No Child Left Behind Act: Improved Accessibility to Education's Information Could Help States Further Implement Teacher Qualification Requirements
Published: 2005-11-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The No Child Left Behind Act (NCLBA) of 2001 established qualification requirements that teachers of core academic subjects must meet by the end of the 2005-2006 school year. Congress has appropriated approximately $3 billion a year through the Title II, Part A (Title II), of NCLBA for teacher improvement programs since the law was passed. With the deadline approaching for all teachers to meet the requirements, GAO was asked to examine (1) the status of state efforts to meet NCLBA's teacher qualification requirements, (2) the use of Title II funds in selected districts, and (3) how the U.S. Department of Education (Education) monitors states and assists them with implementation of the requirements. To obtain this information, GAO reviewed teacher qualifications data submitted to Education by 47 states, conducted site visits to 6 states selected for variance in factors such as teacher requirements and geographic location, visited 11 school districts across these states identified as high-need, and interviewed national experts and Education officials.
section_title: What GAO Found
paragraphs: Data reported to Education by 47 states suggest that the majority of core academic classes were taught by teachers who met NCLBA requirements during the 2003-2004 school year. States have improved in their ability to track and report the percentage of core academic classes taught by teachers who met NCLBA qualification requirements, but several limitations on the quality and precision of state-reported data make it difficult to determine the exact percentage of core academic classes taught by teachers meeting the requirements. Five of the 6 states that we visited allowed veteran teachers to demonstrate subject matter competency through a state-developed procedure called High Objective Uniform State Standard of Evaluation (HOUSSE). Officials in states and districts that we visited said that teachers of multiple subjects, such as teachers in rural schools with a small teaching staff, would likely face challenges meeting the requirements by the 2005-2006 deadline. The 11 school districts that we visited all used Title II funds to provide professional development, and most used Title II funds to reduce class size. Officials in the majority of these districts indicated that NCLBA had led to improvements in the kinds of professional development they funded with Title II funds. Although officials in over half of the districts indicated that they continued to use Title II funds to reduce class size, an activity that was supported under a federal program that predated NCLBA, some district officials told us that they had shifted funds away from class size reduction to initiatives designed to improve teachers' subject matter knowledge and instructional skills, such as professional development. All districts that we visited reported considering student achievement data and targeting Title II funds to improve instruction in the academic subjects in which students were lagging behind. In the 11 districts, few efforts funded with Title II targeted specific groups of teachers, such as teachers in high-poverty schools. Title II funds constituted a small proportion of total funds that districts could use for teacher improvement initiatives, and all districts that we visited used several other funding sources to support their teacher programs. Education monitored state efforts to meet the teacher qualification requirements and offered multiple types of assistance to help teachers meet the requirements. In monitoring states, Education has found several areas of concern, such as states not ensuring that certain newly hired teachers met NCLBA's requirements. Education's assistance has included professional development for teachers and site visits to provide technical assistance to state officials. Education officials said that their Web site has been an important tool for disseminating resources about the requirements, but officials from most states and districts that we visited told us that they were unaware of some of these resources or had difficulty locating them, despite frequently using the Web site.

section_title: Letter
paragraphs: Although research over the past 10 years has shown that teachers play a  significant role in improving student performance, many teachers,  especially those in high-poverty districts, lack competency in the subjects  they teach. Recognizing this, the Congress passed the No Child Left  Behind Act of 2001 (NCLBA), which established qualification requirements  for the nation’s approximately 3 million public school teachers, and made  states, districts, and schools responsible for ensuring that teachers meet  these requirements. Specifically, the act requires that teachers of core  academic subjects such as math and science be “highly qualified” by the  end of the 2005-2006 school year.  To meet the requirements, teachers  must (1) have at least a bachelor’s degree, (2) be certified to teach by their  state, and (3) demonstrate subject matter competency in each core  academic subject they teach. Under the act, teachers may demonstrate  subject matter competency through different avenues, including a state- developed High Objective Uniform State Standard of Evaluation  (HOUSSE). State HOUSSE procedures give veteran teachers—generally  those with 1 or more years of experience—the opportunity to demonstrate  subject matter competency through teaching experience, professional  development, coursework, and other activities. If teachers do not meet the  requirements, school districts may be required to take certain actions,  such as providing additional professional development.
To help states and districts meet NCLBA’s teacher qualification  requirements, the Congress has appropriated approximately $3 billion a  year in grants through the Title II, Part A (Title II), of NCLBA since the law  was passed. This amount constituted about 7 percent of all federal funds  made available to states in 2004 for supporting education in kindergarten  through 12th grade. Title II replaced the Eisenhower Professional  Development and Class-Size Reduction programs, allowing states and  districts to use funds for similar purposes, including training of teachers  and hiring of additional teachers to reduce class size, as well as various  other activities to help recruit, retain, and develop teachers. The  Department of Education (Education) monitors states’ implementation of  NCLBA and provides assistance to states to help them understand the  teacher qualification requirements in the act and appropriate uses of Title  II funds.
In our prior work, we found that states and districts faced challenges in  ensuring that teachers met the requirements and also generally did not  have data systems that could track teacher qualifications by subject in  order to determine teachers’ status in meeting the requirements for those  subjects. In response to congressional requests, we are providing  information on (1) the status of state efforts to meet NCLBA’s teacher  qualification requirements, (2) the use of Title II funds in selected districts,  and (3) how Education monitors states and assists them with  implementation of the requirements.
To obtain this information, we used multiple data collection methods.  First, to provide a national perspective, we reviewed teacher qualification  data in the consolidated performance reports that 47 states submitted to  Education for the 2003-2004 school year, the latest year for which these  reports were available. The remaining 3 states, the District of Columbia,  and Puerto Rico did not provide these data to Education. We identified  several factors that affect the accuracy of these data and preclude a  comparison of classes taught by teachers meeting the requirements across  states. However, on the basis of our work, we determined state-reported  percentages could be used to demonstrate how close a particular state  was to reaching the goal of having all its teachers meet the requirements.  The extent of the data limitations is not currently known, and Education  has followed up with all states to obtain additional information on their  processes for collecting these data. Second, to provide information on  how selected states and districts are implementing the requirements and  using Title II funds, we visited and interviewed officials in 6 states— California, Colorado, Kansas, Maryland, Rhode Island, and Tennessee—to  collect in-depth information on their efforts to meet teacher qualification  requirements and use of Title II funds. These states were selected for  variance in procedures for teachers to demonstrate subject matter  competency, reported quality of their data systems, amount of Title II  funds received, and geographic location. At the time of our site visits, none  of the states had been visited for monitoring purposes by Education.  Across these states, we visited 11 of the nation’s 14,466 school districts,  including both urban and rural districts that state officials had identified as  high-need based on their poverty level and teacher challenges they  experienced. We also interviewed officials from Education, national  education organizations, and teachers’ unions. In addition, we reviewed  Title II monitoring reports completed by Education as of July 2005. Finally,  we analyzed Education’s documents and Web site, legislation, and other  materials related to the teacher qualification requirements and Title II  funds. We conducted our work between November 2004 and October 2005  in accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: The NCLBA of 2001 amended and reauthorized the Elementary and  Secondary Education Act, the largest and most comprehensive federal  education law. The focus of this legislation is on improving students’  academic performance. A growing body of research has shown that  teacher effectiveness is a significant factor in improving students’  academic performance. Research has also shown that many children,  especially those in high-poverty and high-minority schools, are assigned to  teachers who lack knowledge of the subjects they teach. For example, a  2004 report stated that one out of four high school courses was being  taught by teachers without a college major, or even a minor, in the subject  taught, and that students in high-poverty classrooms were more likely to  be assigned to such teachers than students in low-poverty classrooms.
Historically, states have been responsible for developing and  administering their education systems, and most states have delegated the  authority for operating schools to local governments. States and local  governments provide most of the money for public elementary and  secondary education. Education reported that 49 percent of the revenue  for public elementary and secondary education in the 2001-2002 school  year came from state sources, 43 percent came from local sources, and 8  percent came from federal sources. As a result, state and local dollars  fund most major expenses, such as teacher salaries, school buildings, and  transportation. Although the autonomy of districts varies, states are  responsible for monitoring and assisting their districts that, in turn,  monitor and assist their schools.
