Education of Homeless Students: Improved Program Oversight Needed
Published: 2014-07-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The McKinney-Vento Homeless Assistance Act established a grant program to help the nation's homeless students—more than one million in school year 2011-12—have access to public education. Under the Education for Homeless Children and Youth grant program, states and their school districts are required to identify homeless children and provide them with needed services and support. In fiscal year 2014, Education received about $65 million to administer this program. Education provided formula grants to states, which competitively awarded funds to school districts to help meet program requirements. GAO was asked to review program implementation and oversight.
GAO examined (1) how districts identify and serve homeless students and challenges they face (2) how Education and states collaborate with other service providers to address student needs and any barriers, and (3) the extent to which Education monitors program compliance. GAO reviewed relevant federal laws, guidance, and reports, and analyzed Education's state and school district survey data from school year 2010-11. GAO also interviewed federal officials, and state and local officials in 20 school districts—representing a mix of urban, suburban, and rural districts and grant status—in four states, selected for geographic diversity and other characteristics, such as experience with natural disasters.
section_title: What GAO Found
paragraphs: To identify and serve homeless students under the Education for Homeless Children and Youth (EHCY) program, officials in the 20 school districts where GAO conducted interviews reported conducting a range of activities to support homeless youth, but cited several challenges. With regard to GAO's interviews, 13 of the 20 districts identified homeless students through housing surveys at enrollment, while all 20 relied on referrals from schools or service providers. However, officials in 8 of the 20 districts noted that the under-identification of homeless students was a problem. Districts GAO reviewed provided eligible students with transportation to and from school, educational services, and referrals to other service providers for support such as health care or food assistance. Among the challenges that officials in the 20 districts cited were limited staff and resources to provide services, the cost of transportation, student stigma associated with homelessness, and responding to students made homeless by natural disasters. Nationally, school districts surveyed most recently in school year 2010-11 by the Department of Education (Education) reported providing many services while facing similar challenges.
Education's EHCY program manager and state program coordinators have collaborated with other government agencies and with private organizations by sharing information, participating in interagency councils on homelessness, and providing technical assistance to relevant staff. In addition, state EHCY program coordinators have provided training to school districts and helped connect local programs to ensure homeless students receive various services. However, federal and state officials frequently cited limited resources and differing federal definitions of homelessness as constraints to greater collaboration.
Education has protocols for monitoring state EHCY programs, but no plan to ensure adequate oversight of all states, though monitoring is a key management tool for assessing the quality of performance over time and resolving problems promptly. Prior to fiscal year 2010, it had been Education's policy to monitor 50 states and 3 area programs at least once during a 3-year period, and it did so for fiscal years 2007 to 2009. Subsequently, the department adopted a risk-based approach in fiscal year 2010 and monitored 28 states over the next 3 years. In fiscal year 2013, Education again changed its approach to EHCY program monitoring and has monitored 3 state programs since then. Department officials cited other priorities and a lack of staff capacity as reasons for the decrease in oversight. As a result, Education lacks assurance that states are complying with program requirements. GAO found gaps in state monitoring of districts that could weaken program performance, reinforcing the importance of effective federal monitoring of states.
section_title: What GAO Recommends
paragraphs: GAO recommends that Education develop a plan to ensure adequate oversight of the EHCY program. Education concurred with our recommendation.

section_title: Letter
paragraphs: In school year 2011-12, more than 1.1 million children and youth enrolled  in our nation’s public schools were identified as homeless, according to  data from the U.S. Department of Education (Education). Homeless  children and youth may face a variety of barriers to continuing their  education, including frequent moves, a lack of transportation to and from  school, and a lack of adequate supplies and services, such as  counseling, that may be necessary to help them remain in school.  Research on homeless and highly mobile children suggests that they face  challenges with academic achievement and school completion. We  previously reported that students who change schools more frequently  tend to have lower scores on standardized reading and math tests and  drop out of school at higher rates than their less mobile peers. In  addition, according to a study of an urban school district from school  years 2005-06 to 2009-10, homeless and highly mobile children were  more likely to exhibit lower levels of academic achievement compared  with other students.
The Education for Homeless Children and Youth (EHCY) program,  initially authorized by Title VII-B of the McKinney-Vento Homeless  Assistance Act (McKinney-Vento Act), helps address barriers to school  enrollment, attendance, and success for homeless children and youth.  The act requires state educational agencies to ensure that homeless  children and youth have equal access to the same free appropriate public  education, including a public preschool education, as provided to other  children. Congress appropriated about $65 million to carry out the EHCY  program in fiscal year 2014. The McKinney-Vento Act authorizes  Education to provide federal grants to states to administer and oversee  activities under the EHCY program. In turn, states award a majority of  these funds on a competitive basis to select school districts in their state  (grantee districts), based on factors such as the needs of homeless  children and youth within a particular district and the ability of the district  to meet those needs. Regardless of whether a school district receives  EHCY program funds, all districts must comply with certain program  requirements, which include ensuring that homeless children and youth  are appropriately identified, immediately enrolled in school, and receive  the educational and other services for which they are eligible, such as  transportation to and from school. In addition, as GAO has reported in the  past, collaboration presents an opportunity to increase the efficiency and  effectiveness of federal programs.can meet every need of students experiencing homelessness, and   Because no one system of services  funding for the EHCY program is set at relatively modest levels,  collaboration at the federal, state, and local levels is essential to address  the academic and non-academic needs of homeless students. The  McKinney-Vento Act requires states and school districts to coordinate and  collaborate with other programs and service providers that also serve  these children and youth. In light of the issues facing homeless students,  you asked us to examine the implementation and oversight of the EHCY  program.
This report addresses (1) how school districts identify and serve  homeless students and the challenges in doing so, (2) how Education and  states collaborate with other agencies and service providers to address  the needs of homeless students and barriers to collaboration, and (3) the  extent to which Education monitors compliance with the EHCY program  requirements and how Education assesses program results.
To gather information on how the EHCY program is implemented at the  local level, we visited three states—Colorado, New Jersey, and  Washington—and interviewed officials in Texas by phone. We selected  states that represent geographic diversity and based on the  recommendations of experts, including the National Association for the  Education of Homeless Children and Youth (NAEHCY) and other  national organizations working on issues related to homelessness, to  obtain a mix of states implementing promising practices in their EHCY  programs as well as experiencing challenges. In addition, we sought  variation in the number of homeless students states identified in recent  years and the size of states’ EHCY grants, among other factors. We also  selected two states that have recently experienced natural disasters to  see how they coped with sudden increases in the number of homeless  students. In each state, we interviewed state and school district officials.  In total, we spoke with school district officials from 20 different school  districts, nine of which were grantee districts. We selected these districts  with the assistance of state EHCY program coordinators to represent a  mix of urban, suburban, and rural districts, as well as grantee and non- grantee districts. In the states we visited, we also met with school officials  and youth or their families who have experienced homelessness.  Information obtained from these states and school districts is non- generalizable. To obtain generalizable and national-level information on  states and grantee school districts, we analyzed Education data from two  surveys covering school year 2010-11, which we found to be sufficiently  reliable. We assessed the reliability of the survey data by performing  electronic testing of the data elements, reviewing relevant documentation,  and interviewing agency officials knowledgeable about the data. We used  the survey data to examine how states and school districts implement the  EHCY program and how states monitor school districts, among other  things. All estimates obtained from the school district-level survey have  margins of error of no greater than six percentage points. To obtain  information on how Education administers the EHCY program and  collaborates with other agencies, we interviewed Education officials and  officials from other federal agencies, including the Departments of Health  and Human Services (HHS) and Housing and Urban Development  (HUD), as well as the U.S. Interagency Council on Homelessness  (USICH). We also reviewed relevant documents—including federal laws  and regulations, monitoring protocols, and policy memos—and examined  Education’s findings on the EHCY program from state monitoring reports.  See appendix I for additional information on our scope and methodology.
