishing 

programs that train and hire special education and 

other teachers, recruit qualified professionals from 

other fields, and provide increased opportunities for 

minorities, individuals with disabilities and others. 

 9. Hiring highly qualified teachers in order to reduce class 

size, particularly in the early grades. 

Source: NCLBA Pub.L. No. 107-110, section 2123 (2002). 

Appendix III: Activities on Which Districts 

Can Spend Title II, Part A Funds 
Appendix IV: Comments from the U.S. Department of Education 

Page 39 GAO-03-631 No Child Left Behind 

Appendix IV: Comments from the U.S. 

Department of Education 
Appendix IV: Comments from the U.S. Department of Education 

Page 40 GAO-03-631 No Child Left Behind 
Appendix IV: Comments from the U.S. Department of Education 

Page 41 GAO-03-631 No Child Left Behind 
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 42 GAO-03-631 No Child Left Behind 

Carolyn M. Taylor (202) 512-2974 or taylorcm@gao.gov 

Mary E. Roy (202) 512-7072 or roym@gao.gov 

In addition to those named above, the following individuals made 

important contributions to this report: Susan Higgins, Anjali Tekchandani, 

David Garten, Joel Grossman, Richard Kelley, Mark Ramage, Minnette 

Richardson, Susan Bernstein, and Jeff Edmondson. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

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