The federal government has played a limited but important role in  education. 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 is responsible for providing  assistance to states to help them understand the provisions or  requirements of applicable laws and oversees and monitors how states  implement them. With the passage of NCLBA, which requires public  school teachers to be highly qualified in every core academic subject they  teach, the federal government for the first time established specific  criteria for teachers.
The act requires all teachers of core academic subjects to have a  bachelor’s degree, state certification, and demonstrable subject matter  competency for each core subject taught. Under the act, teachers may not  have state certification requirements waived on an emergency, temporary,  or provisional basis. According to the Education Commission of the  States, every state required 4 years of college preparation for teacher  certification as of 1974. However, ensuring that all teachers are certified  and can demonstrate competency in the subject matter they teach  presents a new challenge for many states. Allowable ways for teachers to  demonstrate subject matter competency vary depending upon a teacher’s  experience and the grade level being taught. (See fig. 1.) For example,  elementary teachers new to the profession must pass a state test to  demonstrate subject knowledge and teaching skills. States have the  flexibility to identify and approve such tests for new teachers, as well as  establish the passing scores on the tests. Middle school and high school  teachers have a number of options available to them for demonstration of  subject matter competency, including a college major or a state test in the  subject taught. In addition to the options available for new teachers,  veteran teachers have an additional avenue for demonstrating subject  matter competency through their state’s HOUSSE procedures.
States can make the HOUSSE option available to veteran teachers at all  grade levels. The act sets forth some general criteria for states to use in  developing an acceptable evaluation standard. For example, the standard  must be developed in a way that provides objective and coherent  information about the teacher’s attainment of core content knowledge,  must be aligned with state academic content and student achievement  standards, and must be uniformly applied to all teachers of the same  subject and grade level in the state.
In March 2004, Education announced additional flexibilities to help  teachers who deliver instruction in multiple core academic subjects and  science teachers meet the requirements. Education announced that  veteran teachers who provide instruction in multiple core academic  subjects will be able to demonstrate their subject matter competency  through a single set of procedures, such as a single, streamlined HOUSSE  covering multiple academic subjects. Education also announced that  teachers in eligible rural areas who teach multiple core academic subjects  and meet the requirements in at least one of those subjects would have  additional time to demonstrate subject matter competency in the other  subjects. Further, Education allowed states to rely on their own  certification requirements for science to determine specific science areas  in which teachers will be required to demonstrate subject matter  competency. For example, if a state certified teachers in the general field  of science, then a teacher may demonstrate subject matter competency in  the general science area instead of each separate science subject, such as  physics or biology.
According to Education’s August 2005 nonregulatory guidance, the NCLBA  teacher qualification requirements apply to special education teachers  who provide instruction in core academic subjects, such as teachers in  self-contained classrooms. These teachers may demonstrate subject  matter competency by using any of the options allowed to other teachers  under NCLBA.
Qualification requirements for special education teachers were modified  in the December 2004 reauthorization of the Individuals with Disabilities  Education Act (IDEA). The reauthorized IDEA allowed some special  education teachers additional flexibility in terms of meeting subject matter  competency requirements. First, new special education teachers at the  elementary level who are teaching exclusively children with significant  cognitive disabilities may use the state HOUSSE procedures to  demonstrate subject matter competency, an option otherwise reserved  under NCLBA to veteran teachers. Second, new special education  teachers who teach multiple core academic subjects exclusively to special  education students and already meet the requirements in mathematics,  language arts, or science, have 2 years after hiring to demonstrate subject  matter competency in the other subjects taught. Teachers in this second  category may also do this through the HOUSSE process, including a single  evaluation covering all academic subjects taught. Finally, veteran special  education teachers who teach multiple core academic subjects exclusively  to special education students have the option of demonstrating subject  matter competency through a multisubject HOUSSE, consolidated to  assess teachers’ subject matter knowledge in multiple subjects through a  single process.
The deadline for teachers to meet the requirements depends on the type of  school in which they work. Starting with the first day of the 2002-2003  school year, all new teachers hired into school programs supported with  Title I funds must demonstrate compliance with the requirements  immediately upon hire. Most other teachers have until the end of 2005- 2006 school year to meet the requirements in the law. The current  timelines for teachers to meet the requirements are shown in figure 2.
Prior GAO work found that states and districts were experiencing  challenges implementing NCLBA’s teacher qualification requirements.  Among the most commonly cited challenges were difficulties with teacher  recruitment and retention resulting from factors such as low teacher pay,  lack of adequate professional development opportunities, and difficulty  developing and implementing state data systems for tracking teacher  qualifications. We found that challenges were especially acute in small,  isolated rural districts where teachers often had to teach multiple subjects  across different grade levels. Furthermore, although we found that all  states required that special education teachers have a bachelor’s degree  and be certified to teach—two of the three NCLBA teacher qualification  requirements—many states did not require them to demonstrate subject  matter competency. As the result, we concluded that state-certified special  education teachers who were assigned to teach core academic subjects  might not be positioned to meet NCLBA requirements. In the aftermath of  Hurricane Katrina, states and districts faced with large numbers of  displaced teachers and students may have additional challenges tracking  teacher qualification status and ensuring that all teachers meet the  requirements by the deadline. Education indicated that it will work with  affected states and school districts to determine what flexibility will be  needed with regard to implementing the teacher qualification  requirements.
Federal funding for teacher initiatives was provided prior to NCLBA, but  the act increased the level of funding to help states and districts  implement the teacher qualification requirements. Prior to NCLBA, the  Eisenhower Professional Development and Class-Size Reduction programs  provided funds to the states primarily for professional development in  mathematics and science and efforts to reduce class size for students in  kindergarten through third grade. Title II replaced these two programs,  providing states and districts with approximately $2.85 billion for fiscal  year 2002 to help them implement various initiatives for raising teacher  and principal qualifications—$740 million more than provided in fiscal  year 2001 under the previous two programs. In fiscal year 2004, Title II  provided $2.93 billion to states and districts through Improving Teacher  Quality State Grants.
The formula currently used to allocate funds to states and districts is  similar to the formula used under the Eisenhower Professional  Development and the Class-Size Reduction programs and takes into  account poverty and student enrollment. Specifically, the amount of Title  II funds that each state or district receives is based on its 2001 allocation  under the two previous programs, the number of children aged 5 to 17, and  the number of those children residing in families with incomes below the  poverty line. After reserving up to 1 percent of the funds for  administrative purposes, states allocate 95 percent of the remaining funds  to the districts. They retain 2.5 percent to support state-level teacher  initiatives and allocate the remaining 2.5 percent to the state agency for  higher education to support partnerships between higher education  institutions and high-need districts that work together to provide  professional development to teachers.
While there is no formula in NCLBA for districts to allocate funds to  specific schools, the act requires states to ensure that districts target funds  to those schools with the highest number of teachers who are not highly  qualified, the largest class sizes, or that have been identified to be in need  of improvement. In addition, districts applying for Title II funds from their  states are required to conduct a districtwide needs assessment to identify  their teacher quality needs. Among other things, the needs assessment  should identify those needs that must be addressed if the district is to have  all its teachers meeting NCLBA’s requirements by the deadline. The needs  assessment should take into account activities needed to provide teachers  with the means for helping students meet challenging state and local  academic achievement standards. Districts must involve teachers in the  development of their needs assessment and may consider a variety of  factors, such as teacher and student achievement data and projections of  professional development necessary to help all teachers meet NCLBA’s  qualification requirements.
Under Title II, acceptable uses of funds include teacher certification  activities, professional development in a variety of core academic subjects,  and recruitment and retention initiatives, including hiring teachers in  order to reduce class size. (See app. I for state and district authorized  activities.) Some of these activities, such as recruitment of new teachers  and professional development in math and science, could be funded under  the Eisenhower Professional Development and Class-Size Reduction  programs as well. However, states and districts have more flexibility in  how to spend Title II funds than was previously possible. For example,  while under the Class-Size Reduction Program, funds could be spent on  financial incentives and mentoring programs for new teachers only, Title II  funds can be used for existing teachers as well, if the district identifies a  need. While the Eisenhower program focused primarily on professional  development in math and science, allowable activities under Title II may  include any subject. Under NCLBA, professional development is  considered to be an important component of the overall strategy to  improve the quality of teaching and raise student achievement, and the law  provides the definition of professional development.
