441 G St. N.W.

Washington, DC 20548

July 17, 2013

The Honorable George Miller

Ranking Member

Committee on Education and the Workforce

House of Representatives

The Honorable Raúl Grijalva

House of Representatives

Education Needs to Further Examine Data Collection on English Language Learners in 

Charter Schools

Over the past decade, the number of students who are English Language Learners (ELLs) 

enrolled in U.S. public schools has grown substantially. At the same time, charter schools have 

expanded the educational options for ELLs and their families. As the number of charter schools 

continues to grow, questions have arisen about how charter schools—a relatively new 

phenomenon in public education that began in the 1990s—are serving special student 

populations, including ELLs. Following the completion of our study comparing the enrollment of 

students with disabilities in charter schools and traditional public schools, GAO began a similar 

study evaluating the enrollment of ELLs in charter schools and traditional public schools.1 As 

part of this study, we obtained a dataset from the U.S. Department of Education (Education) 

containing school-level data that could be used to compare ELL enrollment in charter schools to 

ELL enrollment in traditional public schools for school year 2010-11. This was the only dataset 

available at the time that could be used for our analysis. Further, while this dataset was 

designed to contain enrollment data only on ELLs in ELL programs, Education officials initially 

told us there was no reason to expect that charter schools would be less likely than other 

schools to report data for the dataset. In accordance with Government Auditing Standards and 

GAO policy, we assessed the quality of the ELL data as part of our study and found problems 

with the data’s quality that prevented us from completing the study.2

This letter frames our findings concerning Education’s data on ELL enrollment around two 

questions: (1) What is the quality of Education’s data on ELLs in charter schools? and (2) What 

efforts has Education taken to improve its collection of ELL data from charter schools? We 

conducted this review from November 2012 to July 2013 in accordance with generally accepted 

government auditing standards. See enclosure I for details on our scope and methodology.

 1

GAO, Charter Schools: Additional Federal Attention Needed to Help Protect Access for Students with Disabilities, 

GAO-12-543 (Washington, D.C.: June 7, 2012). 

2

See section 6.65 of Government Auditing Standards, 2011 Revision, GAO-12-331G (Washington, D.C.: 

December 2011). 
Page 2 GAO-13-655R English Language Learners

Results in Brief

GAO was unable to compare ELL enrollment in charter schools to ELL enrollment in traditional 

public schools because Education’s only available data on school-level ELL enrollment were

unreliable and incomplete. Specifically, for over one-third of charter schools, the field for 

reporting the counts of ELLs enrolled in ELL programs was left blank. These blank fields cannot 

reliably be interpreted to mean that the charter schools did not have ELLs enrolled. Education 

officials told us that these school-level ELL data do not have a data steward (that is, an office 

responsible for overseeing the quality of the data) and that the quality of the data is not 

examined on a regular basis. A definitional issue may have resulted in states excluding some 

students from the reported counts, and some charter schools may have failed to submit required 

data to their states. Education officials said they had not systematically studied charter school 

nonreporting but acknowledged that states sometimes have difficulty obtaining data from charter 

schools. Some charter schools with blank ELL counts were also missing data from other 

important datasets, such as those on school performance, which suggests potential broader 

problems with charter school reporting. 

Education has a new ELL school-level data collection effort underway that will address the 

problem with the definition used in the current school-level ELL dataset. However, Education 

has not articulated how it will address the broader problem with charter school nonreporting that 

prevented us from completing our study. Further, Education plans to stop collecting school-level 

data for the ELL dataset with the problematic definition, but it plans to continue collecting these 

data for the local educational agency3

GAO is recommending that Education systemically evaluate the extent of charter school 

nonreporting across other data sets and explore whether collection of the poorly defined data on 

ELLs enrolled in ELL programs can be phased out at the LEA and state levels, if the data quality 

problems are not addressed. 

(LEA) and state levels. 

