No Child Left Behind Act: Education Should Clarify Guidance and Address Potential Compliance Issues for Schools in Corrective Action and Restructuring Status
Published: 2007-09-05T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The No Child Left Behind Act of 2001 (NCLBA) focused national attention on improving schools so that all students reach academic proficiency by 2014. In the 2006- 2007 school year, about 4,500 of the 54,000 Title I schools failed to make adequate yearly progress (AYP) for 4 or more years. Schools that miss AYP for 4 years are identified for corrective action, and after 6 years, they must be restructured. GAO examined (1) the characteristics of Title I schools in corrective action and restructuring; (2) the actions that schools in corrective action and restructuring implemented; (3) the assistance those schools received from districts and states; and (4) how Education supports states in their efforts to assist these schools. GAO administered two Web-based surveys to a nationwide sample of schools in corrective action and restructuring status and conducted site visits to five states.
section_title: What GAO Found
paragraphs: Nationwide, the 2,790 Title I schools that were in corrective action or restructuring status in the 2005-2006 school year were more frequently located in urban areas and in a few states. These schools served higher percentages of minority, poor, and middle-school students than other Title I schools, and many report that factors such as neighborhood violence and student mobility pose additional challenges to improving student academic performance. As state proficiency targets continue to increase to 100 percent in 2014, the number of schools in corrective action and restructuring may increase. A majority of schools in corrective action or restructuring status implemented required activities. However, in some cases, schools may not be meeting NCLBA requirements. GAO estimates that 6 percent of schools did not take any of the required corrective actions and that about a third continued corrective actions implemented during earlier years of school improvement but did not take a new action after entering corrective action status. While this course of action may be an appropriate path for some schools to take, the Department of Education has not provided guidance to districts delineating when continuing a corrective action is appropriate and when it is not. In addition, about 40 percent of schools did not take any of the five restructuring options required by NCLBA. While states are required to report annually to the Department of Education the measures taken by schools in improvement status, Education does not require states to report on the specific measures taken for each school. GAO estimates that 42 percent of the schools in corrective action or restructuring did not receive all required types of assistance through their school districts, although most received discretionary assistance from their state educational agencies. Districts are required to ensure that several types of assistance are provided to all schools in improvement status, including those in corrective action and restructuring status. This assistance includes help in analyzing students' assessment data and revising school budgets so that resources are allocated to improvement efforts. NCLBA generally does not require states to provide specific kinds of assistance to schools in corrective action or restructuring; however, they are required to develop a statewide system of support, including school support teams to provide technical assistance to schools and districts. Most schools received some type of assistance from the state educational agency. Education provides technical assistance and research results to states primarily through its Comprehensive Centers Program. Education also has provided more material in its Web-based clearinghouse to address a greater number of topics and is developing an initiative to outline practical steps for schools in improvement, including those in restructuring.

section_title: Letter
paragraphs: Over the past 40 years, the Elementary and Secondary Education Act of  Over the past 40 years, the Elementary and Secondary Education Act of  1965 (ESEA) has authorized billions of dollars in federal grants to states  1965 (ESEA) has authorized billions of dollars in federal grants to states  and school districts to improve educational opportunities for economically  and school districts to improve educational opportunities for economically  disadvantaged students. Despite this investment, the academic  disadvantaged students. Despite this investment, the academic  performance of disadvantaged students is still substantially lower than  performance of disadvantaged students is still substantially lower than  that of more advantaged students. Congress, with the enactment of the No  that of more advantaged students. Congress, with the enactment of the No  Child Left Behind Act of 2001 (NCLBA)—the most recent reauthorization  Child Left Behind Act of 2001 (NCLBA)  However, many Title I  progress toward meeting state proficiency targets.
Pub. L. No. 107-110.
In this report, we refer to Title I, Part A of NCLBA as “Title I.” Other Parts of Title I (Parts  B through I) generally are targeted at specific populations or purposes and are commonly  referred to by their program names, such as Education of Migratory Children. years, and about 4,500 of these schools had not made AYP for 4 or more  years. Under NCLBA, when a Title I school does not make AYP for 4 years,  the school enters corrective action, and the district must take a statutorily  prescribed action to improve the school, such as replacing selected  teaching staff. If the school fails to make AYP for 6 years, the district is  required to restructure the school by changing how the school is  governed. Such changes may include closing the school and re-opening it  as a charter school or turning the operation of the school over to the state  educational agency. As annual goals leading up to the 2014 deadline  continue to increase, more schools are expected to enter corrective action  and restructuring and will be required to take major action to improve.