In addition to using Title II funds for the purposes of raising teacher  qualifications, districts can also transfer these funds to most other NCLBA  programs to meet their educational priorities. Specifically, districts are  allowed to transfer up to 50 percent of the funds allocated to them under  most major NCLBA programs, including Title II, into other programs under  NCLBA. Thus, for example, districts may transfer a portion of their Title  II funds into Title I for initiatives designed to improve student  achievement.
Regardless of whether or not districts transfer funds under the  transferability option, they can spend non-Title II funds, such as Title I  funds, to support teacher initiatives. Under NCLBA, districts are required  to spend at least 5 percent of their Title I funds on helping teachers meet  the qualification requirements. Additionally, schools in the district that do  not meet their student proficiency goals for 2 or more consecutive years  are required to spend at least 10 percent of their Title I funds to provide  the school’s teachers and principals with high-quality professional  development.
States must prepare and publicly disseminate an Annual State Report Card  with information on the professional qualifications of teachers in the state,  the percentage of such teachers on emergency or provisional credentials,  and the percentage of core academic classes being taught by teachers who  do not meet NCLBA’s teacher qualification requirements. Further, Title I of  NCLBA requires districts and schools to inform parents about the  qualifications of their children’s teachers. Districts are required to notify  parents of all students attending Title I schools that they have the right to  request information about the qualifications of their child’s teacher.  Schools must further notify parents if their child has been taught by a  teacher who did not met NCLBA’s teacher qualification requirements for 4  or more consecutive weeks.
The accountability provisions under Title I of NCLBA require every state  and district receiving Title I funds to develop and submit a plan for how it  intends to meet the teacher qualification requirements, along with other  provisions of the act such as adopting challenging academic content and  student achievement standards. The state plan must establish each  district’s and school’s annual measurable objectives for increasing the  number of teachers meeting qualification requirements and receiving high- quality professional development with the goal of ensuring that all  teachers meet the requirements by the end of the 2005-2006 school year. In  addition, beginning with the 2002-2003 school year, districts receiving Title  I funds are required to annually report to the state on their progress  toward state-set objectives, and all states are required to submit an annual  report to Education detailing state progress in meeting the annual  measurable objectives regarding teacher qualification requirements. Under  NCLBA, school districts that do not ensure that their teachers meet the  qualification requirements must implement certain actions, such as  additional professional development. However, their overall funding levels  from Education are not affected. If states do not meet the requirements  for reporting on the qualifications of their teachers, the Secretary of  Education has the authority under NCLBA to withhold state administrative  funds.
Education monitors states’ progress in implementing the requirements  under both Title I and Title II of the act, as well as provides assistance to  them. Beginning with the 2002-2003 school year, Title I of the act requires  Education to publicly report the annual progress of states, districts, and  schools in meeting the measurable objectives for ensuring that all teachers  meet the qualification requirements by the deadline.
section_title: States Have Made Progress in Meeting Teacher Qualification Requirements, but Challenges Remain
paragraphs: The available data suggest that the majority of core academic courses  were taught by qualified teachers in 2003-2004. States have made progress  in tracking and reporting teacher qualification data, but challenges remain  in reporting precise results. States offered multiple options for veteran  teachers to demonstrate subject matter competency as part of their  HOUSSE procedures, but the rigor of these procedures varied across the  states that we visited. Selected state and district officials told us that  certain groups of teachers would likely face challenges meeting the  requirements by the 2005-2006 deadline.
subsections: section_title: Most States Reported That the Majority of Teachers Are Qualified, but Some Data Issues Remain
paragraphs: The data reported by 47 states suggest that the majority of core academic  classes were taught by teachers who met NCLBA requirements during the  2003-2004 school year. Most of these states reported that nearly all of  their core academic classes were being taught by teachers who met the  requirements. However, data for most states appear to show that core  academic classes in low-poverty schools were more likely to be taught by  teachers who met the requirements than classes in high-poverty schools.   The data also suggest that a higher percentage of elementary school  classes were taught by teachers who met the requirements than secondary  school classes. State-reported percentages for each of the 47 states are  shown in appendix II. Data limitations preclude a comparison among  states but, on the basis of our work, we determined state-reported  percentages could be used to demonstrate how close a particular state  was to reaching the goal of having all its teachers meet the requirements.
States have improved in their ability to track and report the percentage of  core academic classes taught by teachers who met NCLBA qualifications.  Reports from 2002 and 2003 from national education organizations, such  as the Education Commission of the States, showed that few states were  able to track and report these data. Similarly, in our 2003 report on the  NCLBA teacher qualification provisions, officials in 7 of the 8 states we  visited told us they did not have data systems capable of tracking teacher  qualifications for each core subject. But by 2005, 47 states reported  teacher qualification data to Education for the 2003-2004 school year.  Officials in the 6 states that we visited told us that they had improved their  data systems, either by creating a new system or by redesigning their  existing system to collect information required under NCLBA. For  example, several states merged their state-level teacher qualification  systems with their district-level class assignment systems to enable them  to determine whether classes were being taught by teachers who met the  requirements. Education officials also told us the 2003-2004 data had  considerably improved from earlier years and that next year’s data will  accurately reflect the status of state efforts to implement the teacher  qualification requirements.
Despite this progress, several issues limit the quality and precision of  state-reported data and make it difficult to determine the exact percentage  of core academic classes taught by teachers meeting NCLBA qualification  requirements. First, district officials in 3 of the 6 states that we visited told  us that they had excluded classes taught by special education teachers  from their calculations; state officials in all 6 site visit states said these  teachers faced particular challenges in meeting the requirements. Second,  states relied on the data districts provided, but state officials generally  noted that data collection processes varied by district, and that the quality  of the data could vary as well. For example, two districts that we visited in  1 state reported data that were based on an incorrect assumption about  which teachers met the requirements, and therefore included some  teachers as meeting the requirements when they had not. Education also  identified data problems in 13 of the 20 states for which it issued  monitoring reports by July 2005. The impact and magnitude of these  problems on state reports is unclear; state-reported data may under- or  overstate the percentage of classes taught by teachers who met the  requirements, depending on the nature of the data problem. Education has  contracted with a research organization to follow up with states to identify  any data issues that may have affected state-reported data, such as states  excluding certain teachers subject to NCLBA’s qualification requirements  from their calculations.
section_title: States Offered Multiple Options for Veteran Teachers to Meet the Requirements
paragraphs: Five of the 6 site visit states had HOUSSE procedures in place for veteran  teachers—those generally with 1 or more years of experience—to  demonstrate subject matter competency, and the procedures included  many different options for teachers to use as part of HOUSSE. The  HOUSSE procedures in these states included the use of a point system that  allowed veteran teachers to demonstrate subject matter competency by  earning points in categories of experience, academic coursework or  professional development, and leadership or service activities, as well as  for evidence of publications, presentations, or awards. Colorado officials  said they did not have a HOUSSE but allowed teachers to demonstrate  subject matter competency through options typically included in other  states’ HOUSSE procedures, such as a combination of college coursework  and professional development options. Figure 3 presents an overview of  HOUSSE point systems from the 5 states we visited that had them in place.  (App. III shows HOUSSE point systems from 2 site visit states.)
In addition to the categories above, the point systems in two states that we  visited also included the option for teachers to demonstrate subject matter  competency through advanced certification. Teachers in Maryland and  Tennessee could earn all of the required points by achieving National  Board Certification.
In addition to the point system, the HOUSSE procedures in some site visit  states offered alternatives for demonstrating subject matter competency.  For example, teachers in Tennessee could demonstrate subject matter  competency through multiple observations of their performance  completed by trained evaluators or the data showing their effect on  student achievement. Teachers in California who were unable to obtain  the required number of points through the point system could use  evidence of positive evaluations of their performance in the classroom or  prepare a portfolio of their work.
Our review of HOUSSE procedures in states that we visited, particularly  the analysis of the points they allowed teachers to count for different  activities, showed that they varied in the weight given to these activities.  The extent to which certain activities reflect teachers’ subject matter  knowledge may affect the rigor of these procedures. For example, as  shown in figure 3, Rhode Island allowed experience to count for about  one-fourth of the 100 points required for demonstrating subject matter  competency, but the other 4 states with HOUSSE procedures allowed  experience to count for about one-half of the points to be earned. Officials  in Colorado indicated that they had chosen not to count experience  toward teachers’ demonstration of subject matter competency because  they did not believe that experience would necessarily translate into  improved subject knowledge. However, Colorado permitted relevant travel  to count toward demonstration of subject matter competency, whereas the  other states did not explicitly include travel in their HOUSSE.