We conducted this performance audit from July 2012 through July 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: The Education for Homeless Children and Youth Program
paragraphs: The EHCY program is the key federal education program targeted to  homeless children and youth, and, in school year 2011-12, more than 1.1  million were enrolled in our nation’s public schools, according to  Education data. For purposes of the program, a homeless child or youth  is one who lacks a fixed, regular, and adequate nighttime residence. This  includes children who: are sharing the housing of others due to loss of housing, economic  hardship, or a similar reason (commonly referred to as “doubled-up”); are living in motels, hotels, trailer parks, or camping grounds due to  the lack of alternative adequate accommodations; are living in emergency or transitional shelters; are abandoned in  hospitals; or are awaiting foster care placement; have a primary nighttime residence that is a public or private place not  designed for or ordinarily used as a regular sleeping accommodation  for human beings; are living in cars, parks, public spaces, abandoned buildings,  substandard housing, bus or train stations, or similar settings; and are migratory children who qualify as homeless due to their living  circumstances, as described above.
Education’s Office of Student Achievement and School Accountability  (SASA)—within the Office of Elementary and Secondary Education— provides EHCY formula grants to states, which must comply with certain  requirements. For example, the McKinney-Vento Act requires each  state that receives funds to establish an Office of Coordinator for  Education of Homeless Children and Youths, with responsibilities that   The state plan describes, among  include carrying out the state plan.other things, procedures that will be used to identify homeless children  and youth, strategies to address challenges, such as enrollment delays,  and a demonstration of the state’s efforts to review and revise policies to  remove barriers to the enrollment and retention of homeless children and  youth. Among other responsibilities, state educational agencies report  data to Education on the educational needs of their homeless students;  provide technical assistance to school districts and monitor their  compliance with the program; and facilitate collaboration between the  state and other service providers that serve homeless children and youth  and their families.
States are generally required to award no less than 75 percent of their  grant to school districts on a competitive basis. Grants to school  districts, awarded for a period of up to 3 years, are to be used for  activities that facilitate the enrollment, attendance, and success of  homeless children and youth in school. Grants to districts are to be  awarded based on the need of the school district for assistance and the  quality of the application submitted. In determining which districts to  fund, states are required to consider certain factors, such as the needs of  homeless children and youth enrolled in the school district, the types of  services to be provided under the program, and the extent to which the  services will be coordinated with other services available to homeless  children and youth. Districts are authorized to use these funds to support  a range of activities for homeless students, such as tutoring,  transportation, and referrals to health care services, as well as to provide  professional development for educators and support coordination  between schools and other agencies. According to Education data, in  school year 2011-12, fewer than a quarter of school districts nationwide  (3,531 out of 16,064) received EHCY program funds; these districts  enrolled 68 percent of the homeless students identified that year.
Education also allows states to use a regional approach to award their  competitive grants. Through such an approach, according to the National  Center for Homeless Education (NCHE),  a state may provide funds to established regional educational entities, geographic clusters of school  districts defined by the state, clusters self-selected by neighboring school  districts, or some combination of these approaches. According to  Education’s survey of states in school year 2010-11, the most recent  survey data available, 16 states reported that they provided funds through  an intermediate educational agency or consortia.
The “school of origin” is the school that the child or youth attended when permanently  housed or the school in which the child or youth was last enrolled. 42 U.S.C. §  11432(g)(3)(G). In determining the best interest of a child or youth, a district must, to the  extent feasible, keep a homeless child or youth in the school of origin unless doing so is  contrary to the wishes of the child or youth’s parent or guardian. 42 U.S.C. §  11432(g)(3)(A)-(B). immediately enroll in the selected school, even without the records,  such as proof of residency, typically required; and  receive services comparable to those offered to other students for  which they are eligible, such as transportation, educational services,  and free school meals.
section_title: Other Federal Programs that May Also Support Homeless Children and Youth
paragraphs: Other programs administered by Education and other federal agencies,  many of which receive more federal funding than the EHCY program,  may also support the needs of homeless children and youth (see table 1  for selected examples). For example, under Title I, Part A of the  Elementary and Secondary Education Act of 1965, as amended (ESEA),  school districts are required to set aside funds as necessary to provide  comparable services for homeless students who do not attend Title I  schools. In addition, grantee school districts are required to coordinate  with other organizations serving homeless children and youth, including  those operating programs funded under the Runaway and Homeless  Youth Act. The populations served by these programs vary, and for  some programs, eligibility for services does not depend on being  homeless. Among the programs that do target homeless populations,  some use definitions of homelessness that are different from the one  used by the EHCY program.
The McKinney-Vento Act also created the U.S. Interagency Council on  Homelessness (USICH), which currently consists of 19 federal cabinet  secretaries and agency heads. The Homeless Emergency Assistance  and Rapid Transition to Housing (HEARTH) Act of 2009 established as  the mission of USICH to coordinate the federal response to  homelessness and create a national partnership at every level of  government and with the private sector to reduce and end  homelessness.
section_title: Selected School Districts Leveraged Existing Resources to Identify and Serve Homeless Students, but Faced Resource Limitations and Other Challenges
subsections: section_title: Selected School Districts Largely Relied on Enrollment Forms and Referrals to Identify Homeless Students, but Faced Challenges and Noted Problems with Under-Identification
paragraphs: To identify homeless students, officials in a majority of school districts (13  of 20) said their districts systematically requested some information on  the housing status of new students using a form during the enrollment   Two of these districts also requested housing information from  process.every student every year to help identify eligible students whose housing  circumstances may have changed following enrollment. According to the  National Center for Homeless Education (NCHE), using a questionnaire  at enrollment can help school districts increase their identification of  homeless students (see fig. 1).
To identify students who were not identified at enrollment or whose  housing status changed during the year, homeless liaisons in the 20  school districts we interviewed also relied on referrals from school staff or  other service providers (see fig. 2). students who provide home addresses of shelters or other students;  students who request transportation changes;  students with attendance problems or who are tardy;  students who fall asleep in class; and  students with dropping grades, hunger, or hygiene issues.
Officials we interviewed also discussed the importance of training staff to  identify homeless students, as identifying currently enrolled students is  less systematic than identifying new students at enrollment.
Despite ongoing efforts to identify homeless students through housing  surveys and referrals, officials in 8 out of the 20 districts we interviewed  noted a problem with the under-identification of homeless students. All  four state EHCY program coordinators we interviewed acknowledged that  school districts face financial disincentives to identifying homeless  children and youth due to the cost of services districts must provide.
