Low-Income and Minority Serving Institutions: Department of Education Could Improve Its Monitoring and Assistance
Published: 2004-09-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Congress has expanded the number of low-income and minority serving institutions eligible for grants under Titles III and V of the Higher Education Act and nearly doubled funding for these grants in the last 5 years to about $432 million in fiscal year 2004. Institutions eligible for funding under Titles III and V include Historically Black Colleges and Universities, Tribal Colleges, Hispanic Serving Institutions, Alaska Native Serving Institutions, Native Hawaiian Serving Institutions, and other postsecondary institutions that serve low-income students. Given the recent expansion, we examined these programs to determine (1) how institutions used their Title III and Title V grants and the benefits they received from using these grant funds, (2) what objectives and strategies the Department of Education (Education) has developed for Title III and Title V programs, and (3) to what extent Education monitors and provides assistance to Title III and Title V institutions.
section_title: What GAO Found
paragraphs: Grantees most commonly reported using Title III and Title V grant funds to strengthen academics, and they reported a wide range of benefits. Most grantees reported using their grants to fund efforts designed to strengthen academics, and we estimate that over three-quarters of the grantees reported initiatives that focused on improving student services (e.g., tutoring) and outcomes for students (e.g., course pass rates). The most commonly reported benefits were related to improvements in academic quality and student services and outcomes. While grantees reported a wide range of benefits, most also reported challenges in implementing their projects that sometimes resulted in the need for additional time at the end of the grant to complete their efforts. Education has developed objectives and strategies designed to strengthen Title III and Title V institutions by improving financial sustainability, technological capacity, academic quality, student services and outcomes, and institutional management. While Education has developed data to determine its progress in four of these areas, it is still in the process of developing data for measuring increased technological capacity. Education has developed plans and tools to enhance its monitoring of and assistance to Title III and Title V grantees, but it has made limited progress in implementing these initiatives. Specifically, Education has not fully implemented its monitoring plan or completed its new electronic monitoring tools, and a new training curriculum to enhance the monitoring skills of staff. We found that only one-quarter of staff conducted two required site visits, and most visits that were conducted were not selected based on the requisite risk criteria. Also, staff were not aware of updated department guidance and, as a result, did not always properly monitor grantees. We also found that Education's ability to provide technical assistance was limited. For example, Education has acknowledged that its failure to provide information on eligibility criteria has resulted in uncertainty about the eligibility of over three-quarters of Title V grantees.

section_title: Letter
paragraphs: Beginning in 1965, Congress created several programs under the Higher  Education Act (HEA) to support postsecondary institutions that provide  low-income and minority students with access to higher education.  Congress reaffirmed its commitment by expanding the number of  assistance programs in reauthorizing HEA in 1998 and has steadily  increased funding since then. Appropriations for these programs have  nearly doubled from about $230 million in fiscal year 1999 to about   $432 million in fiscal year 2004. Given the recent expansion of these  programs, we examined them to determine (1) how institutions used their  Title III and Title V grants and the benefits they received from using these  grant funds, (2) what objectives and strategies the Department of  Education (Education) has developed for Title III and Title V programs,  and (3) to what extent Education monitors and provides assistance to   Title III and Title V institutions.
To determine how institutions used Title III and Title V funds and the  resulting benefits, we developed a data collection instrument and  reviewed grant files for a stratified random sample of 104 of the 206 Title  III and Title V grant recipients, including the grant application, grant  performance reports, and related correspondence. Additionally, we  conducted site visits to nine of the postsecondary institutions included in  our sample based on type of program participation and geographic  proximity to one another. These institutions included four Historically  Black Colleges and Universities in Georgia, two Tribal colleges in North  Dakota, and three Hispanic Serving Institutions in Texas. To determine the  objectives and strategies Education has developed for Title III and Title V  programs, we talked with Education officials and reviewed program and  planning documents. To determine how Education monitors and provides  assistance to the Title III and Title V grantees, we interviewed Education  and postsecondary institution officials and reviewed documents, including  program policies and guidance. A more detailed explanation of our  methodology is included in appendix I. We conducted our work between  July 2003 and August 2004 in accordance with generally accepted  government auditing standards.
subsections: section_title: Background
paragraphs: Postsecondary institutions that serve large proportions of economically  disadvantaged students are eligible to receive grants from Education  through Title III and Title V of the Higher Education Act, as amended, to  improve academic quality, address institutional management issues, and  improve student services and outcomes. Institutions eligible for funding  under Titles III and V include Historically Black Colleges and Universities  (HBCUs), Tribal Colleges, Hispanic Serving Institutions (HSIs), Alaska  Native and Native Hawaiian Institutions, and other undergraduate  postsecondary institutions that serve low-income students. While these  institutions differ in terms of the racial and ethnic makeup of their  students, they serve a disproportionate number of financially needy  students, and have limited financial resources, such as endowment funds,  with which to serve them. (See app. II for characteristics of Title III and  Title V institutions and their students.) Title III and Title V legislation  outlines broad program goals for strengthening participating institutions,  but provides grantees with flexibility in deciding what approaches will  best meet their needs. An institution can use the grants to focus on one or  more activities that will help it achieve the goals articulated in its  comprehensive development plan—a plan that an applicant must submit  with its grant application outlining its strategy for achieving growth and  self-sufficiency. (See app. III for a description of how the grantees we  visited used the grants.) Table 1 briefly describes the characteristics and  eligibility criteria of Title III and Title V grant programs.
Since its inception, one of the primary missions of Title III has been to  support Historically Black Colleges and Universities, which play a  significant role in providing postsecondary opportunities for African  American, low-income, and educationally disadvantaged students. These  institutions receive funding through Title III, part B, in part, to remedy  discriminatory action of the states and the federal government against  Black colleges and universities. Until the Higher Education Act was  amended in 1998, other institutions that serve financially needy students— both minority serving and nonminority serving—competed for funding  under Title III, part A. In 1998, the Higher Education Act was amended to  create new grant programs designated for Tribal Colleges, Alaska Native  and Native Hawaiian Institutions, and Hispanic Serving Institutions. These  programs have provided additional opportunities for Minority Serving  Institutions to compete for Title III and Title V funding. Specifically, in  1999, 55 Hispanic Serving, Tribal, Alaska Native, and Native Hawaiian  Institutions were awarded new grants through the expanded programs.  Table 2 shows the increase in support since the new programs were first  funded in 1999.