However, little is known about what specific corrective actions or  restructuring options schools are currently implementing nationwide, the  extent to which these actions are associated with making AYP, and the  support that schools in corrective action and restructuring have received  from school districts and states as they attempt to improve student  performance. In order to shed light on these issues and help the Congress  prepare for reauthorization of the NCLBA, you asked GAO to answer the  following questions: (1) What are the characteristics of Title I schools in  corrective action and restructuring? (2) To what extent have schools in  corrective action and restructuring implemented corrective actions or  restructuring options? (3) What assistance have schools in corrective  action and restructuring received from districts and states? and (4) How  has the Department of Education (Education) supported states in their  efforts to assist schools in corrective action and restructuring status?
To provide information on these topics, we collected data through  multiple methods. We obtained data on which schools were in corrective  action and restructuring for the 2005-2006 school year. States reported  these data to Education through the Consolidated State Performance  Report process, which collects annual information from states on ESEA  programs. We matched data on these schools with additional data in  Education’s Common Core of Data (CCD), conducted descriptive analyses  of selected characteristics, and compared them to all other Title I schools.  We also administered two Web-based surveys sent to 470 principals in a  nationwide sample of schools in corrective action and restructuring during  the 2005-2006 school year. We administered the surveys between January  and March 2007 and received a combined response rate of about   70 percent. Percentage estimates from the surveys have margins of error  of plus or minus 8 percentage points using a 95 percent confidence  interval, unless otherwise noted. While we did not fully validate specific  information that school officials reported in our survey, we took several  steps, including corroborating evidence of some schools’ improvement  status, to ensure that the information provided by school officials was  sufficiently reliable for the purposes of this report. We conducted site  visits to 5 states (California, Illinois, Maryland, New York, and  Pennsylvania) and 10 school districts with schools in corrective action,  restructuring, or both, as well as 20 schools in those districts. The states,  districts, and schools selected for site visits not only provided variation  across such characteristics as geographic location and district size, but  also generally resembled all schools in corrective action and restructuring  in terms of students’ racial, ethnic, and economic characteristics.  Together, schools in these 5 states accounted for over 59 percent of  schools in corrective action and restructuring nationally in the 2005-2006  school year. We also interviewed state officials from several states (Idaho,  South Dakota, Texas, and Virginia) that had few schools in correction  action or restructuring to obtain information on how their state  educational agencies are working with districts on school improvement  issues. We reviewed relevant federal laws, regulations, and agency  guidance and interviewed Education officials to obtain information about  how they monitor and provide assistance to states and districts. We also  interviewed officials in some of Education’s comprehensive and regional  assistance centers. We analyzed relevant Education documents and  studies and reports issued by policy and research organizations on schools  in corrective action and restructuring and interviewed staff in many of  these organizations. See appendix I for detailed information on both  surveys as well as our other data collection methods. We conducted our  work from August 2006 through August 2007 in accordance with generally  accepted government auditing standards.
subsections: section_title: Background
paragraphs: Under NCLBA, states are required to establish performance goals and hold  their Title I schools accountable for students’ performance by determining  whether or not schools have made AYP. Schools that have not met their  state’s performance goals for 2 or more consecutive years are identified  for improvement and must implement certain activities that are meant to  improve student academic achievement. Districts and states play a role in  this process by providing technical assistance to schools. In addition,  states are responsible for monitoring district and school compliance with  NCLBA. Education provides states and districts with guidance on school  improvement and monitors states for compliance with NCLBA  requirements.
subsections: section_title: States and Districts Are Held Accountable for the Performance of Their Schools and Must Take Action to Improve Student Achievement When Schools Do Not Make AYP for 2 or More Years
paragraphs: Prior to NCLBA, the Congress attempted to hold states accountable for the  annual performance of their schools by requiring them to collect  assessment data, develop criteria to determine whether schools and  districts were performing satisfactorily, and conduct student assessments.  The 1994 reauthorization of ESEA—Improving America’s Schools Act  (IASA)—required that schools be designated for improvement for failure  to make AYP for 2 consecutive years and that districts take corrective  action as a final intervention for schools that repeatedly missed AYP.  However, under IASA states assessed AYP in different ways and used  different measures to evaluate school performance. NCLBA added several  new provisions to address these differences and to strengthen  accountability. These provisions include:    The requirement that states develop plans that include academic  standards and establish performance goals for meeting AYP that would  lead to 100 percent of their students being proficient in reading,  mathematics, and science by 2014. To measure their progress, states  were required to establish academic proficiency goals for making AYP  and to administer an annual assessment to students in most grade  levels. In addition, each school’s assessment data must be  disaggregated in order to compare the achievement levels of students  within certain designated groups with the state’s proficiency targets.  These student groups include the economically disadvantaged, major  racial and ethnic groups, students with disabilities, and those with  limited English proficiency, and each of these groups generally must  make AYP in order for the school to make AYP.