Some site visit states also set a minimum number of points to be earned in  certain categories, while other states did not require teachers to earn  points from those categories. Specifically, Kansas and Maryland required  teachers to earn at least a portion of the total number of points they  needed to demonstrate subject matter competency through college  coursework, while other states did not require a minimum number of  points in that category. States also differed in the number of categories in  which teachers had to earn points. For example, teachers in Rhode Island  were required to earn points from at least three different categories, such  as college-level coursework and professional development in the content  area. In contrast, teachers in Maryland could earn all points necessary for  demonstration of subject matter competency from a single category.  California, Kansas, Rhode Island, and Tennessee also set a requirement  that some activities had been completed within a recent period of time.  For example, Kansas required professional development and service  activities to have taken place within the last 6 years to earn points toward  demonstrating subject matter competency under HOUSSE.
Some of the options that site visit states permitted as part of their  HOUSSE procedures relied on improved student performance or  observations of teachers’ classroom performance. Tennessee allowed  teachers to demonstrate subject matter competency by using data that  show their actual contribution to students’ achievement in that subject.  To use this option for the purposes of demonstrating subject matter  competency, teachers must demonstrate that the most recent 3-year  average gain in the achievement of their students is not detectably  different from or is better than the average gain for all students in the  state. At the same time, Tennessee and California both counted positive  evaluations of teachers’ classroom performance as evidence that could be  counted toward subject matter competency. Although both states based  these evaluations on uniform performance standards established by the  state, officials in these states told us that they did not oversee the  implementation of these evaluations. As a result, we determined that they  could not effectively ensure the quality of evaluations. While we did not  conduct an in-depth review of how the evaluations of teachers’  performance were carried out, we identified two areas of concern for  using this method as an objective state standard. First, the number and  duration of the evaluation sessions may not provide enough information to  determine subject matter competency. Second, these evaluations may be  conducted by personnel who are also responsible for hiring and retaining  teachers in the district, and thus these evaluators may not be objective. In  one small rural district that we visited, the assistant superintendent  responsible for evaluating the teachers’ subject matter competency told us  that the evaluation process was subjective.
Finally, while most states that we visited tried to ensure that activities  accepted as part of their HOUSSE procedures were connected to the  subject area that the teacher taught, Maryland’s HOUSSE procedure  awarded points for activities not directly related to the subject matter,  such as professional development on instructional strategies and  principles. Officials there indicated that the majority of points had to be  earned from activities specific to the subject matter, and that the state’s  HOUSSE procedure sought to recognize both subject matter knowledge  and the teachers’ general teaching expertise.
Some educational experts have noted that the rigor of HOUSSE  procedures varied across states and expressed concerns that states whose  procedures offered less rigorous options may not adequately assess  teachers’ subject matter knowledge. The experts we interviewed told us  that teachers who are not required to engage in activities directly related  to accumulating subject matter knowledge, such as completing college  coursework in a subject, may not increase their knowledge of the subject  taught. In addition, the experts commented that if experience is heavily  emphasized, teachers may not get the subject matter knowledge they need  to be effective in the classroom. States with less rigorous procedures may  not bring about improvements in teachers’ content knowledge or student  performance. Officials from Education confirmed that the rigor of  HOUSSE procedures varied across states, as is permitted under NCLBA.
section_title: Selected States and Districts Faced Implementation Challenges
paragraphs: Although numerous ways exist for veteran teachers to demonstrate  subject matter competency, officials in site visit states and districts and  national association representatives told us that some teachers providing  instruction in multiple core academic subjects, such as special education  teachers and teachers in rural areas and specialized school settings, may  not meet the requirements by the deadline. Officials in the states that we  visited noted that special education teachers would have the greatest  difficulty in meeting the requirements by the deadline, because they were  originally certified in special education rather than in a specific academic  content area. In addition, special education teachers frequently provide  instruction in multiple core academic subjects at the secondary level,  creating challenges in meeting the requirements for each subject. Officials  also noted that teachers in rural districts may face similar challenges. For  example, an official in one state described a rural district landlocked by  mountains where three high school teachers were responsible for teaching  all classes across all subjects and grades at the high school level, and  therefore had to meet the requirements for each subject. Although under  IDEA and Education’s guidance certain special education and rural  teachers who already meet the requirements in one core academic subject  have additional time to meet the requirements for the other subjects,  officials were still concerned about whether these teachers will be able to  meet the requirements for all of the subjects. Officials also reported  challenges for middle school teachers who frequently provide instruction  in multiple core academic subjects, as well as teachers in specialized  school settings, such as schools for students dismissed from their regular  schools as a result of behavioral problems. Officials from two districts in  one state that we visited told us that they had a large number of these  specialized schools, and officials there indicated that teachers often had to  teach multiple subjects to the same group of students, making it difficult  for them because they had to meet the subject matter requirements in each  subject taught. Education allowed states to streamline HOUSSE  procedures by developing a method for veteran teachers of multiple core  academic subjects to demonstrate subject matter competency in all those  subjects through a single procedure. One of the states that we visited  offered a streamlined HOUSSE procedure for its teachers of multiple core  academic subjects. However, officials in the other states that we visited  did not have a single HOUSSE procedure for teachers of multiple subjects,  and some of them indicated that they would like more information on how  to develop one.
Officials in states and districts that we visited also told us that schools will  continue to have difficulty recruiting math and science teachers who meet  the requirements. Schools had difficulty recruiting these secondary  teachers even before NCLBA. These recruitment shortfalls will likely  continue after the 2005-2006 deadline passes, in part because thereafter all  newly hired teachers of core academic subjects, not just those in Title I  schools, will have to demonstrate their subject matter competency before  entering the classroom. Some state and district officials told us that they  were unable to restrict hiring to teachers who met the requirements  because there were not enough candidates who had met the requirements  to fill all of the open positions. One state is altering its emergency  certificate to incorporate a time limit; this certificate will allow teachers to  provide instruction for up to 2 years before they have to fully meet the  subject matter competency requirements. While state officials  responsible for teacher licensing in the state acknowledged that the new  certificate does not meet the requirements of NCLBA, they indicated that  school districts might not be able to fill all their open positions with  teachers who meet the requirements.
We also found that 8 of the 11 districts either did not notify parents when  their children were assigned to teachers who did not meet the  requirements, as required under the act, or did not make the notification  entirely clear to the parents. Five districts in the states that we visited did  not send the letters to the parents, with some district officials stating that  they did not know that the letters had to be sent. Officials in one state  instructed districts not to send the letters until the 2005-2006 deadline had  passed. Three districts in another state sent letters to the parents, but  these letters did not explicitly indicate that the teacher did not meet the  requirements of the law. For example, one district’s letter said that the  teacher “is a dedicated professional who will always work in the best  interest of your child” and “holds a probationary certificate” without  explaining to the parents that probationary certificates do not meet  NCLBA’s requirements.
Additionally, some officials did not know about other aspects of the  requirements, such as actions required for teachers not meeting the  requirements and to whom the requirements applied. For example,  officials in two states told us that they did not know what actions districts  or schools should take against teachers who did not meet the  requirements by the deadline. Officials in one district had fired teachers  because they did not meet the requirements. Other districts generally had  not fired teachers who did not meet the requirements but wanted to know  whether they should. There are no actions specified in the NCLBA with  respect to teachers’ conditions of employment for those who do not meet  the requirements by the deadline. In addition, officials in one district did  not know until our visit that all teachers of core academic subjects—not  just those in Title I schools—would have to meet the requirements by the  end of 2005-2006 school year.
Education acknowledged the challenges that states may face in ensuring  that all teachers meet the requirements by the end of 2005-2006 school  year. On October 21, 2005, Education announced that states may have until  the end of the 2006-2007 school year to ensure that all their teachers meet  the requirements if they can demonstrate that they are making good-faith  effort toward that goal.  As evidence of good-faith efforts, states will need  to meet the following four conditions: (1) show that the state’s  requirements for teachers to demonstrate that they are highly qualified are  consistent with the law, (2) meet the requirements for parental notification  and public reporting, (3) provide complete and accurate teacher  qualification data to Education in January 2006 for the 2004-2005 school  year, and (4) take action to ensure that poor and minority students are not  taught by teachers who do not meet the requirements at a higher rate than  other students. The letter also stated that no federal funds will be withheld  from states if they are unable to ensure that all their teachers meet the  requirements by the end of 2005-2006 school year, as long as these states  are implementing the law and making a good-faith effort to reach that goal.