The grant programs are designed to increase the self-sufficiency and  strengthen the capacity of eligible institutions. Congress has identified  many areas in which institutions may use funds for improving their  academic programs. Authorized uses include construction, maintenance,  or renovation of educational facilities; purchase or rental of  telecommunications equipment or services; support of faculty  development; and purchase of library books, periodicals, and other  educational materials.
section_title: Grantees Reported a Wide Range of Uses and Benefits for Title III and Title V Grants but Cited Some Implementation Challenges
paragraphs: In their grant performance reports, grantees most commonly reported  using Title III and Title V grant funds to strengthen academic quality and  reported a wide range of benefits. Specifically, we estimate that 87 percent  of the grantees reported using their grant funds to improve academic  quality, and an estimated 77 percent reported using their funds to improve  student services (e.g., tutoring) and student outcomes (e.g., course pass  rates). We estimate that over half of the grantees reported using their  funds for initiatives that focused on improving institutional management  and fiscal stability. A majority of the grantees cited benefits related to  improvements in academic quality and student services and outcomes, and  we estimate that over half of institutions reported benefits related to  institutional management and fiscal stability. However, our review of grant  files revealed that many institutions experienced challenges, such as  staffing problems, which resulted in implementation delays.
subsections: section_title: Efforts to Improve Academic Quality
paragraphs: Most of the grantees—ranging from one-half of Title III, part A Tribal  program grantees to all grantees in the Title III, part A Alaska Native and  Native Hawaiian program—reported focusing at least one of their grant  activities on improving academic quality. The goal of these efforts was to  enhance faculty effectiveness in the classroom by providing training and  development opportunities for faculty and to improve the learning  environment for students by improving academic offerings and providing  appropriate educational materials, such as laboratory equipment and  library materials. Some examples include:    Spelman College, a historically black women’s college in Georgia, used  part of its Title III, part B grant to fund a two-semester course that focused  on the dispersion of Africans throughout the world. This writing-intensive  course introduced students to their cultural background and how it relates  to the experiences of others in order to promote critical thinking and  interdisciplinary research. Spelman College has plans to develop a minor  in this area.
The University of the Incarnate Word, a Hispanic Serving Institution in  Texas, used most of its Title V grant to strengthen student learning by  focusing on four areas of faculty development: pedagogy, technology,  globalization, and mentoring. Specifically, the university conducted  technology workshops to promote the integration of technology into the  curriculum and provided funding for faculty to participate in summer  professional development programs and conduct international research.
Most of the grantees also reported that they derived benefits related to  their efforts to improve academic quality. An estimated 76 percent  reported enhancements to faculty development, including increased  faculty participation in professional development activities. We estimate  that 80 percent of the grantees reported improving academic quality by  making enhancements to academic programs, including revising and  developing courses, establishing new academic programs, receiving new  accreditations, and acquiring equipment, library books, and other  educational materials. Some examples of benefits derived include the  following:    At the University of the Incarnate Word, where most of the faculty have  received intensive technology training, over 200 members of the faculty  are using an online course management system as a Web-based  resource for instruction. Faculty can create Web pages for the courses  they teach, allowing students to access course syllabi and assignments  as well as communicate with their professor and other students in the  class.
The College of Southern Idaho, a Title III, part A Strengthening  Institutions grantee in Idaho, reported that with Title III funding it was  able to enhance more than 30 courses and develop a new accredited  health science program in radiologic technology. The college also  reported that two faculty members it provided fellowships had  completed advanced degrees by the end of the grant period.
Table 3 shows the distribution of uses and benefits related to improving  academic quality.
section_title: Efforts to Improve Support for Students and Student Success
paragraphs: We estimate that over three-quarters of the grantees—ranging from   55 percent of Title III, part A Strengthening Institutions grantees to nearly  all Title III, part B HBCU grantees—reported focusing at least one  initiative on improving student services and outcomes. This area includes  tutoring, counseling, and student service programs designed to improve  academic success, along with those efforts the primary focus of which is  increasing student outcomes such as retention and graduation rates,  academic achievement, and entering higher degree programs. Examples of  how grantees have focused their activities on improvements in this area  include:    Morehouse College, a historically black college in Georgia, used part of its  Title III grant to fund a wellness center for its all-male student body. The  center provides individual and group counseling and offers workshops and  seminars on topics like depression and the skills students need to achieve  academic success. The center also offers services to accommodate the  increase in students documented with learning disabilities.
United Tribes Technical College, a tribal college in North Dakota, focused  on increasing retention and persistence of its students by using its   Title III grant to renovate a one-stop center for student services, pay  tutors, and equip a wired computer laboratory in the facility.
The University of Texas at San Antonio, a Hispanic Serving Institution in  Texas, used most of its Title V grant to establish learning communities  where students enroll in clusters of courses in which the course content is  linked. At the heart of the learning communities is the Freshman Seminar,  a course that introduces students to resources that will help them succeed  in college.
We estimate that 62 percent of the grantees reported that they derived  benefits related to their efforts to improve student services, and an  estimated 75 percent reported that they derived benefits related to their  efforts to increase student outcomes. In the area of student services,  grantees primarily reported increases in the numbers of students using  student services, such as counseling and tutoring. Increase in student  retention was the most commonly reported benefit in the area of student  outcomes. For example, Laredo Community College, an HSI in Texas, used  its Title V award to construct and renovate science facilities to meet the  growing demand for science courses. With state-of-the-art laboratories, the  college reported subsequent improvements in outcomes for science  students, such as increases in course pass rates, retention, and enrollment  in further postsecondary study. Table 4 shows the distribution of uses and  benefits related to improving student services and outcomes.
section_title: Efforts to Improve Institutional Management
paragraphs: We estimate that 54 percent of the grantees reported focusing at least one  activity on improving institutional management, which comprises the  efforts to increase capacity and manage institutional operations. Examples  in this area include improving the technological infrastructure, providing  training and development opportunities for noninstructional staff,  constructing and renovating facilities, establishing or enhancing  management systems, and establishing an institutional research office,  among others. Nearly all grantees in the Title III, part B HBCU program  and half of the grantees from the Title III, part A Tribal Colleges program  indicated that at least one activity focused on improving institutional  management. For example,    Stone Child College, a tribal college in Montana, reported that it used  part of its Title III grant to implement an institutional assessment  program that involves a comprehensive assessment of all instructional  programs and services.