In its comments on a draft of this report, Education questioned why data issues prevented GAO 

from completing its study and stated that GAO could have proceeded with its study by focusing 

on the factors affecting patterns of ELL enrollment in charter schools and traditional schools and 

the techniques charter schools use to outreach to ELLs. We disagree with Education because 

without information showing what the patterns of ELL enrollment in charter schools actually are, 

a study of the factors affecting those patterns would not be practicable, useful or informative. 

With respect to our recommendations, Education did not express agreement or disagreement. 

Education said that it was aware of problems with charter school reporting prior to the GAO 

study and that it has efforts already underway to address charter school nonreporting, including 

developing a complete directory of all charter schools in operation. We believe those efforts, 

while necessary, do not fully address the problems with charter school nonreporting that we 

found or illuminate the reasons for nonreporting of charter school data. Education also said it is

exploring options regarding the LEA- and SEA-level counts, including whether these data can 

be phased out if the data quality problems are not addressed. 

 3

Generally, local educational agencies are school districts.
Page 3 GAO-13-655R English Language Learners

Background

By definition, ELLs come from a non-English speaking background and have not yet developed 

the level of English proficiency needed for academic success. Various federal requirements 

pertain to ELLs, including the requirement under the Elementary and Secondary Education Act 

of 1965 (ESEA), as amended, for states to include ELLs in the academic assessments 

prescribed under the act and to report on their achievement.4

In school year 2010-11, 40 states had at least one charter school operating in the state.

Further, according to Education’s 

Office for Civil Rights, ELLs must be provided with alternative educational services until they are 

proficient enough in English to participate meaningfully in regular educational programs. 

5

As part of its mission and oversight, Education collects and reports a wide array of data on 

public schools, such as student enrollment, demographics, and academic performance. 

Education also publishes these data in several reports, most notably its Digest of Education 

Statistics and The Condition of Education that are used by researchers who follow trends in 

education. While Education often reports these data for each state or the nation as a whole, the 

data originate from individual schools. As shown in figure 1, generally, data, such as ELL 

counts, are reported from schools through LEAs and state educational agencies (SEAs) to 

Education. SEAs submit the data to Education, but, to do this, SEAs must first collect the data 

from schools and LEAs. 

Relative to traditional schools, charter schools served only a small fraction of school age 

children—about 1.8 million (4 percent) of the 46 million public school students in those 40 states 

in school year 2010-11. Charter schools are public schools created to achieve a number of 

goals, including encouraging innovation in public education and addressing failing schools. 

Generally, charter schools operate with more autonomy than traditional public schools but are 

subject to various federal requirements in the same way as traditional public schools, including 

requirements under ESEA, civil rights laws, and the Individuals with Disabilities Education Act.

 4

20 U.S.C. §§ 6311(b)(3)(C)(ix)(III) and 6311(h)(1)(C)(i).

5

The District of Columbia is included as one of the 40 states.
Page 4 GAO-13-655R English Language Learners

Figure 1: Flow of Data from Schools to Education

Depending on the requirements for each dataset, SEAs may report data to Education at the 

school-level (that is, broken down by each individual school) or aggregated to the LEA- or SEAlevel.6 Having school-level data is important to researchers wishing to compare charter schools 

to traditional schools because once data are aggregated to the LEA or SEA levels, the ability to 

separate out charter schools from traditional schools is lost. That is why our study comparing 

enrollment of ELLs in charter schools and traditional schools required school-level data. The 

only comprehensive school-level data on ELL counts that Education had at the time of our study 

was of ELLs “enrolled in English language instruction educational programs” designed for 

ELLs.7 Education periodically collects school-level counts of ELLs in its Civil Rights Data 

Collection (CRDC), but, at the time of our review, the recent CRDC data only covered a sample 

of schools that was not designed to be statistically representative of charter schools.8

• ELLs enrolled,

Education 

collects other data on numbers of ELLs at the LEA and SEA levels, but not at the school-level. 