Despite the challenges experienced, state officials reported progress in  better positioning themselves to meet NCLBA requirements. Although our  2003 report showed that states we visited generally did not have data  systems capable of tracking teacher qualifications for each core subject  teachers taught, officials told us that they had improved their data  systems since then. All of the states that we visited had either created a  new data system or redesigned their existing data systems to collect  information required under NCLBA. For example, several states merged  their state-level teacher qualification systems with their district-level class  assignment systems to enable states to determine whether classes were  being taught by teachers who met the requirements. Another state  redesigned its data system so that it would capture teachers’ status in  meeting the requirements.
In addition to improving data systems, state officials also reported taking  steps to help more teachers meet the requirements. For example, one of  the states developed HOUSSE procedures that could be used to  demonstrate subject matter competency across multiple subjects. Under  those HOUSSE procedures, the same allowable activities, such as  professional development and leadership positions, could be counted for  more than one subject. Most states that we visited made some changes in  certification requirements or professional development standards to make  them more consistent with the requirements of NCLBA. For example, two  states created a separate certificate for middle school teachers that  incorporated subject matter competency requirements—a change that  would ensure that middle school teachers have demonstrated subject  matter competency.
District officials also reported taking steps, such as changing their  personnel policies, to ensure that more of their teachers meet the  requirements. For example, officials in two districts told us that they had  encouraged principals to consider dismissing teachers who were not on  track to meet the requirements. In another state, districts were reassigning  teachers to positions for which they met the requirements, and one  district’s officials instituted a policy of preventing teachers from  transferring to any positions for which they did not meet the requirements.  Officials in most districts also told us that they have incorporated  NCLBA’s teacher qualification criteria into their screening of new  candidates. Further, officials from 6 of the 11 districts that we visited told  us that they were reducing the number of teachers with emergency  credentials.
section_title: Visited School Districts Most Often Used Title II Funds for Professional Development
paragraphs: The 11 districts that we visited used Title II funds to support professional  development for teachers, particularly in core academic subjects. Officials  in the majority of these districts indicated that NCLBA had led to  improvements in the kinds of professional development they funded with  Title II funds. Seven of the 11 districts that we visited also continued to  use the funds for class size reduction efforts. However, district officials  told us that they have begun shifting emphasis from class size reduction to  initiatives focused on improving teacher qualifications. Most districts that  we visited considered student achievement needs in identifying  appropriate uses of Title II funds and targeted the funds to programs  designed to help teachers address those needs. Few initiatives in these  districts targeted specific groups of teachers, such as teachers in high- poverty schools. In addition to using Title II, district officials told us they  used various other funding sources to support their teacher initiatives,  including other federal, state, and local funds.
subsections: section_title: All Visited Districts Used Title II Funds for Professional Development, and Many of Them Used These Funds for Class Size Reduction
paragraphs: All districts that we visited used Title II funds to provide professional  development to teachers and focused their efforts on improving the quality  of instruction in core academic subjects such as reading and math. For  example, one district used Title II funds to provide summer workshops on  research-based instructional strategies in reading and paid for  instructional coaches to support classroom teachers throughout the year.  Two districts reported spending Title II funds on math coaches who  perform tasks such as working with teachers to develop lessons that  reflected states’ academic standards and assisting them in using students’  test data to identify and address students’ academic needs. In four  districts, Title II professional development expenditures included the cost  of instructional materials, and in one district Title II funds paid for  substitute teachers while regular teachers attended training.
In addition to spending for professional development in core academic  subjects, officials in 10 of the 11 districts reported using Title II funds on  professional development in other areas, such as on general teaching  strategies and professional development for nonteaching staff. Most of  these districts used at least some Title II funds for professional  development that focused on teaching skills and general teaching  strategies. For example, one district used Title II funds to support a  program for all teachers during their first 3 years of employment with the  district, including biweekly workshops on classroom management, student  assessment, and parental involvement. Another district used the funds to  help teachers understand the instructional needs of gifted and talented  students and to adjust teaching methods to best address those students’  needs. Seven districts also used Title II funds to offer professional  development for nonteaching staff, such as school administrative  personnel. For example, one district coordinated with a postsecondary  institution to train assistant principals on becoming more effective  educational leaders, while another district used the funds to develop  guidance counselors and social workers employed in the district’s schools.
Officials in the majority of the districts that we visited told us that  NCLBA’s emphasis on student achievement and on strategies supported by  research had led to improvements in the kinds of professional  development they funded with Title II funds. Officials said they had  become much more selective when approving professional development  providers, looking for those programs that focused on intensive, research- based instructional strategies. In one district, for example, officials said  that before NCLBA, providers were often selected on the basis of their  long-standing relationship with the district, whereas now the district  approved only those providers whose programs could be substantiated by  research-based evidence of effectiveness. They also indicated that they  had moved away from onetime workshops and begun to emphasize  ongoing professional development that provided teachers with  opportunities to reinforce and apply concepts learned. Furthermore,  district officials that we interviewed reported greater emphasis on  professional development opportunities in core academic subjects in  which NCLBA required students to be assessed. While officials in some  districts said that they were moving in the direction of higher-quality  professional development even before NCLBA, several of them indicated  that the passage of the act added urgency to these efforts.
Officials in 7 of the 11 districts that we visited told us that they also used  Title II funds to hire additional teachers to reduce class size. Districts  focused their class size reduction efforts on specific grades, depending on  their needs and other funding sources available. For example, one district  visited focused its Title II-funded class size reduction efforts on the eighth  grade because the state already provided funding for reducing class size in  other grades. Officials in another district told us they planned to spend  most of their Title II allocation on class size reduction because class size  reduction funding from the state was insufficient. While class size  reduction may contribute to teacher retention and result in a more  individualized approach to student instruction, it also increases the  number of classrooms that need to be staffed. As a result, districts that are  already having problems with teacher recruitment may find it difficult to  find enough teachers who meet NCLBA’s qualification requirements to  staff these classrooms. For example, one district visited used about one- third of Title II funds for class size reduction, but district officials  indicated that recruitment difficulties forced them to continue to hire  teachers who did not meet NCLBA’s qualification requirements.
Our previous work found that classroom reduction expenditures  amounted to more than 50 percent of total Title II funds that districts  spent during 2002-2003 school year, a finding consistent with Education’s  review of districts’ Title II spending during the same time period. Officials  in states that we visited and educational organization representatives that  we interviewed told us that districts continued to spend funds on activities  developed under the previous program. However, some state officials told  us that they were encouraging districts to expand their traditional uses of  these funds and to place a greater emphasis on initiatives designed to  increase teachers’ effectiveness in the classroom.
In 6 districts that we visited, officials told us that they had begun shifting  away from class size reduction efforts to placing greater emphasis on  initiatives for existing teachers. For example, 2 of the districts stopped  spending Title II funds on class size reduction efforts, and another district  planned to eliminate class size reduction expenditures in the next school  year. Officials in 2 other districts told us that while they still funded class  size reduction efforts, they had reduced the amount of Title II funds they  spent for this purpose. District officials indicated that they were now  redirecting funds to support initiatives designed to improve teachers’  subject matter knowledge and instructional skills, such as professional  development.
In addition to undertaking professional development and class size  reduction efforts, 6 of the districts that we visited used Title II funds to  support recruitment and retention activities. For example, 2 districts used  the funds to advertise open teaching positions, as well as to attend  recruitment events outside of the district to identify qualified candidates.  Another district used Title II funds to expand its alternative certification  program, which allowed qualified candidates to teach while they worked  to meet requirements for certification. Two districts used Title II funds for  bonuses to attract successful administrators. To promote greater retention  among new teachers, 3 districts used Title II funds for mentoring activities.  For example, 1 of these districts reported using the funds to provide two  trained mentors for every new teacher. Ten of the 11 districts that we  visited did not use Title II funds to support programs that offered  additional pay to teachers based on their performance or other  qualifications. A few officials cited reasons for not using such programs,  such as the expense or the difficulties in ensuring that they are  implemented fairly.