Tougaloo College, a historically black college in Mississippi, reported  that it used grant funds to support institutional research, assessment,  and planning activities, as well as repairing and renovating facilities to  enhance the appearance and safety of the campus.
An estimated 84 percent of the grantees reported that they derived  benefits related to their efforts to improve institutional management,  primarily by enhancing technology. We estimate that two-thirds of  grantees reported technology-related benefits, including overall  improvements to the technological infrastructure, increases in the number  of classrooms wired for the Internet, and increases in Internet access and  the numbers of computers available to faculty and students. Several of the  grantees we visited credited Title III and Title V programs with helping  them to stay current technologically. For example, Morehouse College  credited Title III funding with helping the institution establish a  technological infrastructure. Title III paid for the installation of high-speed  Internet lines, wiring all buildings on campus, including dormitories, and  connecting all the buildings to a common network. An official at  Morehouse told us that the college’s emphasis on technology stems from  the need to compete with other institutions for the best students and to  ensure that students graduate with technology skills that are necessary for  the workplace. Table 5 shows the distribution of uses and benefits related  to improving institutional management.
section_title: Efforts to Improve Fiscal Stability at Grantee Institutions
paragraphs: We estimate that about one-half of the grantees reported focusing at least  one of their activities on improving fiscal stability, and there was wide  variation across programs. Examples of ways grantees can use grant  funds to improve fiscal stability include such activities as establishing or  enhancing a development office to improve contributions from alumni and  the private sector, establishing or improving an endowment fund, and  increasing research dollars. Seventy-one percent of grantees in the Title  III, part B program, and 63 percent of grantees in the Title III, part A Tribal  Colleges program reported at least one activity focused on improving  fiscal stability. Only one grantee from the Title III, part A Alaska Native  and Native Hawaiian program had an activity focused on improving fiscal  stability, which may be due to greater limitations on how Alaska Native  and Native Hawaiian institutions have been able to use funds in this area.  For example, Alaska Native and Native Hawaiian institutions have not  been able to use grant funds to improve endowment funds, whereas  grantees in the other programs have. One example of how a grantee has  used funds to improve fiscal stability is:    Sitting Bull College, a tribal college with campuses in North Dakota and  South Dakota, used grant funds to develop its fund-raising capacity and  to establish an endowment. Because the college does not receive any  state funding, it relies heavily on federal funding, primarily from the  Bureau of Indian Affairs. College officials think that increasing fiscal  stability is central to becoming more self-sufficient.
An estimated 57 percent of the grantees reported that they derived  benefits related to their efforts to improve fiscal stability, primarily  through endowment building. Grantees from the Title III, part A Tribal  Colleges program and Title V, part A HSI program reported increases in  their endowments most frequently. Laredo Community College, an HSI in  Texas, was able to establish an endowment that will provide scholarships  for math and science students in perpetuity. Over 5 years it matched  $250,000 from its Title V grant with private contributions. Officials said as  a 2-year institution, the college didn’t have much experience with fund  raising prior to the grant, and having the ability to use federal funds to  match private donations energized both the campus and the community to  raise funds. These fund-raising efforts have led to endowments for other  academic programs, such as business and nursing. Table 6 shows the  distribution of uses and benefits related to improving fiscal stability.
section_title: Grantees Cited Implementation Challenges
paragraphs: While grantees reported a wide range of uses and benefits, most grantees  also reported challenges in implementing their projects. We estimate that  80 percent of the grantees reported at least one challenge related to the  implementation of the grants. Difficulties related to hiring and staffing  were the most frequently cited, with an estimated 46 percent of grantees  indicating this had been a problem. For example, officials from Sitting  Bull College told us that its remote location made it difficult to attract and  retain qualified personnel. To address this problem, the institution has  focused on providing training and education to faculty and staff to develop  talent from within the college. Other challenges were not cited frequently  but included construction delays, challenges implementing technology and  distance learning, and state budget shortages.
As a result of implementation challenges, grantees often needed additional  time to complete planned activities.  According to department regulations,  grantees generally have the option of extending the grant for 1 year after  the 5-year grant cycle has ended to obligate remaining funds.  According to  Education, for example, 45 percent of the 55 grantees in the Title III, part  A Strengthening Institutions program that ended their 5-year grant period  in September 2003 had an available balance greater than $1,000, ranging  from 0.5 percent (about $8,000) to 19 percent (about $328,000) of the total  grant. Sixteen of the 25 institutions that had carryover greater than   $1,000 continued to draw down funds in the year following the 5-year  grant. In the Title III, part B program, 80 percent of the 96 grantees that  ended their 5-year grant period in September 2002 had funds remaining at  the end of the 5-year period, ranging from 0.09 percent (about $12,000) of  the total grant to 40 percent (about $2.2 million) of the total grant.  According to department officials, all of these grantees indicated they  would take the additional time they are allowed to spend the funds.  Department officials told us that unexpended funds are common among  HBCUs because they often use these funds to supplement large  construction projects, which take several years to complete.
section_title: Education Has Developed Objectives and Strategies to Strengthen Institutions and Is Developing Corresponding Performance Information
paragraphs: Education has developed objectives and strategies designed to strengthen  Title III and Title V institutions by improving financial sustainability,  technological capacity, academic quality, student services and outcomes,  and institutional management.  Education has developed five measures to  assess its progress in achieving its objectives and is still in the process of  developing data for one of these measures.
subsections: section_title: Education Developed Objectives and Strategies Designed to Strengthen Institutions
paragraphs: Education has established a series of objectives and strategies for its Title  III and Title V programs. In its 2002-2007 strategic plan, Education  established an objective to strengthen HBCUs, HSIs, and Tribal Colleges.  To achieve this objective, Education has developed supporting strategies  to assist grantees in enhancing financial sustainability and increasing  technological capacity. Education has used annual meetings for grantees  as a forum to provide technical assistance to institutions on financial  management issues and to promote technological capacity. Education has  also established objectives in its annual program performance plans to  improve academic quality, fiscal stability and institutional management,  along with student services and outcomes.