A timeline for implementing specific interventions based on the  number of years the school missed AYP. For a school that fails to meet  AYP for 2 consecutive years, districts must offer students in these  schools the opportunity to transfer to a higher-performing public  school in the district, and after the third year, they must also offer  supplemental education services (SES), such as tutoring. In addition,  the school must also develop an improvement plan in consultation with  the district, school staff, parents, and outside experts. These plans,  which are subject to district approval, must incorporate strategies to  address the specific academic issues that caused the school to be  identified for improvement. Under NCLBA, if a school fails to make  AYP for 4 consecutive years, it is required to implement one of the  corrective actions identified in the legislation. In addition, a new  intervention to change the governance of schools—school  restructuring—was introduced for schools that miss AYP for 5 or more  years. (See table 1.) Districts are responsible for selecting and  implementing the corrective actions and restructuring options for these  schools. Schools exit improvement status if they make AYP for   2 consecutive years.
Schools in corrective action must implement at least one of six activities  such as replacing selected school staff or implementing a new curriculum.  Schools that do not make AYP after 5 years must plan for restructuring,  which means that the district must decide how to change the school’s  governance. Restructuring, the most severe of the NCLBA interventions,  requires that the school implement a major change to how the school is  operated, such as reorganizing into a public charter school or contracting  with an outside organization such as a private management company to  operate the school. If the school does not make AYP during the planning  phase, the school enters restructuring. The corrective action and  restructuring activities allowed under NCLBA are shown below in table 2.  NCLBA does not address actions that districts must take after  implementing restructuring and the school continues to fail to make AYP.  Education officials said that they have encouraged states and districts to  continue to try different interventions with these schools.
section_title: Both Districts and States Provide Technical Assistance to Schools in Improvement
paragraphs: The school district bears the primary responsibility for ensuring that its  schools in improvement, including those in corrective action and  restructuring, receive technical assistance, although the state also plays a  role in providing assistance. The purpose of the district’s assistance is to  strengthen and improve the school’s instructional program by helping the  school address the issues that caused it to make inadequate progress in  student achievement. Specifically, the district must ensure that each  school identified for improvement receives assistance based on  scientifically based research in three areas: analysis of student assessment  data, identifying and implementing instructional strategies, and analysis of  the school budget, as shown in table 3 below.
The state educational agencies are also responsible for making several  forms of technical assistance available to schools in improvement and  overseeing the improvement activities of districts. States generally are  required to reserve and allocate 4 percent of the state’s total Title I  allocation for school improvement activities, with 95 percent of these  funds going directly to the districts. States are to prioritize their assistance  to districts that, among other things, serve the lowest achieving schools,  such as those in corrective action and restructuring. They also are  required to develop and sustain a statewide system of support that  provides technical assistance to schools, with a priority given to those in  improvement status. In addition, in developing the statewide system of  support, the state agency must:    Establish school support teams to work in schools throughout the state  that are identified for improvement. The purpose of these teams is to  assist schools to strengthen their instructional programs and must  include individuals who are knowledgeable about scientifically based  research and practice and its potential for improving teaching and  learning.
Designate and use distinguished teachers and principals who are  chosen from Title I schools and have been especially successful in  improving academic achievement.
Devise additional approaches to improve student performance, for  example, by drawing on the expertise of other entities, such as  institutions of higher education, educational service agencies, or  private providers of scientifically based technical assistance.
section_title: Education Provides Assistance to States and Districts and Monitors for Compliance
paragraphs: Education provides assistance to states in implementing NCLBA and  monitors states for compliance. Specifically, Education provides  assistance to states and districts in several ways such as issuing  regulations, providing guidance and policy letters, and through its  comprehensive centers. For example, the department published  nonregulatory guidance that was specific to schools in improvement and  provided information on the actions that districts and states must take to  reform their schools in compliance with NCLBA. To help build the  capacity of states to meet NCLBA goals, Education awarded almost   $57 million in fiscal year 2006 to the 21 comprehensive centers. These  include 16 regional centers established to provide technical assistance to  states within defined geographic areas. In addition, Education established  five content centers that work closely with the regional centers to provide  technical assistance to states on school improvement. One content center  focuses on school improvement issues.