These include data on the number of

9

• ELLs served by the Title III program,10

 6

To lessen the reporting burden on SEAs, for many datasets, Education does not require school-level data and 

instead requires only LEA- or SEA-level data. Requiring school-level data would greatly increase the quantity of data 

that SEAs must submit because there are many more schools than LEAs and SEAs.

and 

7

In Education’s datasets, the term “limited English proficient” (LEP) is used to refer to ELLs. The school-level dataset 

we used was counts of “LEP students enrolled in English language instruction educational programs designed for 

LEP students,” referred to as data group 123.

8

The CRDC is conducted approximately every other school year and usually covers only a sample of schools. 

Education is in the process of collecting school year 2011-12 CRDC data for all schools, and Education officials 

estimated that these data will be available for use in late 2013 or early 2014.

9

This dataset is of limited English proficient students “enrolled in an elementary or secondary school at any time 

during the school year” and is referred to as data group 678. 

10The Title III program provides grants to SEAs to improve the education of ELLs by helping them learn English and 

meet challenging state academic content and student academic achievement standards. Title III program grants are 

authorized by Title III of ESEA.
Page 5 GAO-13-655R English Language Learners

• former ELLs who have achieved proficiency in English and are no longer receiving Title 

III services.

Unlike traditional public schools that are part of a LEA, some states establish charter schools as 

their own LEA. Other states require charter schools to be part of a larger LEA, while still others 

allow charter schools the option to choose between being a distinct LEA or part of a larger 

LEA.11 When a charter school is part of a larger LEA, its data are supposed to be included along 

with data from other schools in the LEA’s totals reported to Education. Conversely, a charter 

school that is its own LEA would report only a single school’s data even when reporting at the 

LEA-level.12

Nonreporting and Definitional Issues Undermine the Quality of Education’s Data on ELLs 

in Charter Schools 

We were unable to compare ELL enrollment in charter schools to ELL enrollment in traditional 

public schools nationwide or by state because of problems with Education’s only available 

dataset of school-level ELL enrollment counts. Specifically, in our review of this dataset, we 

found that a substantial percentage of charter schools—37 percent in school year 2010-11—

had blanks in the field capturing ELL enrollment counts.13 While some of these schools may not 

have any ELL students, our analyses suggested that some schools that have ELLs enrolled did 

not report them.14 Further, the percentage of schools with blanks in the field for ELL counts 

varied by state. In 14 states, at least 60 percent of the charter schools had blank fields. In two 

states generally known to have large numbers of ELLs, New York and New Jersey, over 80 

percent of charter schools had blank fields.

15 In contrast, in six states all charter schools had 

numerical values—including zeros—for ELL counts; that is, no charter schools had blank fields 

for their ELL counts in these states. Figure 2 shows the distribution of charter schools with blank 

ELL counts in the 40 states with charter schools.

 11In addition, some states allow charter schools to be their own LEA for some purposes and part of a larger LEA for 

others, including for purposes of special education.

12Some charter school LEAs comprise more than one charter school. In such cases, the LEA would submit data for 

all charter schools within the LEA.

13We found that 21 percent of traditional public schools had blank ELL enrollment counts. However, the analyses that 

we and Education conducted on schools with blank ELL counts focused on charter schools because their higher 

percentage of blanks (37 percent) would likely hinder our ability to make meaningful comparisons between charter 

schools and traditional public schools. 

14In this report, we refer to schools as leaving fields blank in Education’s dataset. As shown in figure 1, school data 

originate with schools but are reported to Education by SEAs. Because of the SEA’s role of compiling and submitting 

data, it is possible that some SEAs received ELL counts for schools that they did not to submit to Education. 

15According to data from the American Community Survey, New York and New Jersey had the 3rd and 7th highest 

numbers of ELLs, respectively, among the 50 states based on 2009 3-year estimates. Specifically, these ACS data 

are on the number of individuals ages 5 to 21 who speak a language other than English at home and speak English 

less than very well.
Page 6 GAO-13-655R English Language Learners

Figure 2: Percentage of Charter Schools With Blank ELL Enrollment Counts in School 

Year 2010-11, by State

a

States with less than 5 charter schools operating in school year 2010-11.