To assess its progress in meeting the objectives it established in its  strategic and program performance plans, Education has developed five  performance measures. To determine its progress in its strategic objective  to strengthen HBCUs, HSIs, and Tribal Colleges, Education established  performance measures related to financial sustainability and technological  capacity. Specifically, Education established a performance target that by  fiscal year 2007 it will increase the percentage of institutions with a  positive fiscal balance—Education’s measure of financial sustainability— to 99 percent from the fiscal year 1999 baseline of 69 percent. Education  also established a performance target for increasing the percentage of  institutions that increase their investment in technology. To determine its  progress in meeting the objectives in its program performance plan,  Education has set a target that at least 75 percent of the goals grantees  establish related to (1) academic quality, (2) fiscal stability and  institutional management, and (3) student services and outcomes will be  met or exceeded.
section_title: Education Is Making Progress in Developing Performance Data
paragraphs: Education has developed performance data for one of the two  performance targets established in its 2002-2007 strategic plan and has  developed performance data for its program performance plan targets.  Specifically, Education has developed performance data to determine its  impact in increasing financial sustainability and is in the process of  developing data to determine its impact on technological capacity at  institutions. Regarding its goal to increase financial sustainability, the  department reported that the percentage of institutions with a positive  fiscal balance decreased slightly from 71 percent in fiscal year 2001 to   69 percent in fiscal year 2002, falling below the original target that it  established for fiscal year 2002 of 74 percent. In its 2002-2007 Strategic  Plan, the department set a goal that 84 percent of institutions have a  positive fiscal balance by 2004. Education subsequently lowered its target  for 2004 to 70 percent to reflect decreases in state contributions to higher  education—a significant source of funding for most Title III and Title V  institutions—to which it attributed the decline in fiscal balance  performance. To measure its progress in meeting its objective to  strengthen HBCUs, HSIs, and Tribal Colleges through improved  technological capacity, Education expects to report later in 2004 on the  impact of its efforts in this area using information on technology-related  activities reported by grantees in recently submitted annual grantee  performance reports. Education has developed data for the performance  measures in its program performance plan.  Regarding its goals to improve  academic quality, fiscal stability and institutional management, and  student services and outcomes, Education exceeded its fiscal year   2002 performance targets for each of the three measures based on data  taken from its annual grantee performance reports.  Figure 1 illustrates the  measures Education has developed to measure progress in achieving its  objectives, along with its progress in developing data to determine  whether it is meeting its performance targets.
section_title: Education Has Not Fully Implemented Its Initiatives to Improve Monitoring and Assistance, Resulting in Limited Monitoring and Assistance
paragraphs: Education has taken steps to enhance its monitoring of and assistance to  Title III and Title V grantees by developing monitoring plans; creating  electronic monitoring (e-monitoring) tools, such as the performance  reports submitted by grantees to document performance; and providing  additional training to department staff to develop their monitoring skills.  However, Education has yet to fully implement many of these initiatives.  We found that Education has not fully implemented its monitoring plan,  made full use of its new electronic monitoring tools, or completed  development of a new training curriculum for program staff. Additionally,  we found that Education’s ability to target assistance was limited and that  it has not made full use of grantee feedback for targeting assistance. As a  result, Education’s monitoring and assistance have been limited.
subsections: section_title: Education Has Taken Some Steps to Improve Its Monitoring and Assistance Activities
paragraphs: Education has created monitoring plans, electronic monitoring tools that  document grantee progress, and training opportunities for staff. Some of  these steps have been undertaken in response to reports issued by  Education’s Inspector General in 1996 and 2000, which identified the need  for systematic monitoring of the department’s Title III and Title V  programs.
subsections: section_title: Created Monitoring Plans
paragraphs: In 2002, Education’s Deputy Secretary directed each program within the  agency to develop a monitoring plan to place greater emphasis on  performance monitoring for all grantees. In addition to asking whether  grantees were achieving results, program officials were also to consider  what assistance could be provided by Education to help grantees  accomplish program objectives and incorporate in their planning an  increased departmental emphasis on compliance with the law and  guarding against potential risks. In response to the Deputy Secretary’s  directive, Education developed a monitoring plan for Title III and Title V  grantees that calls for department staff to (1) conduct risk assessments,  (2) perform a minimum number of site visits each year, and (3) follow up  with grantees regarding their performance reports.
In assessing risk, department staff are to review a variety of sources,  including annual performance reports, and consider 19 factors affecting  the ability of the grantees to manage their grants in the areas of project  design, administration and implementation, funds management,  communication, and performance measurement. According to the  department’s plan, on the basis of the results of risk assessments, staff are  to follow up with grantees that have issues and select at least two for site  visits. Follow-up can take many forms, ranging from telephone calls and   e-mails to on-site compliance visits and technical assistance. Technical  assistance can involve many activities designed to aid the institution in its  administration of the grant. Although Education’s preferred approach is to  try to inform grantees of steps they can take to address grant  administration issues, grantees can also be subject to some restrictions  based on risk assessments. For instance, if a grantee is designated as “high  risk,” Education can impose conditions on the grantee’s ability to access  grant funds. The risk factors used by Education to identify high-risk  grantees are listed in Table 7.
In response to a 2000 Inspector General report that found Education  needed a systematic approach to monitor Title III grantees, including  resolving and enforcing compliance issues, Education developed and  piloted electronic monitoring tools designed to enable department staff to  standardize monitoring practices and better track performance and fiscal  problems. These tools include (1) an e-monitoring system that maintains  and tracks daily interactions with grantees, (2) an online institutional  performance reporting system, (3) an improved automated payment  tracking system, and (4) an electronic on-site monitoring report.  Education has implemented its online institutional performance reporting  system and intends to begin implementing the other tools across its  programs by the end of fiscal year 2004. Officials we spoke to indicated  that some of these actions were either in the final stages of development  or being piloted with other grant programs.
The department’s e-monitoring system is designed to access funding  information from existing systems, such as its automated payment system,  as well as to access information from a departmental database that  contains institutional performance reports. Education anticipates that the  system will improve its monitoring process by providing staff ready access  to such important information as regulatory citations and alerting staff to  needed monitoring actions. Officials think moving to electronic monitoring  from a paper-based process will improve recordkeeping and  documentation, enhancing the ability to identify and track areas of  concern for individual grantees and across the programs.
Also, as a key component of its e-monitoring system, Education has  developed the online institutional performance reporting process.  Specifically, Education implemented an annual reporting process in fiscal  year 2003 that requires grantees to submit standardized information about  their performance electronically. As a result, the new performance reports  were designed to allow department staff to more quickly and  systematically identify and follow up with grantees on difficulties they are  facing regarding their grants. Also, department staff are required to review  these reports to assess whether adequate progress has been made to  justify continued funding.