Education monitors each state agency to determine, among other issues,  whether the state is ensuring that districts are implementing NCLBA  requirements for school improvement. Education, the state agency, and  districts all play a role in ensuring that schools are meeting NCLBA  requirements. Their monitoring responsibilities are presented in table 4.
Education monitors states in two ways: (1) routinely gathers and analyzes  data collected from Web-based searches and documents, such as  Consolidated State Performance Reports, and (2) on-site visits at least  once every 3 years to monitor state compliance with Title I. During these  site visits, states are monitored to ensure that they are complying with  Title I program requirements, which includes providing the necessary  guidance and support to schools that are in improvement, including those  in corrective action and restructuring. In addition, according to  Education’s monitoring guidelines, Education officials visit selected  districts in each state and ask for evidence on how schools are  implementing required actions and meeting timeframes. Once the review is  complete, Education issues a report to the state containing findings,  recommendations, and required actions needed to address identified  problems. A state is generally given 30 business days to respond to the  findings and required actions and also to provide a timeline for addressing  each issue. A state with significant findings may have conditions attached  to its Title I Grant and if it fails to adequately address the identified  deficiencies, the Secretary generally may withhold the state’s Title I funds  that are used for state administration until all requirements have been  satisfied.
section_title: Schools in Corrective Action and Restructuring Were More Often Located in Urban School Districts and Served Higher Percentages of Minority, Poor, and Middle-School Students Than Other Title I Schools
paragraphs: Schools in corrective action and restructuring status in the 2005-2006  school year were more frequently located in urban school districts and a  few states and served higher percentages of minority, poor, and middle- school students than other Title I schools. In the 2005-2006 school year,  2,790 Title I schools were in corrective action, planning for restructuring,  or implementing restructuring (see fig. 1). These schools comprised about  5 percent of all Title I schools and served over 2 million students. Data for  the 2006-2007 school year show that the numbers of schools in corrective  action and restructuring are growing, a trend that is likely to continue.
subsections: section_title: Schools in Corrective Action and Restructuring Were Concentrated in Urban Areas and a Few States
paragraphs: Schools in corrective action and restructuring were predominantly located  in urban areas, especially compared to all other Title I schools, as shown  in table 5.
Examples of urban areas with relatively higher numbers of schools in  corrective action and restructuring include Chicago, Detroit, Los Angeles,  New York, and Philadelphia. Nationwide, school districts in these 5 cities  alone contained over 25 percent of all schools in corrective action and  restructuring, as shown in Table 6. By comparison, these 5 districts  contained less than 4 percent of all other Title I schools.
Consequently, schools in corrective action and restructuring were  concentrated in a few states. Five states—Illinois, New York, California,  Pennsylvania and Michigan—collectively had over 60 percent of these  schools, but less than 30 percent of all Title I schools nationwide. In  contrast, a majority of states had 20 or fewer schools in corrective action  and restructuring, as shown in figure 2.
In general, states with large numbers of schools identified for  improvement when NCLBA was passed had more schools in corrective  action and restructuring in the 2005-2006 school year than those with few  schools in improvement in 2001. Prior to NCLBA, states had identified  schools for improvement, and when NCLBA was passed in the 2001-2002  school year, it generally required states to maintain the prior improvement  status of schools. Consequently, many schools that were in earlier stages  of improvement in school year 2001-2002 entered corrective action and  restructuring in subsequent years.
section_title: Schools in Corrective Action and Restructuring Served a Higher Percentage of Minority, Economically Disadvantaged, and Middle School Students, Compared to All Other Title I Schools
paragraphs: Schools in corrective action and restructuring also had a much higher  percentage of racial or ethnic minority students compared to all other Title  I schools (96 percent compared to 37 percent) and also enrolled a higher  percentage of economically disadvantaged students (83 percent compared  to 54 percent). These differences varied substantially when the location  of the school is accounted for, as seen in table 7.
Schools in corrective action and restructuring varied in terms of the grade  level of students that they served. Compared with all other Title I schools,  middle schools were considerably over-represented among schools in  corrective action and restructuring while primary schools were  underrepresented, as seen in table 8.