Officials from both grantee and non-grantee districts reported facing  significant challenges in identifying all eligible students.
subsections: section_title: Student Mobility
paragraphs: Officials in 11 of the 20 districts we interviewed said they identified  increasing numbers of homeless children and youth in recent years, and  many noted the frequent mobility of some students, making it challenging  for school staff to keep track of their homeless students.
section_title: Confusion Regarding Applying Eligibility Requirements
paragraphs: Officials in 4 of the 20 districts said it was challenging to identify children  and youth living doubled-up with others, particularly where living with  extended family may be a cultural norm. In such cases, families may not  consider themselves to be homeless or may be unaware of their rights to  receive services under the program. For example, officials in one district  told us that many of the district’s immigrant families who work for a local  meat processor live with relatives in doubled-up conditions but do not  consider themselves homeless. To help clarify program eligibility, one  district we reviewed used its enrollment form to ask parents or guardians  to check a box when they are “living ‘doubled-up’ due to economic  emergency, not to save money or for cultural preference.”
section_title: Limited Information from Housing Surveys
paragraphs: In one school district we reviewed, the enrollment form asks parents or  guardians to check a box “if the student is homeless or living in  temporary/transitional housing,” and asks whether the student is an  “unaccompanied youth,” but does not describe eligible housing situations.  As a result, a student who is living doubled-up due to economic  circumstances may not be identified, even though this situation  represents a majority of homeless students nationwide (see fig. 3).
Nationally, according to Education’s survey of grantee school districts in  school year 2010-11, homeless liaisons spent a median amount of nearly  2 hours per week on their responsibilities for the EHCY program. Many  liaisons said that they juggled multiple responsibilities, including duties  outside of the EHCY program. Officials in 7 of the 20 districts cited their  limited availability to provide training and outreach or the lack of  sufficiently trained school personnel as a challenge to identifying eligible  students. In one state we visited the state EHCY program coordinator  who surveyed homeless liaisons on the amount of time they spent on the  EHCY program said she has found a link between the amount of time  liaisons spend on the EHCY program and the number of homeless  students they have identified.
section_title: Confusion Regarding Terminology
paragraphs: One liaison said there is confusion around “awaiting foster care  placement,” a term used to describe some children and youth eligible for  the EHCY program. Specifically, the liaison told us that she would receive  requests for services for children in foster care, rather than for children  awaiting foster care placement.among the district’s many military families, the term “transition,”  sometimes used to describe eligible families, has a meaning unrelated to  homelessness.
section_title: Stigma
paragraphs: Officials in 7 of the 20 districts said that stigma around being identified as  homeless makes it challenging to identify eligible children and youth. One  formerly homeless student we interviewed described her initial  identification as very traumatic because she did not want anyone at  school to know about her housing status and did not want to be called  homeless. She said she would rather have received bad grades in high  school than have her teachers know of her situation. Another said that  she did not want anyone to know she was homeless but found it difficult  to hide when she had to resort to “couch-surfing” in the homes of many  different people.
section_title: Identification of Homeless LGBTQ Youth
paragraphs: Some officials we spoke with suggested the districts under-identify  unaccompanied homeless youth, including lesbian, gay, bisexual,  transgender, or questioning (LGBTQ) youth who tend to be  overrepresented in the homeless youth population. Officials in five  districts told us they are involved in efforts targeted to LGBTQ youth. For  example, an official in one of these districts said the district has been  involved in focus groups and worked with service providers on how to  better identify and serve these youth who may have separated from their  families due to their LGBTQ identification.
section_title: Fear of Government
paragraphs: Officials in 5 of 20 districts told us that some families fear being known to  government entities, such as child protective services, police, and  immigration services. For example, officials in one district said parents  may be afraid that the child protective services agency will remove their  children from their custody if they are discovered to be homeless.
section_title: Natural Disasters
paragraphs: Natural disasters, including floods and a hurricane that forced many  families from their homes, also presented challenges for some districts  we reviewed. To identify the large numbers of students displaced  simultaneously in these districts, officials working in four of five districts  we interviewed about their experiences with natural disasters relied  heavily on staff and outside resources (e.g., shelters and community  meetings). However, officials said that factors such as families’  unwillingness to self-identify and frequent mobility following the disaster  created challenges to identifying and serving students. For example,  officials in a district affected by heavy flooding said that immediately  following the flooding, families moved in with relatives or other families  and did not necessarily consider themselves to be homeless. However,  as time passed, the district had to identify families in another wave as  families again were displaced from where they initially had moved.
Under-identification can negatively affect homeless students’ ability to  access needed services and to succeed in school. For example,  according to a formerly homeless youth we interviewed, prior to being  identified as homeless during his final year of school, he had been  receiving Fs on his report card. After being identified, he received a bus  pass, school supplies, and a laptop—necessary supplies to help him  graduate. Although he faced significant pressures outside of school,  according to a school official, and challenges completing his schoolwork,  he graduated and was able to obtain employment. Another  unaccompanied homeless youth said that after he was identified as  homeless he received assistance with school work and clothing for an  internship, and was very happy to be able to stay at the same high  school. Some officials we interviewed noted that children and youth not  connected to school or other services can be particularly challenging to  identify, leaving them most at risk of failing to receive necessary services.
section_title: Selected School Districts Leveraged Resources to Serve Homeless Students, but Faced Resource and Coordination Challenges
paragraphs: Students experiencing homelessness have diverse needs, ranging from  school-related to more basic needs. Nationally, grantee school districts in  school year 2010-11 most frequently reported transportation to and from  school, family or student preoccupation with survival needs, and frequent  mobility from school to school as among homeless students’ greatest  barriers to school enrollment, attendance, and success, respectively,   Some officials  according to Education’s survey of these school districts.we interviewed cited similar barriers. For example, a high school principal  said that the most pressing need for homeless students in his school is  for a safe place to sleep, and students who are worried about where they  will sleep at night will not be focused on their studies. Some of the  homeless youth we spoke with also indicated that stable housing or food  were among their significant needs. Specifically, one unaccompanied  homeless youth we interviewed—who has lived with a series of family  members since leaving her mother’s home—said that while she currently  sleeps on the couch in her uncle’s house, she worries every day about  her next move as she does not know how long she will be allowed to stay.
To help address the needs of homeless students, grantee school districts  in school year 2010-11 reported providing a variety of services, according  to Education’s survey (see fig. 4).
subsections: section_title: Transportation
paragraphs: Officials we interviewed said their districts provided eligible students with  transportation to and from school, as required by the McKinney-Vento  Act, through means such as public transit, district buses, taxi cabs, gas  assistance and mileage reimbursements. Officials in 9 of the 20 districts  also said they collaborated with neighboring districts to transport  homeless students across district boundaries, such as by splitting  transportation costs or dividing responsibility for routes to and from  school.
The Consolidated Appropriations Act, 2014 authorized school districts to use ESEA Title  I funds to provide transportation for homeless students to their schools of origin.  Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, div. H, tit. III, 128 Stat. 5, 388  (2013). school that the family had requested. While district officials did not think  this was in the best interest of the child, officials said they did not think  they could refuse to provide transportation due to the distance. Some  district officials we spoke with also said coordinating transportation across  districts can be difficult. For example, billing and being billed by other  districts can be inefficient and problematic. A district transportation official  we interviewed noted the significant amount of administrative work it  takes to arrange a student’s transportation. For example, she said she  could spend an entire day trying to figure out how to free up a bus driver  to transport one homeless student to and from school when she also  needs to worry about the transportation of another 500 students.
section_title: Coordinating Educational Services
paragraphs: Officials in the districts we interviewed coordinated with other education  programs and districts to help address homeless students’ needs. For  example, some districts used ESEA Title I, Part A funds to provide  students with tutoring, uniforms, and funds for class fees, as well as  hygiene kits, clothing and laundry vouchers, among other things.  Officials in 7 of the 20 districts said these funds also supported salaries  for positions that support homeless students, such as EHCY program  staff, social workers and homeless student advocates. In addition,  officials in some districts said they have coordinated with staff from  special education programs to help facilitate services for homeless  students; migrant education programs to help identify homeless migrant  children; and in some instances, preschool programs to serve homeless  preschool-aged children. Officials in 5 of the 20 districts said their  preschool programs reserved spaces for homeless preschool-aged  children or prioritized these students for services, and in four of these  districts, officials said the district transported homeless preschoolers to  and from school. Some officials also described coordinating with other  districts. For example, officials in three districts said they coordinated with  other districts to help homeless students obtain partial credit for work  completed elsewhere but said that such efforts could be challenging. In  one extraordinary case, we spoke with an official who said he worked for  months to obtain a student’s transcript from an African refugee camp to  be able to eventually verify the student had received 33 credits,  exceeding the 22 necessary to graduate. According to a formerly  homeless youth we interviewed, receiving credit for work completed was  very important to help her meet graduation requirements as she moved  across the country twice during high school and attended a total of four  high schools.