Six of the districts that we visited reported taking advantage of NCLBA’s  transferability option, with most of them transferring Title II funds into  Title V. Under Title V, districts receive funding to support local education  reform efforts in a broad range of areas, including activities to improve the  academic achievement of all students and raise teacher effectiveness. For  example, one district transferred Title II funds into Title V for initiatives  designed to address students’ academic needs, such as assessing their  reading skills. Districts officials indicated that they preferred to transfer  funds into Title V because it afforded them the most flexibility in spending  the funds. However, one district transferred Title II funds into Title I to  provide academic services in reading and math to middle school students.
In addition to participating in activities funded with districts’ own Title II  allocations, teachers also took part in activities supported through Title II  grants to universities and in state-level Title II initiatives. Three of the four  university-based grantees that we visited focused on providing  professional development to teachers in math or science. For example,  one program reviewed offered a 2-week summer math workshop to  prepare teachers for the subject matter exams that, if passed, could be  used to demonstrate subject matter competency. Another university  grantee developed a standards-based online math program for middle  school teachers based on the math questions that students most frequently  missed on the state’s assessment. While university officials administering  that program said that it could be used for teachers to earn points toward  demonstration of subject matter competency under NCLBA, they did not  know how many participants in the program had not yet met the  requirements or how many districts allowed teachers to apply their  participation toward earning points through the state’s HOUSSE.  Additionally, states used a portion of Title II funds retained by state  departments of education to support professional development for  teachers in core academic subjects. In two states that we visited, officials  reported that state Title II initiatives specifically targeted teachers who  had not met the subject matter competency requirements of NCLBA; these  initiatives either offered them professional development in core academic  subjects or reimbursed them for taking college courses in the subjects  taught.
section_title: Visited Districts Considered Student Achievement Needs in Identifying Uses of Title II Funds
paragraphs: Officials in the districts that we visited said that in deciding what specific  initiatives should be funded with Title II funds, such as the types of  professional development programs for teachers, they considered student  achievement needs and targeted the funds to programs designed to help  teachers address those needs. To identify student achievement needs,  these officials said that their districts examined students’ results on state  assessments and a school’s progress in meeting annual student proficiency  goals in core academic subjects, as required under NCLBA. The districts  then targeted their Title II funds to programs for teachers to improve  instruction in those subjects in which students were lagging behind. For  example, officials in one district said that because math was an area in  which schools did not meet annual student proficiency goals, the district’s  Title II expenditures were targeted to professional development programs  in math. In another district, the superintendent indicated that his district  had placed the primary focus of its Title II initiatives on reading in early  grades because schools in the district had not met reading proficiency  goals for elementary students in the past. Some districts considered  student achievement results in combination with other factors to identify  most appropriate uses of federal funds. For example, officials in one  district said that they looked at both schools’ student assessment results  and teacher experience levels when deciding where to place Title II- funded instructional coaches.
Officials in the districts that we visited said that they involved a variety of  stakeholders, such as teachers and parents, to help them identify district  needs that could be addressed with Title II funds. The nature of  stakeholder involvement varied across the districts that we visited. For  example, several districts administered a survey to teachers, parents, and  students, asking them about their perceptions of the district and its needs.  Another district administered an online professional development survey  to its teachers, asking them to assess the type of professional development  activities received. District officials said they used the results of these  surveys to decide how to best spend Title II funds. In other districts,  officials considered stakeholders’ perspectives in less structured ways.  For example, in one district that did not have a separate process for  gathering stakeholders’ views prior to making funding decisions, officials  said that stakeholders’ perspectives were still considered as the result of  the superintendent’s regular meetings with school officials and parent  groups across the district.
While most districts that we visited targeted Title II funds to subject areas  that presented academic challenges to students, only a few of the Title II  funded initiatives were directed to specific groups of teachers, such as  teachers in high-poverty schools or teachers who had not yet met the  requirements of NCLBA. One district that we visited targeted Title II  dollars to teachers in high-poverty schools, funding initiatives such as  reimbursing these teachers for taking college classes necessary for them  to meet state certification requirements and providing tuition for teachers  in alternative certification programs who agreed to teach in high-poverty  schools. In four districts that we visited, officials reported having  initiatives specifically for teachers who had not yet met NCLBA’s  qualification requirements. Some of these initiatives offered  reimbursement to teachers for taking college courses or other professional  development that they could use to demonstrate compliance with  NCLBA’s requirements. Other initiatives helped teachers prepare for  subject matter exams and reimbursed the registration fees of those who  passed them to demonstrate subject matter competency in the subject  taught. While many professional development programs supported with  Title II funds were not necessarily targeted to teachers who still needed to  meet the requirements, teachers who had not met the requirements could  count their participation toward demonstration of subject matter  competency under NCLBA by earning points through their state’s  HOUSSE.
In each of the districts that we visited, any teacher could participate in at  least some professional development or other programs supported with  Title II funds, and district officials indicated that they had made efforts to  address district-wide teacher needs. Ten of the 11 districts that we visited  had a large number of high-poverty schools, and by focusing on  districtwide teacher needs, district officials could also address the needs  of teachers who provided instruction to low-income students. For  example, the superintendent of 1 district, in which all teachers could  participate in Title II initiatives, credited the professional development  funded through Title II with the narrowing of the achievement gap  between the district’s low-income and other students. The statutory  formula that states used to allocate Title II funds to the districts takes into  consideration their poverty levels, and several officials we interviewed  told us they believed Title II funds were generally reaching districts with  the greatest need.
section_title: Visited Districts Used Non- Title II Funds to Support Teacher Initiatives
paragraphs: Title II funds are generally a small part of total funds available to the  districts for teacher initiatives, and visited districts used various non-Title  II funds to address their teacher needs, including other federal, state, and  local funds. In two districts, for example, officials told us that Title II funds  represented less than half of all the funds they spent on teacher initiatives.  Moreover, districts received federal funds under different programs, and  Title II constitutes a relatively small proportion of all federal funds they  could use for teacher initiatives. In one district visited, for example, Title II  funds constituted about 13 percent of the total federal funds available,  with the bulk of the district’s federal money coming from Title I. Our prior  work also showed that districts planned to spend much larger percentages  of other federal, state, and local funds than Title II funds on teacher- related activities, but in high-poverty districts Title II funds constituted a  larger share of total funds spent on these activities than in low-poverty  districts.
Although Title II was one of many resources available to the districts,  many district officials we interviewed said that Title II funds played a  significant role in their teacher improvement efforts. For example, officials  in one district credited Title II-funded professional development with  helping teachers prepare for subject matter tests they needed to pass in  order to demonstrate subject matter competency under NCLBA. In  another district, officials said that their initiatives to support teachers,  such as coaches, would not have been possible without Title II funding.
Districts that we visited supported a variety of teacher programs with non- Title II funds. Among other federal funds, Title I was one of the most  frequently cited sources for supporting teacher initiatives. For example,  two districts used Title I funds to hire coaches or consultants to help  individual teachers in high-poverty schools become more effective in the  classroom. A few of the initiatives funded with Title I were specifically  designed to help teachers meet NCLBA’s qualification requirements. For  example, one district used the funds to reimburse teachers who passed the  subject matter exam for their registration fees and for taking additional  college coursework to help them meet NCLBA’s subject matter  competency requirements. In addition to using federal funds, districts also  used state funds for teacher initiatives. For example, districts in one state  received funds from the state for activities such as professional  development to support all beginning teachers. Finally, districts used local  and private funds to support various teacher initiatives. For example, one  district used local funds to reimburse teachers for taking additional  courses to raise their qualifications, while another district used private  foundation funds to provide housing allowances for high-performing  teachers who accepted positions in the district’s most struggling inner-city  schools.