Education is also in the process of redesigning its automated grant  payment system to provide information staff need to monitor grantee  transactions and to connect it with its e-monitoring system. In a   2003 report on its monitoring efforts, Education indicated that program  staff would be heavily engaged in the redesign of its automated payment  system to identify problems and necessary modifications associated with  the system’s usage. Additionally, because the system was designed to  reflect mostly financial information about grantees and not as a  performance monitoring system, Education plans to make information  from its automated payment system accessible through its e-monitoring  system to eliminate the number of systems program staff have to access to  monitor grantees.
Education also plans to launch an electronic on-site review report to  better target its assistance and increase Education’s ability to track and  resolve findings identified during on-site reviews. This tool is designed to  reinforce adherence to the department’s standardized reporting format  that is to be used during on-site reviews. The electronic report will be  integrated with the e-monitoring system.
section_title: Plans to Expand Training
paragraphs: To improve its training program, Education has developed a corrective  action plan to provide courses over the next 3 years to address the training  needs of its staff. In its fiscal year 2004 monitoring plan, Education  reported that there is a need to move beyond the generic training that is  traditionally offered to staff toward training that has both real world  applications and a programmatic context. Consequently, Education’s  training plan called for training to provide specific guidance on its new  monitoring procedures.
section_title: Lack of Progress Implementing Initiatives Has Resulted in Uneven Monitoring and Assistance
paragraphs: We found that the department’s lack of progress in implementing its plans  to improve monitoring activities, automate related processes, and train its  staff has resulted in uneven monitoring and assistance for Title III and  Title V grantees. For example, we found that Education has yet to make  full use of its risk-based plan to select grantees for its monitoring visits  and technical assistance. In fact, our review of site visit documentation  showed that risk factors were only employed to select 5 out of 26 grantees  visited in fiscal year 2003. Of these 26 institutions, most had been selected  according to other factors such as geographic proximity to another  grantee. Staff we met with acknowledged that they had not conducted  risk assessments for their grantees, and most were unaware of the new  requirement to do so. We also found that only one-quarter of department  staff completed two site visits in fiscal year 2003, as required.
Because the department had not completed its e-monitoring efforts, it has  continued to rely on paper-based monitoring systems, which have not  provided complete, consistent, and timely information used in monitoring.  For example, during our review of grantee program files, Education could  not locate 3 of 112 files we requested. Additionally, another 11 files did not  contain all required materials, such as institutional performance reports.  Further, the department could not fully account for and provide  documentation of completed site visits. These files are the primary  resource used by department staff to inform monitoring and assistance  efforts.
Finally, because the department has not yet implemented its new training  curriculum, its staff were not aware of updated department guidance and  as a result did not always follow department guidelines for monitoring  grantees. For example, department staff told us they did not conduct  required site visits because of a lack of preparation related to inadequate  training. One senior department official we spoke with agreed that existing  training was inadequate, adding that the training could not translate the art  of monitoring to inexperienced department staff.
section_title: Education’s Ability to Target Assistance Has Been Limited
paragraphs: While Education provides technical assistance through conferences, pre- application workshops, and routine interaction between program officers  and grantees, a senior department official acknowledged that Education  needs to do more to target technical assistance. He said that one of the  department’s goals is to move from focusing on the process of awarding  grants to a more programmatic emphasis where the needs of the grantees  guide the services that are offered. One of the key areas of technical  assistance that Education is targeting for improvement is educating  grantees about eligibility criteria. In response to concerns Education’s  Inspector General raised about awards made in the Title V, part A  Developing Hispanic Institutions program, earlier this year Education  completed a review of all Title V grantee files to determine whether  grantees were eligible for the awards. On the basis of this review,  Education concluded that there were questions surrounding the eligibility  of more than three-quarters of the 220 grantees that have received funds  through the program. Education found that 12 institutions should not have  received grants because their percentages of low-income Hispanic  students were below the required 50 percent. In other cases, the  department indicated that it could not determine eligibility because  institutions made calculation errors, institutions did not report  percentages, or the institutions’ calculation methods could not be  determined. The department concluded that 47 of the grantees used the  correct calculation method and met the eligibility assurance requirement  that at least half of its Hispanic students are low-income but noted that  there were still concerns that some of these institutions may have had  documentation problems. Education has attributed these irregularities to  confusion about how to meet eligibility requirements stemming from  insufficient guidance it provided to applicants as well as an institutional  lack of systematic data collection.  As a result, Education decided that it  would not take action in this specific instance against any of the grantees  with eligibility concerns. Education has taken steps to address the  problem, including developing new guidance for applicants and verifying  all eligibility assurances that applicants submit. Education plans to assist  grantees with the eligibility process at pre-application workshops.
Education’s ability to target assistance is limited in two ways: it does not  readily use the feedback it obtains from grantees, and its feedback  mechanisms may not encourage open communication. For example, a  senior official told us that feedback Education collected via surveys from  grantees at conferences has not been used in planning assistance efforts.  Additionally, one of Education’s feedback mechanisms may limit  communication because it identifies grantees and is tied to funding  decisions. Specifically, Education provided grantees with the opportunity  to comment on ways to improve the services the department provides in  their annual performance reports, which department staff review to  determine whether sufficient progress has been made to continue funding.  Department officials told us that Education is considering ways to collect  feedback from grantees separate from the performance reporting process  for all its grant programs.
section_title: Conclusions
paragraphs: Congress has demonstrated its support for Title III and Title V programs  by expanding the number of institutions covered and by nearly doubling  funding to these programs since 1999. Title III and Title V programs are  designed to provide additional resources to institutions that face  challenges providing a quality education to low-income and minority  students who are typically underrepresented in postsecondary education.  While Title III and Title V programs provide important resources to  address some of the most critical needs of these institutions, the need for  monitoring and assistance does not end with the award of a grant. These  institutions, because they have limited resources, sometimes need  additional assistance to help them implement their projects. Consequently,  Education’s role in monitoring and providing assistance to Title III and  Title V grantees is critical to the success of these programs. Education has  taken steps to enhance its monitoring and assistance efforts. However, by  failing to carry out an effective process to identify and target oversight and  assistance to at-risk grantees, Education has fallen short of ensuring that  these institutions have all the tools they need to fulfill the programs’  objectives. Education recognizes that it must work in partnership with its  grantees to enhance the quality of and access to postsecondary education  and has put in place plans that would allow it to better monitor and assist  grantees. Education needs to fully implement these plans to provide  oversight and assistance to those institutions most in need.
section_title: Recommendation
paragraphs: We recommend that the Secretary of Education take steps to ensure that  monitoring and technical assistance plans are carried out and targeted to  at-risk grantees and the needs of grantees guide the technical assistance  offered. These steps should include completing its automated monitoring  tools and training programs to ensure that department staff are adequately  prepared to monitor and assist grantees and using appropriately collected  feedback from grantees to target assistance.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Department of Education for  review and comment. In written comments on a draft of this report, the  Department of Education agreed with our recommendation to carry out  and target its monitoring and technical assistance plans to at-risk grantees.  Education has made a commitment to complete the implementation of its  monitoring, training, and technical assistance efforts in a timely manner.   Education also provided technical comments, which we incorporated  where appropriate. Education’s comments appear in appendix IV.