Officials in 11 of the 20 districts we interviewed cited challenges due to  limited staff availability or resources with which to serve homeless  students and adequately address their needs. For example, a school  principal in a K-8 school we visited without full-time counselors or support  staff said homeless students there have access to about 30 percent of the  support services the school would like to offer them. In another high  school we visited, officials said there is a severe lack of resources at the  school to support homeless students. Specifically, according to officials,  teachers currently fund a “food closet” on nearly every floor of the high  school to meet the needs of hungry students.
section_title: Partnering with Community Organizations
paragraphs: To expand their ability to serve homeless students’ needs, district and  school officials also leveraged community resources to provide students  with access to additional services and supports. For example, some  officials we interviewed said that they referred homeless students or their  families to organizations and agencies that provide health and mental  health services, as well as to other community organizations, such as  food pantries and shelters for students’ pressing needs. Officials in 6 of  the 20 districts reported they assisted homeless youth in accessing public  benefits, such as for health care or food. Officials in some districts also  said they referred students to other federal programs, such as Head Start  and Runaway and Homeless Youth (RHY) programs, and housing  programs for services. In one district we visited officials said they  improved referrals for services by developing trainings for an interagency  committee comprised of various community stakeholders on resources  and services available to homeless students. However, officials said that  a lack of community resources affected their ability to meet student  needs. For example, officials in a number of school districts we  interviewed (9 of 20) said the lack of available or affordable housing  options made it challenging to address the needs of homeless children  and their families.
School districts also played an important role in addressing the needs of  students displaced by natural disasters and maintaining their school  stability. For example, in the immediate aftermath, officials we interviewed  in one of five districts about their experiences with natural disasters said  three schools were used as emergency shelters for families. Officials in  four districts said they received a great deal of community support  through donations—such as mattresses, heaters, food, clothing and  supplies—to help address the significant needs of displaced students and  families. However, officials also reported challenges in serving large  numbers of newly identified homeless students, sometimes without  additional funds for services. For example, one district without EHCY  grant funds spent $750,000 to transport displaced students to and from  school and to pay tuition to other districts where some students began  attending school, according to officials. Maintaining contact with families  through their moves was also a challenge for some officials we  interviewed. In one district, officials said they were unaware of the  number of students who have not returned to their school of origin or who  plan to relocate permanently to where they went after the storm. In  addition, officials in another district discussed the need for counseling  following the trauma that students faced in fleeing and coping with a  natural disaster.
Homelessness Following a Natural Disaster  Three families we interviewed who were displaced from their homes following a  hurricane—two of whom moved at least twice in the months following—told us of the  important role their children’s school played in helping to address their many needs. In  addition to transportation and school supplies, the school provided homeless families with  free before- and after-school care for students, food, gift cards, and clothing—some of  which were donated by other organizations, businesses, and school districts, within and  outside the state. According to school officials, families were also offered counseling  services, though meeting students’ needs for counseling has been a challenge. Officials  described how children faced significant trauma following the storm. For example, one  student carried a sibling on her back to escape rising floodwaters.
section_title: Federal and State Agencies Use Numerous Strategies to Collaborate to Improve Services to Homeless Students despite Barriers
subsections: section_title: The Federal EHCY Program Manager Collaborates with Officials from Other Education Programs, Federal Agencies, and States to Increase Awareness about Homeless Education
paragraphs: The federal EHCY program manager collaborates with officials from other  Education programs, federal agencies, and states (see table 2). These  collaborative efforts are designed to share information with other  programs likely to serve homeless students and increase awareness  about the EHCY program and the rights of, and services available to,  homeless students, among other things. In addition, the EHCY program  manager provides training and technical assistance to state program  coordinators. GAO has previously found that collaboration is essential for  increasing the efficiency and effectiveness of federal programs and  activities in areas where multiple agencies or programs have similar  goals, engage in similar activities, or target similar beneficiaries.
section_title: State Educational Agencies Collaborate with Other State Agencies, Service Providers, and School Districts
paragraphs: State EHCY program coordinators collaborate with other state agencies,  service providers and school districts to improve services to homeless  children and youth. The McKinney-Vento Act requires state EHCY  coordinators to facilitate coordination between the state educational  agency and other state agencies and to collaborate with school district  homeless liaisons, service providers, and community organizations,  among others. According to Education data from its survey of state  EHCY program coordinators covering school year 2010-11, 30 state  coordinators ranked coordinating with other organizations and agencies  to provide and improve services to homeless children and youth among   Thirty-six state  the three activities on which they spend the most time.coordinators reported that building programmatic linkages among various  programs, agencies, or organizations was among the top three  collaboration efforts that improved program administration and/or services  to homeless children and youth (see fig. 5).
The collaborative activities state EHCY program coordinators engage in  may vary depending on whether they are collaborating with school  districts, other programs, interagency councils, or non-governmental  entities (see fig. 6).
State EHCY program collaboration activities with other state agencies,  programs, service providers, and associations have included raising  awareness of the program, developing joint products, such as strategic  plans, and efforts to better connect students to services. For example,  state EHCY program staff in one state told us they collaborate with the  state’s health department and Children’s Health Insurance Program to  make sure students have access to immunizations and help homeless  families apply for health insurance for their children. Additionally, they  collaborate with the state agriculture department to ensure homeless  children have immediate access to free school meals. One state  coordinator told us that she has partnered with the 21st Century  Community Learning Centers (21st CCLC) program, which allowed the  state to increase the number of high schools receiving 21st CCLC funding  from 5 to 37 and increased the resources available to serve homeless  students. In addition, three state coordinators we spoke with told us that  they have worked with universities in their states to, for example, provide  information about students experiencing homelessness and barriers they  face to higher education. Officials in one state told us that this  collaboration has led over 30 public institutions of higher learning to  identify a single point of contact within the school to advocate for  homeless students.
section_title: Federal and State Agencies Face Similar Barriers to Greater Collaboration
paragraphs: 42 U.S.C. § 11432(f)(6). collaboration. For example, he only attends conferences for Title I and  other Education programs every few years. Similarly, while state EHCY  program coordinators we spoke with generally felt that there is significant  collaboration with other entities, several also told us that staff capacity  was a significant barrier to further collaboration. State coordinators are  generally responsible for managing the EHCY grant process, monitoring  and overseeing implementation of the EHCY program at the school  district level, and providing technical assistance and training to school  district personnel, including homeless liaisons; sometimes in several  hundred school districts. Many state coordinators have responsibilities in  addition to those for the EHCY program. According to Education’s survey  data from school year 2010-11, 23 of the 50 state EHCY program  coordinators reported working 30 hours or more per week on EHCY  program responsibilities. The same survey found that more than half of  the states (27) had one or fewer full-time employees working in the state  EHCY program office (see fig. 7). For example, one state coordinator we  spoke with was also the coordinator for another education program, which  she said takes up about 40 percent of her time.