While Education’s data reporting protocols for this dataset allow blank fields if the ELL counts 

are zero, these blanks cannot reliably be interpreted as zeros, especially given the large number 

of charter schools with blank ELL counts. In response to concerns we raised about the data, 

Education conducted analyses that found some charter schools with blank ELL counts did, in 

fact, have ELLs enrolled. Specifically, Education found that some of these charter schools were 

their own LEA and had LEA-level counts for ELLs in a different dataset which is collected at the 

LEA-level but not at the school-level. Also, some of the charter schools with blank ELL counts in 

the dataset we reviewed had reported assessment results for ELLs through another Education 

data collection. 

The difficulty of interpreting blank ELL counts in Education’s dataset is further complicated by 

how Education defines a key term for the dataset. Specifically, this dataset is a count of ELLs 

enrolled in “English language instruction educational programs,” not a simple count of all ELLs. 

When we began our study, Education officials told us there was no reason to expect that certain 

types of schools such as, charter schools or schools without Title III funding, would be less likely 

than other schools to report data for the dataset. However, after we identified the high 

percentage of charter schools with blank ELL counts, Education officials told us that the 

definition of “program” for the dataset is broad and left up to state interpretation. Specifically, 

they said that charter schools may be less likely to consider their ELLs as participating in a 

program, as defined by their state and, therefore, may not report their ELLs in this dataset. 

Further, they said that, in some states, the SEA may decide not to report ELLs for some schools 

if it determines that the schools did not have programs that met the state’s definition of 

“program" for the dataset. An Education official told us that officials in one state said they 

consider the term “program” for this dataset to mean the Title III program that provides grants to 

states to support the education of ELLs, and the state only reports ELLs in schools that receive 

Title III funding. This definitional issue could affect the reliability of ELL counts across all states, 

including the six states where no charter schools had blank ELL counts. 
Page 7 GAO-13-655R English Language Learners

An additional likely cause for blank ELL counts in Education’s dataset is that some charter 

schools failed to submit required data to their state. Education officials said they had not 

systematically studied charter school nonreporting but acknowledged that states sometimes 

have difficulty obtaining data from charter schools. Further, Education officials told us that some 

state officials identified charter school nonreporting as a contributing factor to the large 

percentage of blank ELL counts in Education’s dataset. In addition, Education’s analyses 

suggest that some of the charter schools with no reported ELL data for the dataset we reviewed 

may have additional data reporting problems. Specifically, Education’s analyses found that 

some charter schools with blank ELL counts were also missing math or reading performance 

data or graduation rates for all students, including ELLs, which suggests these schools had 

broader reporting problems not limited to ELLs. In response to our questions about the 

problems with charter schools’ ELL data, Education officials told us that the school-level ELL 

data that we reviewed do not have a data steward (that is, an office responsible for overseeing 

the quality of the data) and that the quality of the data is not examined on a regular basis; 

instead, any quality reviews of the data are conducted on an ad hoc basis when the data are 

requested. 

The problems we identified with Education’s school-level ELL dataset coupled with Education’s 

own findings that key information was missing from other databases that collect information on 

charter schools, indicate potential broader problems with charter school reporting and 

undermine Education’s ability to have reliable, timely information to monitor charter schools.16 In 

addition, the problems GAO identified with the school-level ELL data appear to affect the quality 

of the LEA-level counts of ELLs enrolled in “English language instruction educational programs” 

that Education publishes and makes available to researchers in the Common Core of Data, the 

agency’s dataset that captures a broad range of information on education. Education officials 

told us that states submit school-level and LEA-level data separately to Education; therefore, 

the LEA-level data may not have the same problems that we identified with the school-level 

data. However, when we calculated and compared statewide ELL counts from two datasets—

(1) the school-level dataset we received from Education and (2) LEA-level data from the 

Common Core of Data—we found that, for most states, the ELL counts for both datasets 

matched almost exactly, as shown in figure 3. This suggests that, even though states submit the 

school-level and LEA-level data separately to Education, both datasets are derived from the 

same source—data collected from schools. This further suggests that, as with the school-level 

data, the LEA-level data are incomplete and unreliable. For example, New Jersey’s ELL counts 

from its LEA-level and school-level data matched almost exactly even though over 80 percent of 

its charter schools did not have ELL counts in the school-level data.