Two districts that we visited had implemented or planned to implement  differential compensation programs that offered financial rewards to  teachers, such as onetime bonuses or salary increases, based on their  performance or other qualifications. One school district in Tennessee  made recruitment, retention, and salary bonuses available to teachers who  had demonstrated a record of effectiveness and taught in some of the  district’s neediest schools. To assess teachers’ eligibility for these  bonuses, the district used the data showing teachers’ impact on student  performance available through the state’s system of measuring students’  achievement gains from year to year. This initiative is currently supported  with both Title I and Title II funds. A school district in Colorado approved  a plan for a districtwide differential compensation system that would  provide teachers with multiple opportunities to increase their yearly pay,  including gaining additional knowledge and skills, assuming positions in  hard-to-fill subjects or hard-to-staff schools, earning successful  performance evaluations, or meeting annual objectives for students’  performance. This initiative will be funded through a local property tax  increase that will create a trust fund to ensure that the new pay system can  be permanently sustained. While officials in that district acknowledged  that Title II funds could be used to support differential compensation  initiatives, they indicated that Title II alone could not sustain this system.
Officials in the districts that we visited said that they did not look at Title  II funds in isolation from other funds when making funding decisions, but  rather they attempted to leverage different funding sources available to  address their teacher needs. For example, officials in one district said that  the district’s use of Title I funds for teacher recruitment purposes allowed  them to focus Title II funds on the coaching program for teachers.
section_title: Education Monitored States and Offered Assistance on Implementing the Requirements, but Some of Education’s Information Was Not Readily Accessible
paragraphs: Education monitored states and offered assistance to help teachers meet  NCLBA’s teacher qualification requirements. In its monitoring reports,  Education identified areas of concern related to states’ implementation of  the teacher qualification requirements. Education’s assistance efforts  included professional development opportunities and information packets  on NCLBA’s requirements. The agency also conducted site visits to states  to discuss NCLBA’s teacher qualification requirements and offer technical  assistance. Although several key resources about NCLBA’s teacher  requirements can be reached only through Education’s Web site, officials  in most states and districts that we visited told us that they had difficulty  locating these resources or were unaware of them. Our review of  Education’s Web site showed that several key resources on NCLBA’s  teacher qualification requirements were located on different Web pages  that were not linked, making it challenging to find them.
subsections: section_title: Education Monitored States’ Implementation of Teacher Qualification Requirements
paragraphs: Education provided written feedback to states on their implementation of  NCLBA’s teacher qualification requirements through the Title II  monitoring process. Education began Title II monitoring in June 2004 and,  as of July 15, 2005, had conducted monitoring visits to 29 states and the  District of Columbia and released reports documenting findings to 20 of  the states. Reports were generally released to states about 1 to 3 months  after the monitoring visit. Education officials reported that states had an  opportunity to respond prior to the release of monitoring reports, and to  develop a plan to address findings. None of our site visit states received a  monitoring report in time to be included in this analysis.
In these 20 monitoring reports, Education issued findings to states that did  not fully implement NCLBA requirements. States most frequently received  findings for not ensuring that teachers hired into Title I schools or with  Title II funds met the teacher requirements (14 states), as required by  NCLBA. Another frequent finding was that state-reported data did not  adequately reflect the status of teachers in meeting the requirements (13  states). For example, several states could not report data on the  percentage of classes taught by teachers not meeting NCLBA’s teacher  qualification requirements for special education or secondary school  classes.
In addition, some states received findings for not requiring certain  teachers to demonstrate subject matter competency as required under  NCLBA. For example, 9 states received findings for allowing teachers of  history, geography, civics/government, or economics to demonstrate  subject matter competency in the broad area of social studies instead of in  each subject taught. Seven states received findings for not requiring new  elementary school teachers to demonstrate competency in the manner  required by NCLBA. Education found that all 7 states had not implemented  a test for new elementary school teachers to demonstrate subject matter  competency or the test was optional. Eight states received findings related  to the demonstration of competency for middle and high school teachers,  and 7 states received findings related to the demonstration of competency  for special education teachers. In states that did not require certain  teachers to demonstrate competency as required by NCLBA, state data do  not fully reflect the percentage of classes taught by teachers who met  NCLBA teacher qualification requirements.
Table 1 lists the major findings related to NCLBA’s teacher qualification  requirements.
Of the 20 states that received monitoring reports, 19 states did not receive  a finding regarding their HOUSSE procedures, even though some experts  have questioned the rigor of HOUSSE procedures in many states. Through  the monitoring process, Education is reviewing state HOUSSE procedures  to ensure that they are consistent with NCLBA’s criteria. Table 2 lists  NCLBA’s criteria for state HOUSSE procedures.
As long as their HOUSSE procedures meet each of NCLBA’s criteria, states  have had flexibility in developing HOUSSE under NCLBA. Among 19 states  with HOUSSE procedures that were determined to meet NCLBA’s criteria  were one state with a HOUSSE that allowed for evaluations of teachers’  classroom performance and several states in which teachers meet  HOUSSE requirements by being fully certified to teach their subject.  Education officials noted that evaluations of teachers’ performance could  be accepted as part of state HOUSSSE procedures as long as they are  rigorous and objective measures of teachers’ subject matter knowledge  that are based on multiple observations and performed by trained  evaluators. In addition, Education officials told us that while teacher  certification in itself would not be sufficient for demonstration of subject  matter competency, several states provided evidence that was accepted by  Education showing that their certification requirements met the criteria  for HOUSSE in the law. In the one state that received a finding related to  its HOUSSE, teachers were allowed to earn more than half of the points  necessary to meet HOUSSE requirements through experience. The state  received a finding because NCLBA does not allow HOUSSE to be based  primarily on teaching experience.
Eleven of the 20 state monitoring reports included written commendations  from Education for state efforts to improve professional development,  strengthen teacher preparation, or develop data systems that track teacher  qualifications. Eight states received commendation for improving or  offering high-quality professional development for teachers. For example,  Arkansas was commended for requiring every teacher to complete 60  hours of professional development each year and devoting considerable  state funding to professional development. Seven states were commended  for strengthening teacher preparation. For example, Georgia was  commended for aligning all teacher preparation to state standards for  student learning. Six states were commended for new or improved data  systems for tracking teacher qualifications. For example, Mississippi  received a commendation for tracking teachers’ qualifications,  certifications, and assignments, and linking those factors to individual  students’ progress.
section_title: Education Offered Assistance to Teachers and States on the Implementation of Teacher Qualification Requirements
paragraphs: Education offered several types of assistance to help the nation’s 3 million  public school teachers meet NCLBA’s teacher qualification requirements,  including professional development opportunities. Education offered  professional development opportunities workshops in which about 4,500  teachers have participated since June 2004. These workshops and related  materials were also made available online free of charge. Teachers  accessed these workshops online through Education’s Web site or through  www.teacherquality.us, a Web site Education uses to provide information  on Education’s teacher initiatives. In addition, teachers can determine  whether their state would accept these workshops as credit toward the  state HOUSSE requirement online. As of September 2005, all states and the  District of Columbia were awarding points for teachers’ participation in  these workshops as part of their HOUSSE procedures or for teacher  recertification.
Education also offered assistance directly to teachers to help them  understand NCLBA’s requirements and gave teachers an opportunity to  provide feedback about what additional support they need. Education  distributed 255,000 “Toolkit for Teachers” information packets that  provide information about NCLBA’s teacher qualification requirements.  The toolkit addressed frequently asked questions that are relevant to  teachers, such as whether NCLBA’s teacher qualification requirements  apply to special education teachers. In addition, Education offered a series  of teacher roundtables that gave teachers an opportunity to share their  views with Education officials on how Education can support them in the  classroom.
Education provided technical assistance to state officials from all 50 states  through site visits by the Teacher Assistance Corps (TAC). TAC visits,  which took place prior to Education’s monitoring of NCLBA’s teacher  qualification requirements, were intended to help states implement the  requirements, according to Education officials. The TAC teams that  conducted site visits were composed of Education officials and experts.  Education characterized these visits as “conversations without  consequences” and did not provide written feedback to states based on the  TAC visits. Education officials said that TAC teams discussed HOUSSE  procedures, the collection of data on teacher qualifications, the best use of  Title II funds, and other issues. Officials from two of the six states that we  visited said that TAC suggestions helped them implement their HOUSSE  procedures. Three other states that we visited said that TAC teams’  suggestions were not useful in their circumstances. For example, officials  in one state said that Education’s suggestion that small rural districts  share teachers to ensure that students are taught by teachers who meet  NCLBA’s requirements was impractical given the distance between  schools. Based on difficulties that states identified during TAC visits,  Education offered science teachers and teachers of multiple subjects,  including rural teachers, additional flexibility in meeting NCLBA’s teacher  requirements.