Copies of this report will be sent to the congressional committees and  subcommittees responsible for the Higher Education Act; the Honorable  Joshua Bolten, Director, Office of Management and Budget; and other  interested parties. Copies will also be made available to others upon  request. In addition, this report will be available at no charge on GAO’s  Web site at http://www.gao.gov.
If you have any questions about this report, please contact me on   (202) 512-8403 or Bryon Gordon at (202) 512-9207. Other contacts and  acknowledgments are listed in appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We reviewed Title III and Title V grant programs to determine (1) how  Title III and Title V institutions are using the grants and the benefits they  have derived, (2) what objectives and strategies the Department of  Education (Education) has developed for Title III and Title V programs,  and (3) to what extent Education monitors and provides assistance to Title  III and Title V institutions.
To determine how institutions used the funds and the benefits derived, we  reviewed grant files for a stratified random sample of 104 of the 206 Title  III and Title V individual development grant recipients. We reviewed grant  applications and grantee performance reports to develop a standardized  data collection instrument. We completed the data collection instrument  for each grantee in our sample, and each record was independently  reviewed by another staff person for clarity and accuracy.
To identify these recipients, we obtained from Education a list of grantees  for specific grant cycles. The grant cycles were chosen to allow us to  review documentation from as many years of the 5-year grant cycle as  possible or to allow for the review of comparable information. For  example, we selected 1999-2004 as the grant cycle for grantees from three  of the programs in our review because 1999 was the first year awards were  made in these programs. For the Title III, part B program, we looked at  available data from the 2002-2007 grant cycle because performance reports  comparable to those provided by grantees in other programs were not  available from a previous grant cycle. The grant cycles are shown in   Table 8.
We stratified our sample by the five programs and within these strata  randomly selected grantees. Our sample was statistically drawn and  weighted so that we could generalize the results of our review across  programs. As with all samples, our review of grant files is subject to  sampling errors. The effects of sampling errors, due to the selection of a  sample from a larger population, can be expressed as confidence intervals  based on statistical theory. Sampling errors occur because we use a  sample to draw conclusions about a larger population. If a different  sample had been taken, the results might have been different. To recognize  the possibility that other samples might have yielded other results, we  express our confidence in the precision of our particular sample’s results  as a 95 percent confidence interval. The 95 percent confidence interval is  expected to include the actual results for 95 percent of samples of this  type. Our sample sizes were selected to give us results within +/- 10  percentage points of what we would have obtained if we had surveyed the  entire study population within each program. Because we included the  entire population for the Title III, part A programs that cover Tribal  Colleges, Alaska Native Institutions, and Native Hawaiian Institutions,  there is no sampling error associated with the results presented for these  programs. Each sample element was subsequently weighted in the analysis  to account for all members of the population, including those that were  not selected. When we make estimates to the entire population of  grantees, we are 95 percent confident that the results we obtained are  within +/- 7 percentage points of what we would have obtained if we had  included the entire population within our review unless otherwise noted.
We analyzed data from the Integrated Postsecondary Education Data  System (IPEDS) to better understand the kinds of students they serve.   To assess the completeness of the IPEDS data, we reviewed the National  Center for Education Statistics’ documentation on how the data were  collected and performed electronic tests to look for missing or out-of- range values. On the basis of these reviews and tests, we found the data  sufficiently reliable for our purposes. Additionally, we conducted site  visits to nine of the postsecondary institutions included in our sample  based on type of program participation and geographic proximity to each  other. These institutions included four Historically Black Colleges and  Universities in Georgia, two Tribal colleges in North Dakota, and three  Hispanic Serving Institutions in Texas.
To determine what objectives and strategies Education has developed for  Title III and Title V programs, we talked with Education officials and  reviewed program and planning documents. To determine how Education  monitors and provides assistance to the Title III and Title V grantees, we  talked with Education officials and reviewed program policies and  guidance.
section_title: Appendix II: Characteristics of Title III and Title V Grantees by Program
paragraphs: Federal grants include Pell Grants and other federal grants awarded to individual students.
This is an admission policy whereby the institution will accept any student who applies.
section_title: Appendix III: Overview of How Grants Have Been Used by Institutions We Visited
subsections: section_title: Clark Atlanta University, a private comprehensive historically black university in Atlanta, Georgia, was formed in 1988 by the consolidation of Clark College, a 4- year liberal arts college founded in 1866, and Atlanta University, a graduate institution, founded in 1869. In fall 2002, 3,864 undergraduates were enrolled, of which 94 percent were black and 71 percent were women.
paragraphs: Clark Atlanta University reported focusing its Title III, part B grant on  efforts that will improve student services and student outcomes and  academic quality. The university has used its funds to provide support to  strengthen student communication skills, including reading, writing, and  speech. Funds have also been used to provide tutoring and supplemental  instruction in selected academic programs. Another of Clark Atlanta’s  efforts is designed to enhance retention by integrating instructional support  programs and student services to ensure academic success for students.
Clark Atlanta originally proposed an effort to improve its ability to provide  distance-learning courses. However, this effort was reexamined once a  new president was appointed and more was known about the costs of  implementing distance learning. According to the project director, these  concerns led the institution to shift the focus from distance learning to an  emphasis on instructional technology infusion and Web-enhanced course  instruction. Flexibilities in the program allowed the institution to make this  change.
While its current grant began in 2002, Clark Atlanta, like other HBCUs, has  benefited from the continued funding Title III, part B provides. Specifically,  officials at Clark Atlanta have credited Title III with enabling it to build and  sustain its technological infrastructure and facilitating the infusion of  technology into instruction.