According to state EHCY program coordinators, resource constraints  have prevented additional collaboration efforts. For example, three state  coordinators told us they must choose which partners to collaborate with  at the expense of others. In one of these states, this has meant limited  collaboration with RHY programs. In GAO’s previous work, we have  emphasized the importance of agencies identifying and leveraging  sufficient funding to accomplish their objectives and to initiate or sustain  their collaborative efforts and we suggested approaches to help them do  so.
Federal and state officials also said that differing definitions of who is  considered “homeless” under various federal programs was another  barrier to collaboration. Because the population eligible for services  under each program differs, the populations contained in data collected  by one agency will be different than in data collected by other agencies,  making data sharing more difficult. The federal EHCY program manager  told us that the lack of a consistent definition across programs  administered by Education and HUD has created a challenge to  increasing data sharing at the local level between school districts and   Because a relatively small number of  Continuums of Care (CoC).students considered homeless under Education’s definition may be  eligible for services funded by CoCs, these entities sometimes feel that  the additional work necessary to share the data is not worthwhile,  according to the EHCY program manager. Nationally, most homeless  students are “doubled up.” Officials from one state told us that because  this is the case in their state, though school districts want to provide wrap- around services that meet the wide variety of homeless youths’ needs,  these students may be ineligible for services through HUD programs.However, one school district in one of the states we reviewed has entered  into an agreement with the local CoC that allows school district personnel  to access and enter data into the CoC’s Homeless Management  Information System. This partnership allows the school district and CoC  partners to track the services homeless students have received, evaluate  the need for additional services, and make referrals for those services,  among other functions. A state EHCY program coordinator we spoke with  told us that a common definition would allow Education and HUD  programs to pool data, increasing collaboration and efficiency. This  official said that instead of redundant data collection, resources could be  used to provide additional services.
section_title: Education Currently Lacks a Comprehensive Oversight Plan and Faces Limitations in Using its Performance Data to Assess Program Results
subsections: section_title: Education Has Protocols for Monitoring State EHCY Programs but Lacks a Plan to Ensure Oversight of All States
paragraphs: Education has protocols and procedures in place to monitor state EHCY  programs. According to Education guidance, monitoring is the regular and  systematic examination of a state’s administration and implementation of  a federal education grant, contract, or cooperative agreement. To hold  states accountable to provide a free appropriate public education to  homeless students, Education evaluates the degree to which states  meet certain standards, called monitoring indicatorsThese include data on:   (see appendix II). monitoring of school districts; implementation of procedures to identify, enroll, and retain homeless  students by coordinating and collaborating with other program offices  and state agencies; provision of technical assistance to school districts; efforts to ensure that school district grant plans for services to eligible  homeless students meet all requirements;  compliance with statutory and other regulatory requirements  governing the reservation of funds for state-level coordination  activities; and prompt resolution of disputes.
Education’s monitoring involves a review of documents, followed by an  on-site or videoconference review, and preparation of a final report that  includes any compliance findings for which the state must take corrective  action (see fig. 8). Between fiscal years 2007 and 2009, Education’s  policy was to monitor 50 states and 3 other areas (i.e., 53 “states”)least once during that 3-year time period and it followed this policy.
Starting in fiscal year 2010, Education adopted a risk-based approach to  select states for monitoring to more efficiently target and prioritize limited  resources, resulting in longer gaps between monitoring visits in some  states. Education conducts an annual risk assessment to evaluate which  states have the highest risk of noncompliance, according to the EHCY  program manager. The agency weighs the following four risk assessment  criteria equally: the state’s academic proficiency levels for students  experiencing homelessness, the tenure of the state EHCY program  coordinator, whether there are multiple or recurring EHCY monitoring  findings, and a financial review of the state’s EHCY grant expenditures.Education also considers the size of the state’s EHCY grant allocation  and the length of time since a state was last monitored. Since Education  adopted this approach in fiscal year 2010, it has monitored 31 of the 53  states for the EHCY program—28 from October 2009 to September 2012  and 3 from October 2012 to July 2014. Of the 22 remaining states,  Education last monitored 7 states in fiscal year 2007, 6 in fiscal year  2008, and 9 in fiscal year 2009 (see fig. 9).
In the fall of 2012 Education began monitoring states that had received  waivers from certain ESEA requirements under an initiative Education  calls “ESEA Flexibility” and since that time, has monitored three states for  compliance with the EHCY program. Under Education’s ESEA flexibility  initiative, 44 of the 53 states currently have waivers from specific  requirements of the ESEA, as amended. In these states, Education has  conducted regular monitoring, but the monitoring only covers compliance  with the ESEA waiver requirements and does not include monitoring for  compliance with the EHCY program. As a result, the states with ESEA  waivers currently have little EHCY program oversight at the federal  level. Education officials cited the shift to a risk-based approach to  monitoring the EHCY program, the more recent need to focus on ESEA  flexibility waiver monitoring, and a lack of staff capacity as the primary  reasons why they have not been able to monitor the states as frequently  in recent years as in the past. Education officials said they intend to  continue to monitor the EHCY program in the future, but the agency has  not determined when or how it will do so. Standards for internal control  emphasize the need for federal agencies to establish plans to help ensure  goals and objectives can be met, including compliance with applicable  laws and regulations. Absent a plan for future monitoring of grantees,  Education cannot be sure that problems will be identified and resolved  promptly.
As a result of reducing the number of monitoring visits, Education has  been unaware of the compliance status of some states for an extended  period of time. According to GAO’s Standards for Internal Control in the  Federal Government, monitoring is a key management tool that helps  agencies assess the quality of performance over time and ensure that the   Additionally, one state EHCY program  problems are promptly resolved.coordinator we interviewed said that federal monitoring ensures a higher  level of compliance with the McKinney-Vento Act and that it is in a state’s  best interest to be monitored regularly. According to this program  coordinator, monitoring helps states improve how they address homeless  students’ needs and provides important leverage within the state to  ensure that program funds are used as intended. Of the 22 states that  Education has not monitored since at least fiscal year 2009, 10 had been  required to take corrective actions following their last review to address  compliance concerns. While Education found these actions to be  sufficient, according to officials, Education is currently unaware of  whether these states have remained in compliance and it is possible that  they (or other states) may have new or recurring compliance issues. For  example, one of the states we visited had not monitored its grantees on- site since school year 2008-09, whereas NCHE recommends states  monitor grantees on-site at least once every 3 years.