 16Federal agencies are responsible for establishing and maintaining internal control to achieve their objectives such 

as enforcing compliance with federal laws and regulations, and having relevant, reliable, and timely information is a 

standard element of internal control. See OMB Circular A-123, “Management’s Responsibility for Internal Control”, 

revised December 21, 2004 and GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-

21.3.1 (Washington, D.C.: November 1999).
Page 8 GAO-13-655R English Language Learners

Figure 3: Percentage Difference between Numbers of English Language Learners 

Included in School-Level Dataset Analyzed by GAO and Local Educational Agency Level 

Data from Education’s Common Core of Data

Note: California is excluded from the table because its ELL counts for school year 2010-11 were not included in the 

Common Core of Data.

Education is Revising its ELL Data Collection Efforts, but Charter School Nonreporting 

Remains Problematic 

Beginning in school year 2013-14, Education plans to collect new school-level data on all ELLs 

regardless of whether or not they are enrolled in a “program,” thus addressing the issue with the 

term “program” that limits the usefulness of the current school-level dataset.17

In addition, Education officials are developing a workbook to serve as a guide for SEAs in 

reporting charter school data. Specifically, according to Education officials, the workbook will 

address issues that affect Education’s ability to maintain a complete and accurate directory of 

charter schools. For example, the workbook is intended to address issues, such as reporting on 

the opening and closing of charter schools and providing up-to-date information on charter 

schools’ LEAs and authorizers. Education plans to issue this workbook in the summer of 2013 

before the school year 2013-14 data collection cycle. However, Education has not articulated 

how it will address issues with charter school nonreporting that hindered our ability to compare 

ELL enrollment at charter schools to enrollment at traditional public schools.

According to 

Education officials, the new school-level data will, unlike the current school-level data, have a 

data steward and will receive regular data quality reviews. For the dataset that we analyzed, 

ELLs enrolled in English language instruction educational programs designed for ELLs, 

Education plans to halt collection of school-level data but continue collecting LEA- and SEAlevel data. Given that the quality problems we found in the current school-level data appear to 

carry over to and reduce the usefulness of the LEA- and SEA-level data, the cost of continuing 

to collect these LEA- and SEA-level data may not be justified. 

Conclusions

The population of ELLs is growing and charter schools provide these students and their families 

an additional educational option. Therefore, it is important that data be available on the 

 17Currently, this dataset (referred to as data group 678) is collected only at the LEA and SEA levels. 
Page 9 GAO-13-655R English Language Learners

characteristics of students enrolled in charter schools in order to assess how these schools are 

serving ELLs relative to traditional public schools. However, because of problems with the 

completeness and reliability of Education’s current school-level data, we could not determine 

how the enrollment of ELLs in charter schools and traditional public schools compare. Further, 

the nonreporting by charter schools that we identified and the subsequent finding by Education 

that some charter schools had not reported information in other datasets may signal a broader 

problem with charter school reporting. These data problems could have implications for 

Education’s ability to track key information related to charter schools and interfere with their 

ability to effectively oversee charter schools’ compliance with relevant federal requirements. 

While Education plans to begin collecting new school-level ELL data that does not have the 

definitional issue that characterizes its current data collection, the problem of nonreporting by 

charter schools remains. Further, the problems we identified with Education’s current schoollevel ELL data also appear to affect these data at the LEA and SEA levels. While Education has 

plans to stop collecting these data at the school-level, it plans to continue its LEA- and SEAlevel data collection. The limited usefulness of the LEA- and SEA-level data may not be worth 

the cost of collecting the data, given the data quality problems we identified.