Fort Valley State University, a public historically black  university, was founded as Fort Valley State College in  1939 and became Fort Valley State University in 1996.  Located in Fort Valley, Georgia, it is the state’s only 1890  land grant institution. In fall 2002, 2,193 undergraduate  students were enrolled, of which 94 percent were black  and 56 percent were women.
Fort Valley State University reported using its Title III, part B grant to fund  a number of efforts to improve academic quality, student services and  outcomes, and institutional management. For example, to improve  academic quality, the university reported using grant funds to establish a  major in juvenile justice and a population studies center—the first of its  kind in the state university system—to prepare students for careers as  demographers. Fort Valley has also focused its grant efforts on  strengthening its fine arts program. As part of its faculty and staff  development program, the university reported providing two faculty  members with funding that led to an advanced degree.
To improve student services and outcomes, the university reported using  grant funds to establish an academic success center, which is responsible  for providing advisement services and referrals for additional services. The  university also reported using the grant to enhance support services for  students enrolled at its outreach sites. Specifically, the university has  increased tutoring and counseling services for students at these locations  for whom traveling to the main campus might not be practical. The  university reported an increase in the pass rate for the Georgia Regents  exam for students who participated in academic enrichment services.
Fort Valley also reported using its current Title III grant to upgrade its  network in support of its objective to redesign the system architecture and  ensure that existing hardware is continuously upgraded. In particular, Title  III funds were used to replace network hardware and outdated servers,  increasing the overall speed of the network. Officials at the university told  us that Title III funds from earlier grant periods provided the base funding  to establish the college’s technological infrastructure.
Spelman College, a private historically black liberal arts  college for women in Atlanta, Georgia, was founded in  1881. In fall 2002, 2,121 undergraduate women were  enrolled at the college, 97 percent of whom were black.
Spelman reported using its grant to focus on improving academic quality  and institutional management. Specifically, the grant has been used to  strengthen writing, promote interdisciplinary teaching and research,  integrate educational technology into the learning environment, and  support an advanced program in computer science. To improve  institutional management, Spelman has used its grant to ensure that the  college has access to appropriate levels of technical computing and  networking support services essential to effective use of technology  resources for education and research.
According to the project director, Title III funds have enabled Spelman to  purchase sophisticated computer equipment for its computer science and  math students that it would not have been able to obtain otherwise.  Students who major in computer and information science acquire cutting- edge knowledge of the discipline. We toured a facility at the college that  houses test networks for teaching purposes. In teams, students attempt to  break into the test networks, enhancing their knowledge of network  security without harming the college’s actual network.  Spelman also used  Title III funds to wire each room in the dormitories on campus to enable  students to connect to the campus network using a laptop or personal  computer.  The director of the project thinks technology will always be a  key area covered by Title III funds at the college because it frees up funds  to meet other needs.
Morehouse College is a private historically black liberal  arts college for men located in Atlanta, Georgia.  Established in 1867 in the basement of a Baptist church  to prepare black men for the ministry and teaching, the  school received full accreditation in 1957. In fall 2002,  2,738 undergraduate men were enrolled, 94 percent of  whom were black.
Morehouse College reported using its grant to fund several efforts  designed to support students, improve technological capacity, promote  faculty development, and develop a holistic approach to strategic planning  and assessment to determine the effectiveness of academic programs and  services. To support students, Morehouse has used its grant to support a  tutoring initiative designed to retain freshmen, as well as a learning  resource center that provides study space, a 24-hour computer lab, and  supplemental educational materials for all students. Morehouse has also  used its grant to cover the cost of professional counselors in its wellness  center, which provides counseling, disability services, and workshops on a  variety of topics such as test taking and study skills.
Morehouse has relied on Title III funding to help build its technological  infrastructure. For example, Title III funds have been used to pay for the  installation of high-speed Internet lines, wiring of all buildings on campus  including dormitories, and connecting all the buildings to a common  network. An official at Morehouse told us the college’s emphasis on  technology stems from the need to compete with other institutions for the  best students and to ensure that students graduate with technology skills  that are necessary in the workplace.
Morehouse reported that it has also used Title III funds to develop a  strategic planning and assessment model that it will use to determine the  overall effectiveness of its programs and services, including documenting  student learning outcomes. Related to its efforts to promote faculty  development, it has provided fellowships to help two faculty members  complete advanced degrees.
Title V, part A Developing Hispanic Serving Institutions we visited in Texas  University of Texas at San Antonio (UTSA)
UTSA, a public Hispanic Serving Institution in San  Antonio, Texas, was founded in 1969 to serve the needs  of the multicultural population in the San Antonio area  and South Texas. In fall 2002, 48 percent of the 18,729  undergraduate students enrolled were Hispanic, and 55  percent were women.
The University of Texas at San Antonio reported focusing its grant on  improving student services to increase retention and graduation rates.  Specifically, the university used its Title V grant to establish learning  communities where cohorts of 25 students are enrolled in three linked  courses. At the heart of the learning communities is the Freshman  Seminar, a course that introduces students to resources that will help them  succeed in college. Each course in a learning community is linked by a  theme that connects the classes within the learning community to one  another, offering students the opportunity to study a given topic from  various points of view.
UTSA reported it has used the grant to provide training for faculty to  enhance their teaching techniques and understand the developmental  needs of students in their classes. Officials at the university told us that the  learning communities have changed how professors teach and that they  understand their role in retaining and graduating students. One faculty  member we spoke to said even though he has always received fairly high  ratings from his students, he considered himself an average teacher  before participating in the learning communities. He thinks he’s more  effective in the classroom now and credits the learning communities with  the increased confidence he has about teaching and better relationships  with faculty. Students we talked to agreed that being enrolled in three  courses with the same group of students helped them connect more easily  with other students and resources on campus, as well as teaching them  about how to succeed in college.
LCC, a public Hispanic Serving Institution is located in  Laredo, Texas, an isolated border town that is 150 miles  from any major city in the United States. In fall 2002, 94  percent of the 7,766 undergraduate students enrolled  were Hispanic and 59 percent were women.