Under the McKinney-Vento Act, states are required to develop plans that describe how  they will implement the program and submit the plans to Education. 42 U.S.C. § 11432(g).  Education is responsible for reviewing state plans using a peer review process and  evaluating whether state laws, policies, and practices described in the plan adequately  address the problems of homeless children and youths relating to access to education and  placement as described in the plan. 42 U.S.C. § 11434(a). updated their plans with new activities and goals. Some states have  implemented programmatic changes since the plans were initially  required in 2002. For example, one state we visited changed its service  delivery model in recent years by adopting a regional approach to award  grants to lead school districts that are responsible for providing services  to other districts in their region. This state’s EHCY coordinator confirmed  that the state has not submitted any state plan updates to Education  since 2002. However, because Education is no longer consistently  monitoring all states for compliance, the agency is also unable to  determine whether states’ current practices are consistent with their  existing state plan. GAO’s Standards for Internal Control in the Federal  Government suggest that management continually assess and evaluate  whether internal control activities—such as reviewing and monitoring  compliance with state plans—are effective and up-to-date.
section_title: Education Survey Data and GAO’s Review Showed that States Generally Focused Their Monitoring on Grantee Districts and Not Non- Grantee Districts
paragraphs: The McKinney-Vento Act requires each state to describe in its plan how it  will ensure that all school districts comply with EHCY program  requirements, but does not specify how states must monitor compliance  or where they should focus their efforts. NCHE’s guidance to states on  monitoring districts acknowledges the challenge of monitoring all districts  on site annually—given resource constraints—and recommends that  states utilize a combination of strategies, such as on-site monitoring for  grantee districts and desk monitoring, i.e., phone calls or written  correspondence, for non-grantee districts. According to Education’s  survey of states in school year 2010-11, states use a variety of  approaches in monitoring districts. Most states (43 out of 50) monitored  grantees on-site and about half (26 out of 50) did so for non-grantees.  States also commonly use desk monitoring, with about two-thirds (34 out  of 50) using this approach for grantees and about half (26 out of 50) doing  so for non-grantees (see table 3).
The majority of states in Education’s survey also reported including the  EHCY program in the state’s monitoring of other federal programs for  both grantee districts (33 out of 50) and non-grantee districts (29 out of  50). States that monitor compliance for the EHCY program in this way  are able to reach additional districts without adding to the state EHCY  program coordinator’s responsibilities, one of a few strategies that NCHE  recommends to cover a large number of districts. For example, in one  state we visited, a review team monitors about 100 school districts per  year with a lengthy checklist for federal programs that includes the EHCY  program.
States focused their monitoring on districts that had received an EHCY  grant from the state, resulting in limited oversight of many non-grantee  districts. NCHE’s guidance indicates that states should monitor grantees  at least once during the grant cycle—which can be up to 3 years—and  non-grantees at least once every 3-to-5 years. According to Education’s survey, most states (39 out of the 46 that responded to this question) said  that they monitor grantees at least once every 2 years. Half (23 out of 46)  of the states that responded to this question reported monitoring non- grantees at least once every 2 years and the other half reported  monitoring them less frequently (see fig. 10). Additionally, 2 of 50 states  reported that they did not monitor non-grantees at all (see table 3).
Similarly, state EHCY program coordinators in three of the four states we  reviewed focused on monitoring grantees and employed a variety of  approaches, according to our interviews with the coordinators. One state  coordinator reported monitoring all grantee school districts on-site  annually. Two state coordinators reported monitoring grantees annually  using a combination of on-site visits and desk reviews, in which grantees  are monitored via phone and email and must send data to the state for  review. The fourth state coordinator we interviewed reported conducting  quarterly fiscal and program reviews in lieu of formal on-site or desk  monitoring for all of the grantees since school year 2008-09.
The four states we reviewed also varied with regard to how often they  monitor non-grantees. State coordinators in two of the four states we  reviewed regularly monitor all non-grantee districts within the 3 to 5 year  timeframe NCHE suggests. One state coordinator reported monitoring  non-grantees on a 3-year rotational basis. Another state coordinator uses  desk monitoring for all non-grantees annually and also uses a risk-based  approach to select non-grantees for on-site monitoring. state coordinators we interviewed do not regularly monitor non-grantees  within the suggested timeframe; however, one of these states annually  ensures that all districts have identified a homeless liaison.
States may not focus monitoring efforts on non-grantee districts because  they lack tools to enforce compliance. One state coordinator explained  that the state can record a finding of noncompliance, but because there is  no direct fiscal action or penalty attached to it, the district may disregard  it. Another state coordinator said she has to accept a district’s report of  zero homeless students, even if she suspects that the district may be  under-identifying them. In contrast, state coordinators we spoke with said  that states can hold districts with EHCY grant funding more accountable  because they have more direct leverage over them, in the form of the  grant. According to Education’s survey of states, 3 of 39 states that  responded to this question reported that they withheld funds from  grantees that were out of compliance.
This state’s EHCY program coordinator reported annually reviewing each district’s data  on homeless students and visiting those non-grantees with the highest risk of  noncompliance based on several risk factors, such as fewer than expected homeless  students identified given a district’s poverty rates; trends in under-identification; a high  number of disputes with neighboring districts and/or complaints from parents; and the size  of the district, with larger districts assumed to have a higher risk of noncompliance. districts were aware of the availability of services through the regional  structure adopted by the state. This state uses a regional approach for its  grantee districts, whereby the grants are distributed to lead entities that  are in turn responsible for ensuring that all homeless students within the  region receive appropriate services. To do this, the grantee district may  provide funds and/or services, such as training, to other districts in its  region. While we met with two lead grantee school districts that provided  services to other districts in the region, we also met with two other non- grantee districts whose officials were unaware that the district was eligible  for funds or services from their respective lead grantee districts, indicating  that the state’s regional model was not being implemented effectively.  Such problems suggest inadequate state-level monitoring of school  districts, reinforcing the importance of effective federal monitoring of  states.
section_title: Education Collects Performance Data but Faces Limitations in Using Them to Assess Program Results
paragraphs: Education relies on annual state performance data collected from school  districts to determine the extent to which states are meeting the  program’s intended goal of ensuring that homeless students have access  to a free appropriate public education (see table 4).
Education has increased the number of data elements it requires school  districts, particularly non-grantee districts, to report in the Consolidated  State Performance Report. For example, in school year 2010-11,  Education began requiring states to report information on the academic  achievement of homeless students in reading and mathematics from non- grantee school districts, data that had been required from grantee districts  since at least the 2004-05 school year. In school year 2011-12,  Education added corresponding data elements in science for all districts  to the Consolidated State Performance Report. In school year 2012-13,  Education began requiring states to report information on the number of  homeless students enrolled in each district, by certain subcategories.Previously, Education had only required states to report this information  by subcategory for grantee districts; for non-grantee districts, states were  only required to report the total number of homeless students enrolled  and their primary nighttime residence.
Education presents trends in data on homeless students over time in its  Consolidated State Performance Report; however, there are limitations  to the use of state-reported data to assess the program’s results. For  example, the state data on the number of homeless students are likely  incomplete or unreliable due in part to the under-identification of eligible  students. In Education’s survey of states, 13 of the 25 states that  responded to this question had found that at least one grantee was not in  compliance with the statutory requirement to identify homeless children  and youth. In one of the four states we reviewed, Education found the  data on the number of homeless students to be unreliable, which the  state EHCY program coordinator attributed to a 2009-10 transition to a  new, state-wide database system that led to undercounting homeless  students. Both Education and the state educational agency are taking  steps to address the state’s data quality issues, according to officials from  both agencies. Education officials told us that the under-representation of  the number of homeless students in the data generally is an area of  concern, which they are addressing in multiple ways. In addition to  questioning states about this issue, an Education official said the agency  has worked with a contractor who analyzed school district-level data in  every state to help identify school districts that may have been under- identifying homeless students by comparing their rate of homeless  student identification to the percentage of students receiving free or  reduced-price lunch. The contractor has made presentations on the  results of this analysis to state EHCY program coordinators, and  Education plans to provide state EHCY program coordinators with  additional technical assistance on outreach and identification.