Several factors might explain why middle schools are over-represented.  Evidence from the National Assessment of Educational Progress— especially for many of the urban school districts with numerous schools in  corrective action or restructuring—shows that the percentage of students  who score at a proficient level or above in math is generally lower in  middle schools than in elementary schools. Other factors may also  include being less qualified than their peers in elementary or middle  schools, teachers in middle schools, and social and emotional challenges  associated with students as they make the transition into middle schools.  Yet another reason may be that because of NCLBA provisions about the  minimum number of students in a school that would comprise a  designated student subgroup, middle schools typically have to make AYP  for more student subgroups than elementary schools.
section_title: The Number of Schools in Corrective Action and Restructuring Has Increased Considerably from Last Year and May Continue to Do So
paragraphs: Data for the 2006-2007 school year showed that the number of schools in  corrective action and restructuring has increased. In 2006-2007, there were  4,509 schools in corrective action and restructuring compared to 2,790 the  year before, an increase of over 60 percent, and more than twice as many  schools compared to just 2 years earlier. (See fig. 3.)
Additionally, 41 states had more schools in corrective action and  restructuring whereas only 8 states had fewer. (See fig. 4 and see app. II  for a comprehensive list of the number of schools in corrective action and  restructuring in each state.) Most notably, in 2006-2007, the state of Florida  had 574 schools in those categories compared to only 32 such schools in  2005-2006. According to a Florida state official, this increase is attributable  to the fact that many schools have been struggling to meet the increasing  proficiency targets. Other states with large increases include California  (increase of 376 schools) and Massachusetts (increase of 118 schools). A  few states, such as Michigan, had fewer schools in corrective action and  restructuring in 2006-2007 compared to the prior year. In Michigan’s case,  it is not clear whether the decrease was related to state or district reform  efforts, changes in criteria making it easier for schools to make AYP, or  some combination of these factors.
The general trend toward higher numbers of schools in corrective action  and restructuring may continue. As of the 2006-2007 school year, more  schools were identified for improvement than at any time since such data  were tracked under IASA. As proficiency targets continue to increase up  to 100 percent by 2014, many schools identified for improvement may not  make AYP. Consequently, if these schools cannot meet the increasing  proficiency targets, they will enter corrective action and ultimately  restructuring.
section_title: Most Schools Used a Corrective Action or Restructuring Option, but Some May Not be Meeting NCLBA Requirements
paragraphs: Our survey results indicated that a majority of schools in corrective action  and restructuring implemented required activities; however, in some cases  schools may not be in compliance with NCLBA requirements. Although  many schools in corrective action implemented multiple corrective  actions, some did not take any corrective action. A majority of  restructuring schools implemented a required restructuring option, but  based on our survey results, about 40 percent of schools did not take any  of the 5 restructuring options required by NCLBA, one of which is a broad  category referred to as “other” major restructuring. Although there was no  relationship between any of the specific activities and whether a school  made AYP, a higher percentage of schools that fully implemented  improvement activities made AYP compared with those that had not fully  implemented activities.
subsections: section_title: Among Schools in Corrective Action, Almost All Took at Least One Corrective Action, but Some May Not Have Taken an Action As Required by NCLBA
paragraphs: Among schools in corrective action status, we estimate that 94 percent  implemented at least one corrective action from those specifically  identified by NCLBA, and about three-quarters had used more than one  corrective action. Hiring an outside expert and changing the internal  structure of the school were the most frequent actions, with each  implemented by about 60 percent of schools. Outside experts are used to  advise the school on its progress toward making adequate yearly progress.  Among schools that changed their internal structures, about 85 percent  increased small group work and about 75 percent reorganized the school  schedule to increase opportunities for professional development. Many  schools also reduced class size, created small learning communities, and  implemented team teaching as part of the changes to the organizational  structure. In addition to hiring outside experts and changing internal  structure, about 40 percent of schools changed the curriculum. A smaller  percentage of schools implemented certain forms of corrective actions  such as extending the school year or day or decreasing management  authority at the school level. Some officials explained that extending the  school year or day would be costly to the district because teacher salaries  may have to increase to compensate for the additional instructional time.  For the majority of schools, district officials played a significant role in  determining the action taken. Figure 5 shows the allowed corrective  actions and the percentage of schools implementing each action.