Laredo Community College reported using its Title V award to meet the  demand for health care workers in the area. Since the grant was awarded  to the college in 1999, two new hospitals have been built and work on a  third facility is under way.  The college has used its Title V grant primarily  to increase student access and success in math and the sciences; for  example, by providing funds for a new science facility to house 20 percent  more students and by paying to renovate and update laboratory facilities  and equipment. Title V funds covered 40 percent of the costs of  construction for the new facility, and the college raised the remaining  funds. The new building replaces a facility more than 30 years old that did  not meet current safety standards.
LCC also reported using its Title V grant to provide a comprehensive  faculty development program designed to integrate technology and  retention strategies into the curriculum. Officials at the college said the  institution chose to focus its grant activities on faculty because they believe  retention is driven by instruction. Changes in instruction and the curriculum  due to this training are credited with the nursing program’s recently  achieving a 100 percent student pass rate on certifying examinations.
LCC designated $250,000 from its Title V grant to develop an endowment  fund for the college. By matching each dollar provided by Title V, the  college has used one-half of the interest generated annually from the  endowment to provide scholarships for math and science students.  College officials told us that the matching component has generated a  substantial amount of interest in the community, with endowments being  developed to benefit students in other disciplines.
University of the Incarnate Word, a private liberal arts,  Catholic institution in San Antonio, Texas. In fall 2002, 55  percent of the 3,337 undergraduate students were  Hispanic and 67 percent were women.
The focus of the University of Incarnate Word grant is on strengthening  student learning through faculty development. The university aimed to  change the classroom culture to better serve its diverse student body,  particularly Hispanic students, by focusing on pedagogy, globalization,  technology, mentoring, and recruitment and retention of minority faculty.  According to one official at the university, students at the institution mirror  the demographics of San Antonio, but the faculty did not and faculty were  interested in how they could be more effective with these students. The  university reported that it used its grant to develop and implement a  linguistic and cultural diversity workshop to train faculty in how to cope with  differences in learning among students from different cultures, and has  provided Spanish language instruction to faculty. The university also used  its grant to research models for recruiting and retaining minority faculty and  is incorporating recommendations into its strategic plan.
To promote globalization and research, Incarnate Word reported that it  used the grant to provide faculty with grants to conduct research abroad.  For example, using her newly acquired technology skills and seed money  from Title V, one professor led a student expedition to map the ruins of an  ancient Mayan city.
Another key focus of the grant has been providing technology training to  increase the infusion of technology into the classroom. According to  university officials, most faculty at the college have participated in summer  institutes and workshops, and many are creating Web pages for their  courses using a course management software. The Web pages can be  used to post syllabi and assignments, as well as to communicate with  students in the class  The university plans to sustain its faculty development activities at the  conclusion of the grant using a portion of the interest from the endowment  it has raised using grant funds.
Title III, part A Tribally Controlled Colleges and Universities we visited in North Dakota  United Tribes Technical College (UTTC)
UTTC, a private tribal college located in Bismarck, North  Dakota, was established in 1969 as an employment  training center. In fall 2002, 89 percent of the 463  undergraduate students enrolled were American Indian or  Alaska Native, and 59 percent were female.
United Tribes Technical College reported that it used its Title III grant to  develop comprehensive student services. In particular, the college  leveraged its Title III funds with funds from the Department of Commerce  to create a one-stop center that houses most services students need, such  as registration, advising, tutoring, counseling, computer labs, a cafeteria,  and student bookstore. The college also reported that it used grant funds  to develop a retention model specifically designed to meet the needs of  American Indian students. Officials told us that funds were also used to  address retention because tribes don’t have the resources to adequately  prepare students for college.
College officials also told us that grant funds were used to enhance  student records management, improving communication between offices  that interact with students, such as admissions and registration. The  college has installed a system designed to consolidate its many separate  databases that were housed in each student service office on campus.
Officials at the college told us that the Title III grants it has received over  the years have been an important source of funding, allowing the college  to pursue institutional goals while freeing up other institutional funds to  provide tuition assistance to needy students. Officials told us that the  college does not participate in the federal student loan programs because  it does not want to risk losing eligibility to participate in the federal Pell  Grant program if loan default rates are too high.
In 2002, United Tribes Technical College received a 1-year construction  grant, which it has used to enhance its technological infrastructure,  including enhancing connectivity to the North Dakota University System’s  interactive video network.
SBC, is a public tribal college located on the Standing  Rock Sioux reservation, which spans parts of both North  and South Dakota. The main campus is in Fort Yates,  North Dakota, with satellite campuses in McLaughlin and  Mobridge, South Dakota. In fall 2002, 89 percent of the  214 undergraduates enrolled at the college were  American Indian or Alaska Native, and 74 percent were  women.
Sitting Bull College reported that the focus of its grant has been to improve  student services and outcomes, along with fiscal stability. Officials told us  that there is an acute need for services that will help bring students up to  the college level because most students enter the college with below  average skills in math, reading, and English. To address the academic  deficiencies many students have, Sitting Bull college proposed learning  assistance programs that would help students improve basic skills and  additional student services. Officials told us that students who score below  the 12th grade level in core courses are now required to take appropriate  foundations courses. In the past many students opted out of these courses  because they don’t count toward graduation requirements, but they were  failing as a result. Title III funds were used to renovate a building and  purchase software and computers for this effort. The college has also  implemented a survey designed to identify students at risk of failing or  dropping out.
Sitting Bull College also reported that it used grant funds to develop its  fund-raising capacity and to establish an endowment. Because the college  does not receive any state funding, it relies heavily on federal funding,  primarily from the Bureau of Indian Affairs. College officials acknowledged  that increasing fiscal stability is central to becoming more self-sufficient.
In 2002, Sitting Bull College received a 1-year construction grant through  Title III, which it is using for construction of a new campus.
Grants to Historically Black Colleges and Universities are based on a formula that is calculated each  year based in part on the number of Pell Grant recipients, the number of graduates, and the number  of students that enroll in graduate school within 5 years after earning an undergraduate degree.  Funding information for subsequent years of the grant cycle was not available from Education  In addition to receiving a 5-year development grant through Title III, part A, these Tribal colleges  were awarded a 1-year construction grant.
section_title: Appendix IV: Comments from the Department of Education
section_title: Appendix V: GAO Contacts and Staff Acknowledgments
subsections: section_title: Contacts
section_title: Acknowledgments
paragraphs: In addition to those named above, Karen Burke, Carl Barden, Carla  Craddock, Kim Gianopoulos, Catherine Hurley, Sheila Nicholson, Jim  Rebbe, and Vanessa Taylor made important contributions to this report.