Recommendations for Executive Action

We recommend that the Secretary of Education take the following two actions:

1. To more fully understand and address nonreporting of charter school data, conduct a 

systematic evaluation of other important data sets such as, datasets on academic 

achievement and graduates/completers to determine the extent of charter school 

nonreporting, assess underlying reasons for such nonreporting, and determine the steps 

needed to address nonreporting.

2. Because the problems we identified with the school-level ELL data also affect the LEAlevel data, explore whether the collection of the LEA- and SEA-level counts of ELLs 

enrolled in English language instruction educational programs can be phased out, if the 

data quality problems are not addressed. 

Agency Comments and Our Evaluation

We provided a draft of this report to the U.S. Department of Education for review and comment. 

The U.S. Department of Education provided written comments which are reproduced in 

enclosure II.

In its comments, Education did not indicate agreement or disagreement with GAO’s 

recommendations. Education questioned why data issues prevented GAO from completing its 

study. Education posited that GAO could have proceeded with its study focusing on the factors 

affecting patterns of ELL enrollment in charter schools and traditional schools and the 

techniques charter schools use to outreach to ELLs. We disagree with Education. Lacking 

information showing what the patterns of ELL enrollment in charter schools actually are, a study 

of the factors that affect those patterns would not be practicable, useful or informative. Further, 

with respect to the data Education provided to GAO for its study, Education in its agency 

comments reported that they had already determined that the data were of “limited utility.” 

However, Education did not provide information on the problems with the data until after we 
Page 10 GAO-13-655R English Language Learners

identified the high percentage of charter schools with blank fields in the dataset. As a result of 

our review of the data, Education conducted its own analyses and consulted with states to 

understand the potential causes for the problems. Education said that, other than the dataset 

that GAO used on “Limited English Proficient students enrolled in language instruction 

educational programs,” it has not had a school-level dataset on ELL enrollment data because, 

consistent with its program statutes, such a dataset has not been needed by its program offices 

to date. Moving forward, Education said that it will have two datasets with school-level ELL 

enrollment data and that one of these, the Civil Rights Data Collection for school year 2011-12, 

will be available for use by early 2014. Once these data are available, GAO will assess the 

quality and make a determination about whether the data can be used for a future study of ELL 

enrollment. 

In response to GAO’s first recommendation that Education conduct a systematic evaluation of 

other important datasets to determine the extent of charter school nonreporting, Education said 

that it was aware of problems with charter school reporting and that the department had efforts 

underway to improve the completeness and quality of charter school data prior to the GAO 

study. Specifically, Education said that it is developing a complete and accurate directory of 

charter schools and that this is a first step in ensuring high quality reporting because schools 

must be included in the directory before student counts can be reported for them. Education 

also stated that the lessons and outcomes from the directory review are informing its 

development of a charter school reporting workbook, which will assist states, along with 

traditional and charter school districts and authorizers, in reporting complete and high quality 

data. Further, Education said the technical assistance it provides to states and the attention it is 

giving to the charter school directory will encourage closer examination of the charter school 

data that states report to Education. We believe Education’s efforts to provide technical 

assistance to states, maintain an up-to-date directory of charter schools, and develop a charter 

school reporting workbook can help improve the collection of charter school data. However, 

these efforts are not designed to provide a clear picture of the extent of nor reasons for charter 

school nonreporting, and we believe a systemic evaluation could be useful for this purpose.

In response to GAO’s second recommendation that Education explore whether the collection of 

LEA- and SEA-level counts for ELLs enrolled in “English language instruction educational 

programs” can be phased out if the data quality problems are not addressed, Education said it is 

exploring how phasing out this data collection would meet the needs of various data users and 

impact the Common Core of Data, which is a compilation of information on all public schools

and school districts in the United States. Further, its Office of Civil Rights and Title III office are 

discussing the option of providing instructions and other guidance to states and districts on the 

definition of “English language instruction educational programs” in the data collection in order 

to improve the quality and quantity of responses. Education said it plans to continue collecting 

these data at the LEA and SEA levels during this evaluative phase. 