Based on our survey, we estimate that 6 percent of schools in corrective  action status did not take corrective actions. For example, in one school  we visited, the principal told us that the school had not implemented any  changes during its year in corrective action. He told us that the district  provided no input on the required actions and that the state educational  agency approved the school improvement plan without comment.
About a third of schools that went into corrective action in 2005-2006 did  not take a new corrective action in that year. These schools took  corrective action in earlier years of improvement and did not implement  any further corrective actions after entering corrective action status. For  example, some schools indicated that the school used an outside expert or  implemented a new curriculum in previous school years and had not  implemented any additional corrective actions the year in which the  school entered corrective action status. Education officials told us that if a  school implemented a corrective action in earlier stages of improvement  (year 1 or 2 of improvement), an additional corrective action might not be  required. They explained that whether a district must take additional  actions depends in part on whether the school is showing improvement in  student achievement. If the school showed evidence that the intervention  is producing results that are likely to enable the school to exit  improvement status, an additional corrective action might not be  necessary. On the other hand, Education officials noted that if the data  indicates that the previous corrective actions have not addressed the  school’s achievement problems they would expect the district to take  additional corrective action. While it may be appropriate in some cases for  schools to continue implementing the same actions, Education officials  acknowledged that they have not provided written guidance on when  continuing prior actions without implementing a new one would be  acceptable.
Department officials told us that while they had conducted Title I  monitoring in every state, they had not found compliance issues  specifically related to corrective action from their monitoring visits. States  are required to conduct annual reviews of district progress in part to  ensure that districts are carrying out their responsibilities, one of which is  taking at least one corrective action when necessary. However, states  generally do not report to Education district noncompliance, such as  failure to take corrective actions as required. Under NCLBA, states are  required to annually submit to Education and make widely available the  measures taken to address the achievement problems of schools in  improvement status, including schools in corrective action. However,  Education does not require states to report on the measures taken for each  school. Instead, Education requires states to provide a brief summary of  the measures taken across the state. Consequently, Education lacks  information on which action was taken by each school, whether schools  are taking actions at all, and whether or not states have taken any actions  against schools or districts for failure to comply with NCLBA.
section_title: Among Schools in Restructuring, Almost Two-Thirds Implemented a Restructuring Option; However, Many Schools May Not Be in Compliance with NCLBA Requirements
paragraphs: We estimate that a majority of schools in restructuring had implemented at  least one of the five restructuring options allowed by NCLBA. According  to NCLBA, each of these options is to result in a major change to the  school’s governance. As figure 6 shows, about 40 percent of the schools  implemented the “other” major restructuring of the school’s governance,  which can include such actions as expanding or narrowing the grades  served or creating smaller learning communities within the school. We  estimate that 27 percent of schools replaced all or most of the staff related  to the school’s performance issues.
Of the 40 percent of schools that selected “other” major restructuring of  the school’s governance, 44 percent created smaller learning  communities—an approach taken by some of the schools we visited. For  example, one middle school we visited created “academies” within the  school. Each academy had its own theme, and students stay within the  academy as they are promoted from grade to grade. Another 37 percent of  schools that chose the “other” option narrowed or expanded the range of  grades served within the school, for example, changing a kindergarten- through-grade-five elementary school to a kindergarten- through-grade- eight school. In one district we visited, officials reported that a  kindergarten-through-grade-eight model creates a more positive learning  environment than middle schools do as it creates a sense of family and  relationships in schools. Figure 7 shows the various types of restructuring  activities taken by schools implementing “other” major restructuring.
In addition to the “other” major restructuring option, in an estimated   27 percent of restructuring schools, all or most of the staff (primarily  teachers and principals) who were relevant to the failure to make AYP  were replaced. The schools we visited that replaced staff varied in terms  of whether teachers, principals, or both were replaced. Our survey  indicated that for many of these schools, it was difficult or very difficult to  recruit new teachers as replacements.
Very few schools in restructuring had contracted with an entity, such as a  private management organization, become a charter school, or been taken  over by the state. Some states may not have authorized all restructuring  options under state law or policy, which may explain why fewer schools  have taken these options. For example, according to a recent report, while  some states have policies that permit districts to turn schools over to  private management or to reopen schools as charter schools, others do  not. In three of the five states we visited, state officials reported that their  state educational agencies currently do not take over schools. In one of  these states, turning over school management to the state agency is  permissible under state policy, but officials told us that the state does not  have the capacity or expertise to do so. The amount of time it takes to  plan for such a change may also be a factor in why these options are not  often selected. For example, a district official reported that the district did  not have sufficient time during the restructuring planning process to  seriously consider reopening as a charter school, contracting with a  private management company, or turning the operation of the school over  to the state. In about 70 percent of schools, the district played a significant  role in determining the restructuring option taken.