Through TAC visits, Education officials identified state and local  initiatives that they considered to be innovative ways of improving teacher  qualifications. Such initiatives addressed teacher certification and  licensing, professional development, and other topics. In an effort to share  information on these state and local initiatives with policy makers or  others, Education posted information about these initiatives on  www.teacherquality.us.
Education has provided guidance and hosted meetings for state officials  on the implementation of NCLBA’s teacher qualification requirements.  Education’s guidance answered questions about NCLBA’s teacher  qualification requirements and Title II, such as when teachers with  alternative certification can be considered as having met NCLBA’s teacher  requirements. Education officials reported that they update their guidance  periodically to answer new questions about the teacher requirements,  most recently in August 2005. In addition, Education convenes state Title  II directors once a year to provide updates on the implementation of  NCLBA’s teacher requirements.
Education has also funded several projects that work to improve the  preparation and increase the numbers of special education teachers. For  example, one center compared special education teachers prepared in  alternative certification programs with their counterparts from traditional  preparation programs.
section_title: Some Information on Education’s Web Site Was Not Readily Accessible
paragraphs: According to Education officials, Education’s Web site has been an  important part of their outreach efforts regarding NCLBA’s teacher  qualification requirements. Several of the resources related to  implementation of the teacher qualification requirements, such as the  Teacher Toolkit and state innovative practices, are now available only  through Education’s Web site. However, officials from most states and  districts that we visited who use Education’s Web site to access  information on teacher programs or requirements told us that they were  unaware of some of Education’s teacher resources or had difficulty  accessing those resources. For example, although all of the states we  visited accepted Education’s professional development for credit toward  recertification or HOUSSE, district officials from only 3 of the 11 districts  we spoke with were aware of these opportunities or that they were  available online. Moreover, officials in 4 of the states that we visited told  us that they wanted to know more about other states’ initiatives to  improve teacher qualifications but were not aware that Education had  made this information available online or did not know how to access the  information. In the states that we visited, several state and local officials  mentioned that they attempted to find information by using Education’s  search function but often had trouble finding what they needed.
In our review of Education’s Web site, we found that information and  resources on the teacher qualification requirements were located on  several different Web pages that sometimes were not linked, making the  information difficult to locate. For example, state initiatives were available  through the “Teachers” section of Education’s Web site and not through  the “Administrators” section, even though state and local administrators  would likely find this information more useful than teachers would. See  figure 4 for the description of teacher qualification information included  on different sections of Education’s Web site.
section_title: Conclusions
paragraphs: Since we last reported on the status of implementing the teacher  qualification requirements in our 2003 report, state and district officials  have taken steps to implement these requirements, such as reducing the  number of uncertified teachers and developing data systems to track  teachers’ qualifications. In addition, Education officials indicated that  states have taken steps to raise teacher qualifications through changes in  state certification systems.
Although states have made progress in tracking teacher qualifications data  and reporting on their status in meeting the requirements, difficulties  remain in identifying teachers who do not meet the requirements. This  may be a challenge, particularly because a number of states did not  include all teachers in their calculations or faced other data issues. Where  data challenges exist, Education and the states may not have the  information necessary to direct assistance to where it is most needed. This  may result in some teachers not receiving appropriate support to help  them meet the requirements. Education is working on identifying data  challenges and addressing them through its monitoring visits and other  technical assistance to states. Until these data issues are resolved, state  reports on their status in meeting the teacher qualification requirements  should be viewed as preliminary.
To facilitate state and district implementation efforts, Education relies  extensively on its Web site as one of its principal means for providing  information and implementation resources for states and districts.  However, state and district officials told us that they were unaware of  some of the information resources that Education made available and had  difficulty locating other known sources of information on Education’s Web  site. Consequently, states and districts may not be taking full advantage of  the opportunities and flexibilities made available by Education that would  help them meet teacher qualification goals. Further, without this  information, some states and districts may not be correctly applying the  requirements, thus jeopardizing the ability of their teachers to meet the  requirements by the deadline. This may impede efforts to increase student  performance and ensure that all students reach state standards.
Finally, even when all teachers have met NCLBA’s qualification  requirements, it is unclear whether their doing so will have the expected  effect on student performance. Under the law, states have considerable  flexibility in developing requirements for teachers to demonstrate subject  matter competency. The rigor of these requirements varied across states.  Consequently, it remains to be seen how different state requirements will  affect the quality of instruction and student performance.
section_title: Recommendation for Executive Action
paragraphs: We recommend that the Secretary of Education explore ways to make the  Web-based information on teacher qualification requirements more  accessible to users of its Web site. Specifically, the Secretary may want to  more prominently display the link to state teacher initiatives, as well as  consider enhancing the capability of the search function.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to Education for review and comment.  In its letter, Education agreed with our recommendation, indicating that  the department has already taken steps to address it.  Specifically, the  department is reviewing how teacher qualification information on the  “Teachers” section of its Web site can be better integrated with related  information on other Web sites, including teacherquality.us. Education’s  written comments are reproduced in appendix IV.
We are sending copies of this report to the Secretary of Education,  relevant congressional committees, and other interested parties. We will  also make copies available to others upon request. In addition, the report  will be made available at no charge on GAO’s Web site at  http://www.gao.gov.
Please contact me at (202) 512-7215 if you or your staff have any questions  about this report. Other contacts and major contributors are listed in  appendix V.
section_title: Appendix I: Activities on Which States and Districts Can Spend Title II, Part A, Funds
paragraphs: Table 3 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. After reserving 1 percent of the total Title II allocation to the state  for administrative activities, states retain only 2.5 percent of the remaining  99 percent for state activities.
Table 4 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. After reserving 1 percent of the total Title II allocation to the state  for administrative activities, states allocate 95 percent of the remaining 99  percent to the districts.
section_title: Appendix II: State-Reported Percentage of Core Academic Classes Taught by Teachers Meeting NCLBA’s Teacher Qualification Requirements in the 2003-2004 School Year
subsections: section_title: All schools
paragraphs: These data exclude classes that have students from both elementary and secondary grades.
Np = data were not provided by the states.
section_title: Appendix III: Sample HOUSSE Procedures from Two States Visited
section_title: Appendix IV: Comments from the U.S. Department of Education
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: Harriet Ganson (Assistant Director) and Natalya Barden (Analyst-in- Charge) managed all aspects of the assignment. Scott Spicer, Katharine  Leavitt, and Deborah Edwards made significant contributions to this  report. Other key contributors to this report included Jessica Botsford,  Richard Burkard, Emily Leventhal, Jonathan McMurray, Jean McSween,  John Mingus, and Shannon VanCleave.
section_title: Related GAO Products
paragraphs: No Child Left Behind Act: Education Could Do More to Help States Better  Define Graduation Rates and Improve Knowledge about Intervention  Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005.
No Child Left Behind Act: Most Students with Disabilities Participated  in Statewide Assessments, but Inclusion Options Could Be Improved.  GAO-05-618. Washington, D.C.: July 20, 2005.
Charter Schools: To Enhance Education’s Monitoring and Research,  More Charter School-Level Data Are Needed. GAO-05-5. Washington, D.C.:  Jan. 12, 2005.
No Child Left Behind Act: Education Needs to Provide Additional  Technical Assistance and Conduct Implementation Studies for School  Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004.
No Child Left Behind Act: Improvements Needed in Education’s Process  for Tracking States’ Implementation of Key Provisions. GAO-04-734.  Washington, D.C.: Sept. 30, 2004.
No Child Left Behind Act: Additional Assistance and Research on  Effective Strategies Would Help Small Rural Districts. GAO-04-909.  Washington, D.C.: Sept. 23, 2004.
Special Education: Additional Assistance and Better Coordination  Needed among Education Offices to Help States Meet the NCLBA Teacher  Requirements. GAO-04-659. Washington, D.C.: July 15, 2004.
Student Mentoring Programs: Education’s Monitoring and Information  Sharing Could Be Improved. GAO-04-581. Washington, D.C.: June 25,  2004.
No Child Left Behind: More Information Would Help States Determine  Which Teachers Are Highly Qualified. GAO-03-631. Washington, D.C.:   July 17, 2003.
Title I Characteristics of Tests Will Influence Expenses; Information  Sharing May Help States Realize Efficiencies. GAO-03-389.   Washington, D.C.: May 8, 2003.
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