Education also provided technical comments on the report, and we have made changes in the 

report, where appropriate, to address these comments.

As agreed with your office, unless you publicly announce its contents earlier, we plan no further 

distribution of this report until 30 days from its issue date. At that time, we will send copies of 

this report to relevant congressional committees, the Secretary of Education, and other 

interested parties. In addition, the report will be made available at no charge on the GAO Web 

site at http://www.gao.gov.
Page 11 GAO-13-655R English Language Learners

If you or your staff have any questions about this report, please contact me at (202) 512-7215 or 

scottg@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs 

may be found on the last page of this correspondence. GAO staff who made key contributions 

to this report are Sherri Doughty, Assistant Director; Kathy Peyman, Analyst-in-Charge; Divya 

Bali; James Bennett; Holly Dye; Kirsten Lauber; Lise Levie; Ying Long; Luann Moy; and James 

Rebbe.

George A. Scott

Director

Education, Workforce, and Income Security Issues
Page 12 GAO-13-655R English Language Learners

Enclosure I: Scope and Methodology

We assessed the quality of Education’s enrollment data on English Language Learners (ELLs) 

in charter schools in order to determine if the data were reliable for the purpose of comparing 

ELL enrollment in charter schools to ELL enrollment in traditional public schools. We obtained 

from Education nationwide data for school year 2010-11 on all public schools, including charter 

schools.18

To determine the quality of Education’s ELL enrollment data, we conducted analyses and 

reviewed documentation such as data reporting protocols. Our analysis of the dataset included 

analyzing, at the national and state levels, the number of charter schools and traditional public 

schools that had a blank field for the number of ELLs enrolled. In addition, for some states with 

many charter schools with blank fields for ELL enrollment numbers, we reviewed the list of 

individual charter schools to assess the plausibility that the blanks indicated that no ELLs were 

enrolled in the schools. To do this, we considered evidence such as the names of charter 

schools and how their ELL count reporting compared to other schools in nearby zip codes. 

Further, we calculated statewide ELL counts from two datasets—(1) the school-level dataset we 

received from Education on the “limited English proficient (LEP) students enrolled in English 

language instruction educational programs designed for LEP students” and (2) LEA-level data 

from the Common Core of Data—and we compared these two statewide ELL counts to 

determine the extent to which they differed. Finally, we interviewed officials at Education about 

the data and about the analyses they conducted on the data reporting of charter schools that 

had blanks in the field for the number of ELLs enrolled. 

These data came from a dataset on the “unduplicated number of limited English 

proficient (LEP) students enrolled in English language instruction educational programs 

designed for LEP students.” (Education’s datasets use the term “limited English proficient” to 

refer to ELLs.) Based on an interview with Education officials and our review of available 

documentation about Education’s datasets, we concluded that this was the only available 

dataset that could be used for a valid comparison of ELL enrollment in charter schools to ELL 

enrollment in traditional public schools. Education had other datasets related to ELL enrollment, 

such as a dataset on the “unduplicated number of LEP students enrolled in an elementary or 

secondary school at any time during the school year.” However, these other datasets did not 

contain representative school-level data for charter schools that were needed for our review. 

Specifically, other datasets either (1) only included state-level or local educational agency (LEA) 

level data but not the school-level data needed for our analysis or (2) included school-level data 

for a sample of schools that was not designed to be statistically representative of charter 

schools. 

To determine the efforts Education has taken to improve its collection of ELL data from charter 

schools, we interviewed Education officials and reviewed relevant documents. 

We conducted this review from November 2012 to July 2013 in accordance with generally 

accepted government auditing standards.

 18Education also provided GAO with ELL enrollment data for school year 2009-10, but GAO’s detailed analysis, 

discussed in this letter, focused on the school year 2010-11 data because it was the most recent available data.
Page 13 GAO-13-655R English Language Learners

Enclosure II: Agency Comments and Our Evaluation
Page 14 GAO-13-655R English Language Learners
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