Although a majority of schools implemented a restructuring option, about  40 percent of the schools that were in restructuring did not take any of the  5 restructuring options prescribed under NCLBA, according to our survey  results. Several principals of schools that had not restructured did not  know why an option was not taken. In other cases, principals believed that  the school board or district had decided not to restructure. In addition,  one of the surveyed schools and some school and district officials we  visited did not believe restructuring was necessary when student  achievement was improving. For example, officials at one of the schools  we visited that was planning for restructuring indicated that the district  and school administration had determined that no changes were needed  because they were confident that the actions already taken were helping  students.
Nonetheless, about half of the schools that did not take one of the five  restructuring options engaged in a variety of school improvement efforts.  Some of these efforts may fall under the “other” major restructuring  option, while others do not appear to be consistent with NCLBA  requirements for restructuring. For example, one school implemented a  new curriculum as a restructuring option, while at another school extra  funding was used for small group instruction and after-school programs,  both of which more closely resemble corrective action under NCLBA. In  addition, in two districts we visited, officials allowed schools that were  improving to continue efforts started under prior stages of improvement.  However, we could not determine based on the information reported by  survey respondents whether these activities would be considered  restructuring under NCLBA. Further, several Education officials we spoke  with could not determine whether or not the actions schools reported  taking were in compliance without more information from the schools,  such as other on-going districts efforts.
Similar to our finding that many schools may not be implementing a  restructuring option, Education’s 2006 interim report on Title I stated that  very few schools in restructuring status implemented a restructuring  option prescribed by NCLBA, though many implemented actions NCLBA  specifies for the corrective action stage of school improvement. Despite  these findings, department officials told us that they did not have any  monitoring findings related to restructuring requirements, nor did they  know whether any states had found districts that had not implemented  restructuring requirements, although they did find deficiencies in some  districts’ review of school improvement plans.
Education’s monitoring tools and reporting requirements do not fully  address issues of compliance. While Education’s state monitoring tool  includes questions about how states monitor the implementation of school  improvement plans, Education officials acknowledged that the department  may be able to strengthen its monitoring tool to determine whether state  oversight of districts is adequate to ensure compliance. Also, since states  are not required to report district noncompliance to Education and  Education does not require states to report on the specific corrective  actions and restructuring options taken to address the achievement  problems of each school, federal officials have limited information on  areas in which there are compliance issues as well as the extent to which  districts are complying.
section_title: A Higher Percent of Schools That Fully Implemented Improvement Activities Made AYP
paragraphs: We estimate that over a third of schools that fully implemented a  corrective action or restructuring option made AYP, as opposed to   16 percent of schools that had mostly or partially implemented  improvement activities. Several officials noted, and research shows, that  school improvement efforts take more than a year to affect student  achievement, so it is possible that these activities will help these schools  make AYP over the next several years. Many district and school officials  we interviewed told us that implementing a new curriculum takes time and  that other improvement efforts can take several years to fully implement  and to see results. Other factors also can affect school improvement  efforts. For example, among the schools that made AYP, 76 percent of  principals believed teacher quality helped or greatly helped school  improvement activities in their school, opposed to only 53 percent among  schools that had not made AYP. In addition to teacher quality, around 80  percent of school officials believed that instructional support and  resources, such as teacher aides and computers, helped or greatly helped  their school improvement efforts. Schools lacking such support may find  implementation of corrective action and restructuring more challenging.
Based on our survey results, none of the specific corrective actions or  restructuring options was associated with making AYP, nor was making  AYP associated with the number of activities undertaken, and these  findings are consistent with recent research on school improvement.  Many school officials believed that other factors affected student  achievement and therefore, the schools’ ability to make AYP. About   80 percent of school principals believed that community poverty impeded  student achievement, while two-thirds believed community violence  impeded achievement. We found similar views during our site visits. For  example, at two schools we visited, officials noted that the presence of  gangs in the neighborhood affected student achievement, and teachers at  one school commented that it was unsafe for students to visit the  community library after dark. Several school and district officials  observed that poverty affected students’ academic efforts. School officials  noted that many poor students cannot stay late at school because they  have family obligations, such as taking care of younger children. In  addition, about two-thirds of school principals believed that student  mobility (moving from one school to another) impeded student  achievement, and several officials said that districtwide or statewide  curricula had been implemented, in part, to address widespread student  mobility by establishing a consistent instructional approach across  schools. Moreover, we estimate that nearly half of school officials believed  that low student attendance impeded student achievement at their school.  This finding was more prevalent among schools that had not made AYP  compared to schools that had made AYP. Finally, several activities were  undertaken by very few schools, such as state takeover or extending the  school year, so these activities’ association with AYP could not be  accurately assessed in this study.