Another limitation to the use of state-reported data is that, by design, the  data are difficult to compare across states. As GAO has previously  reported, states vary in how they measure student academic  achievement, as permitted by ESEA, to allow states to address their  unique circumstances. Education has acknowledged this inherent  limitation, as well as challenges in comparing data within states over time,  as many states have made changes to their state assessments that can  impact comparability. According to the Common Core State Standards  Initiative, a voluntary state-led initiative, 43 states and the District of  Columbia have chosen to adopt the Common Core State Standards— designed to define the knowledge and skills students should gain  throughout their K-12 education in order to graduate high school prepared  to succeed in entry-level careers, introductory academic college courses,  and workforce training programs. Most states have chosen to participate  in one of two state-led consortia working to develop assessments based  on these standards, expected to be available in school year 2014-15,  which may lead to greater comparability across states. Similarly,  according to agency officials, Education collects dropout and graduation  rate data, including disaggregated data for homeless students, but these  data are calculated differently in different states—making comparisons  across states problematic. GAO has previously reported on the use of  different state graduation rates, and recommended that Education provide  information to all states on ways to account for different types of students  in graduation rate calculations and assess the reliability of state data used  to calculate interim rates, which it did.
Aside from its annual data collection efforts, Education’s latest study  (forthcoming in 2014), which covers school year 2010-11, will provide  some valuable information on program implementation, according to  agency officials. The study collects information from surveys of state  EHCY program coordinators and grantee school district homeless liaisons  on topics such as their EHCY-related responsibilities; data collection and  use; collaboration with other programs and service providers; barriers  homeless students face to enrolling, attending, and succeeding in  schools; and state monitoring of districts’ compliance with the McKinney- Vento Act, among other topics.
section_title: Conclusions
paragraphs: The EHCY program, funded at about $65 million for fiscal year 2014, is  intended to remove barriers to educational achievement for homeless  students and provide them with access to critical services—such as  transportation to school and referrals for health care. Such services are  important to help mitigate the range of negative effects experienced by  homeless children and youth across an array of measures, including  academic achievement and school graduation rates. The program  identified more than 1.1 million homeless students in school year 2011- 12—students who, had they not been identified, might have faced greater  difficulties succeeding in school and preparing to graduate. To increase  the program’s effectiveness, school districts, states, and the federal  government leverage existing resources to ensure that homeless  students are identified and their various academic and non-academic  needs are met. The EHCY program promotes efforts to leverage  resources, in part, by requiring coordination and collaboration among  various programs and service providers that also serve homeless  students. Collaboration can be particularly important for districts and  communities addressing significant increases in homelessness following  natural disasters.
Appropriately identifying eligible students, in collaboration with other  providers, is key to ensuring that districts provide homeless students with  the services they need. However, challenges districts face in identifying  students coupled with potential financial disincentives to identify them due  to the cost of providing them with services such as transportation, can  lead to under-identification, which has several consequences. First, it can  result in barriers to homeless students’ educational stability and  achievement. Homeless children and youth who are not identified may  have difficulty getting to and from their school as their nighttime residence  changes and may therefore be derailed in their attempts to obtain an  education without the assistance available through the EHCY program.  Second, under-identification complicates Education’s ability to fully  assess program results due to concerns about the accuracy and  completeness of the data, which it has taken some steps to address.  Similarly, under-identification complicates the ability of the U.S.  Interagency Council on Homelessness to accurately assess progress  toward its goal of ending homelessness for families, youth, and children  by 2020.
While it may not be possible to accurately determine the extent to which  districts may be under-identifying students—and the extent to which these  children and youth may not succeed academically— monitoring states  and school districts is imperative to ensure compliance with the  requirements of the McKinney-Vento Act, particularly in light of the fact  that some states are implementing the program differently than described  in their state plans. Without monitoring states through regular reviews of  state programs and implementation plans, Education will not have the  information it needs to determine whether states are meeting  requirements that help provide eligible students with the resources  needed to pursue an education.
section_title: Recommendation for Agency Action
paragraphs: To help ensure state compliance with the McKinney-Vento Act, Education  should develop a monitoring plan to ensure adequate oversight of the  EHCY program. This plan could, for example, determine a schedule of  states to be monitored and incorporate procedures to assess whether  states need to update their state plans.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Departments of Education, HHS,  and HUD and to USICH for review and comment. Education and USICH  provided formal comments that are reproduced in appendices III and IV.
Education, HHS, HUD, and USICH also provided technical comments,  which we incorporated as appropriate.
Education agreed that sufficient oversight of EHCY program requirements  at the federal, state, and local levels is necessary and that both inter- agency and cross-program collaboration is essential to ensure that the  needs of homeless children and youth are addressed. Education noted  that although not all state EHCY programs have been monitored in recent  years, the department has continued to conduct risk assessments for all  states and to provide technical assistance to states and school districts  through the EHCY program office and NCHE.
Education concurred with our recommendation that, in order to ensure  compliance with the McKinney-Vento Act, the department should develop  a monitoring plan to ensure adequate oversight of the EHCY program.  Education said that it is currently developing a plan for monitoring for  fiscal year 2015 and will increase monitoring for the EHCY program,  ensuring that all states identified as “higher risk” in its next round of risk  assessments are monitored through document reviews, on-site and  remote interviews with state and local educational agency personnel. We  encourage Education to continue to consider the length of time since a  state was last monitored in its determination of risk and to consider  developing a monitoring schedule to help ensure that it has the  information it needs to determine whether all states are meeting EHCY  program requirements. Education also said that it is making changes to  its monitoring protocol, adding questions related to student academic  achievement and potential under-identification of homeless students. We  support Education’s decision to increase its EHCY program monitoring  and believe focusing additional attention on the issue of under- identification is particularly important. Without a fuller sense of the extent  of under-identification, it is difficult for Education to gauge program  results. Lastly, Education indicated that it plans to include the  development of a secure website through which states can update their  state plans in its next technical assistance contract. Since states may  have changed the way they implement the EHCY program since their  state plans were originally developed, we encourage Education to take  steps to ensure that states that need to update their plans do so.
USICH agreed that monitoring EHCY grantees is important to ensure  homeless children and youth are identified. USICH also noted the  important role that Education can play in fostering best practices,  strategic partnerships, and innovation to address the needs of homeless  students. USICH stated that it considers Education and the EHCY  program to be critical partners in developing and advancing the work of  USICH’s goal of ending homelessness among families, children, and  youth by 2020.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from its  issue date. At that time, we will send copies of this report to the  Secretaries of Education, HHS, and HUD, the Executive Director of  USICH, relevant congressional committees, and other interested parties.  In addition, the report will be made available at no charge on the GAO  Web site at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512- 7215 or Brownke@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made key contributions to  this report are listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: We used several approaches to obtain information on how school  districts, states, and the Department of Education (Education) implement  and oversee the Education for Homeless Children and Youth (EHCY)  program. To gather information on how the EHCY program is  implemented at the local level, we visited three states—Colorado, New  Jersey, and Washington State—and conducted interviews with a fourth  state, Texas, by phone. We selected states that represent geographic  diversity and were identified by experts, including the National  Association for the Education of Homeless Children and Youth  (NAEHCY) and other national organizations working on issues related to  homelessness, for their experiences in providing education to homeless  students. We identified these organizations during the course of our  background research. We also considered the number of homeless  students states identified in recent years, including any trends, the level of  program funding states received, and the delivery structure of early  childhood education programs in the state. In addition, we selected states  that experienced surges in homelessness due to recent natural  disasters—including wildfires, flooding, and a hurricane. Together, these  states included about 13 percent of identified homeless students  nationwide in school year 2011-12. In each state, we interviewed state  officials to obtain information on how they collaborate with other agencies,  service providers, and school districts, as well as their monitoring  practices. We also met with school district officials. In all, we spoke with  representatives from 20 school districts in the four states. We selected  school districts, with assistance from state EHCY program coordinators,  to represent a mix of urban, suburban, and rural districts, as well as  districts that received EHCY program funds (grantees) and those that did  not (non-grantees). In one state, we also met with representatives of two  regional educational entities that are responsible for providing EHCY- related services to several school districts within their respective regions  and receive EHCY program funds to do so. In the states we visited, we  also met with school officials at the elementary, middle, and high school  levels, and youth that have experienced homelessness, or their families,  about their educational experiences (12 youth and three families).  Information obtained from these states, school districts, youth, and  families is non-generalizable. We also attended the 2012 NAEHCY  Conference to obtain further insights into how school districts were  implementing the EHCY program and met with five additional state  coordinators at that conference to discuss how they collaborated with  various stakeholders.
To obtain generalizable and national-level information from states and  grantee school districts, we analyzed Education data from two surveys  covering school year 2010-11. Education’s surveys collected information  on services school districts provided to homeless children and youth;  state and local collaboration efforts with other Education programs; and  how states monitored school districts, including any differences in  monitoring among grantee and non-grantee districts. A total of 448 school  districts were included in the district-level survey sample, including the 50  largest school districts and a random sample of 401 other school districts  (3 districts were removed from the sample after the survey was released  because they had merged with other districts). The surveys were  conducted electronically, however, in a small number of cases (7 or 8)  districts that did not initially respond to the electronic survey were  administered the survey over the phone or on paper. The school district- level survey had a weighted response rate of 86 percent (96 percent for  the 50 largest districts and 85 percent for the remaining 398 districts).  The state survey was sent to all 50 states, the District of Columbia, and  the Bureau of Indian Affairs. The Bureau of Indian Affairs did not respond  and was later removed from the scope of the survey. One additional state  provided incomplete survey answers, leaving 49 states and the District of  Columbia as the state survey population. We assessed the reliability of  Education’s survey data by performing electronic testing of the data  elements, reviewing relevant documentation, and interviewing agency  officials knowledgeable about the data. We found that the data were  sufficiently reliable for the purposes of this report. The responses of each  eligible sample member who provided a useable questionnaire were  weighted in the analyses to account statistically for all members of the  population. We created weights for each survey respondent to account for  unequal probabilities of selection and various unit response rates among  the survey strata. All estimates obtained from the school district-level  survey have margins of error of no greater than six percentage points.
To obtain information on how Education administers the EHCY program,  we interviewed Education officials about how the agency monitors states  for compliance and collaborates with other federal programs. We also  interviewed officials from other federal agencies, including the  Departments of Health and Human Services (HHS) and Housing and  Urban Development (HUD), as well as the U.S. Interagency Council on  Homelessness (USICH), to obtain their perspectives on collaborating with  Education on programs that serve homeless children and youth. We also  interviewed Education officials about the agency’s monitoring efforts.  Additionally, we reviewed relevant documents—including federal laws  and regulations, monitoring protocols, and policy memos—and examined  Education’s findings on homeless education from state monitoring  reports.
We conducted this performance audit from July 2012 through July 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Education for Homeless Children and Youth Program Monitoring Indicators
paragraphs: Federal monitoring indicator  1.1: The state conducts monitoring and evaluation of school  districts with and without subgrants, sufficient to ensure  compliance with McKinney-Vento program requirements.
Selected examples of acceptable evidence that states provide  Written procedure for monitoring school districts with and without  subgrants to include:
Recent copy of monitoring policies and procedures, schedules for  current and previous school years.  Sample notification letters to school districts, preparation  checklists, or other forms.  A copy of the interview protocol for school district reviews.
Most recent copies of reports, recommendations and follow-up to  corrective actions.
2.1: The state implements procedures to address the  identification, enrollment and retention of homeless students  through coordinating and collaborating with other program  offices and state agencies.
Written communication to school districts updating state policies and  procedures that address the problems homeless children and youth  face in school enrollment and retention since the last Department of  Education program review.  Updates to the state plan, including the completion of planned activities  and proposals for new state-level activities.
2.2: The state provides, or provides for, technical assistance  to school districts to ensure appropriate implementation of  the statute.
Copies of written guidance to school districts and/or information  dissemination materials distributed electronically or by other means.  The most recent liaison orientation, on-line trainings, conferences, and  regional training agendas and technical assistant log.
3.1 The state ensures that school district subgrant plans for  services to eligible homeless students meet all  requirements.
Evidence that the state has an application and approval process to  provide competitive subgrants to school districts.
3.2: The state complies with the statutory and other  regulatory requirements governing the reservation of funds  for state-level coordination activities.
State budget detail on reserved funds for state-level coordination  activities for the current fiscal year and use of funds for the last fiscal  year.
3.3: The state has a system for ensuring the prompt  resolution of disputes.
Updated state dispute resolution policy and procedures including:  procedures for tracking disputes  documents indicating that dispute procedures have been  implemented  records indicating that disputes are addressed, investigated and  resolved in a timely manner  Evidence that the state tracks if school districts have a dispute  resolution policy in place.
section_title: Appendix III: Comments from the Department of Education
section_title: Appendix IV: Comments from the U.S. Interagency Council on Homelessness
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Kathryn Larin (Assistant  Director), Avani Locke (Analyst-in-Charge), David Barish, and Jennifer  Cook made key contributions to this report. Also contributing to this report  were Alicia Cackley, Sarah Cornetto, Keira Dembowski, Justin Fisher,  Hedieh Fusfield, Jessica Gray, Thomas James, Jean McSween, Mimi  Nguyen, Paul Schmidt, Almeta Spencer, Kathleen van Gelder, and Amber  Yancey-Carroll.
section_title: Related GAO Products
paragraphs: Managing for Results: Implementation Approaches Used to Enhance  Collaboration in Interagency Groups. GAO-14-220. Washington, D.C.:  February 14, 2014.
Homelessness: Fragmentation and Overlap in Programs Highlight the  Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491.  Washington, D.C.: May 10, 2012.
Homelessness: To Improve Data and Programs, Agencies Have Taken  Steps to Develop a Common Vocabulary. GAO-12-302T. Washington,  D.C.: December 15, 2011.
K-12 Education: Many Challenges Arise in Educating Students Who  Change Schools Frequently. GAO-11-40. Washington, D.C.: November  18, 2010.
Homelessness: A Common Vocabulary Could Help Agencies Collaborate  and Collect More Consistent Data. GAO-10-702. Washington, D.C.: June  30, 2010.
Runaway and Homeless Youth Grants: Improvements Needed in the  Grant Award Process. GAO-10-335. Washington, D.C.: May 10, 2010.
Disconnected Youth: Federal Action Could Address Some of the  Challenges Faced by Local Programs That Reconnect Youth to  Education and Employment.GAO-08-313. Washington, D.C.: February  28, 2008.