section_title: Many Schools in Corrective Action and Restructuring Did Not Receive All Required Assistance through Their School Districts; However, Most Received Assistance from Their State
paragraphs: We estimate that more than 40 percent of the schools in corrective action  and restructuring did not receive all of the required technical assistance,  such as data analysis and professional development, through their school  district, but most of the schools received some technical assistance from  their state. While states generally are not required to provide specific kinds  of assistance to schools, they are required to develop a statewide system  of support that is available to schools and districts and to provide  technical assistance to schools if the district fails to do so. Most schools  reported receiving technical assistance from their state educational  agency, such as help from instructional experts or highly skilled  educators.
subsections: section_title: Many Schools in Corrective Action and Restructuring Did Not Receive All Required Assistance through Districts
paragraphs: We estimate that 42 percent of the schools in corrective action and  restructuring had not received all of the required assistance in school year  2005-2006 while about 56 percent did. Schools most frequently received  technical assistance related to professional development (92 percent) and  instructional strategies (90 percent). However, only about 70 percent  received assistance with analyzing the school budget to ensure that  resources were allocated toward improving student achievement. We also  found, based on our survey results, that 7 out of 313 schools (about   2 percent) in corrective action and restructuring received no assistance.  (See fig. 8 for the percentage of schools receiving each type of required  technical assistance.)
Education officials noted that through their monitoring site visits they  found that some districts had not provided all of the assistance required.  In these instances, Education officials said states could withhold Title I  funds from the districts that are out of compliance. However, Education  could not tell us how often states take actions against districts for not  providing required assistance, because according to one Education  official, Education did not collect this information from states.
Generally, school officials we met with told us that the district was  actively involved in providing assistance to their schools. Almost all school  principals and teachers that we interviewed specifically emphasized  district efforts to train their administrators and teaching staff to analyze  and use student testing data to target their instruction to areas of  academic weakness and to students that needed additional assistance. In  addition, they said that districts had targeted resources to provide  professional development and implement effective instructional practices.  For example, in most districts we visited, school officials said that literacy  or math coaches had been hired to provide staff development or to work  with teachers to identify instructional practices to improve instruction.  Also, in some schools we visited, officials told us that districts assisted the  schools in their efforts to increase parental involvement. For example, in  New York City, the district helped some schools by approving a parent  coordinator position to get parents more involved in their schools.  Officials in some districts also reported reviewing school budgets to  ensure that resources are allocated to programs that target student  performance. In regard to budget assistance, district officials in Chicago  told us that they must approve budgets of all schools in restructuring. In  addition, principals in two California schools reported that the district  reviewed their budgets and recommended expenditures that targeted  school improvement activities.
section_title: Most Schools Received Some Assistance from State Educational Agencies, and Almost Half of Schools Received State Funds for School Improvement
paragraphs: Most schools received some assistance from their state educational  agency, and almost half received state funds for school improvement.  States are required to develop a statewide system of support that is  available to assist districts. As a part of this system, states must create  school support teams, which are composed of various participants,  including highly qualified or distinguished educators, such as teachers and  principals who can assist the school in strengthening its instructional  program to improve student achievement. We estimate that about   65 percent of schools received assistance from their state educational  agency in developing the school improvement plan, and 60 percent  received assistance from a school support team (fig. 9). Although state  educational agencies generally are not required to provide specific kinds  of technical assistance to schools in corrective action and restructuring,  they are required to ensure that districts are providing all of the required  assistance to schools identified for improvement, and if the district has  not, state educational agencies must step in and provide the assistance.
An estimated 47 percent of the schools in corrective action and  restructuring received state funds for school improvement activities in  addition to federal Title I funds. While state funds were used for many  different kinds of school improvement activities, more than 75 percent of  the schools surveyed used the funds for professional development  activities, classroom support such as instructional and resource materials,  or both. In addition, officials in four of the five states we visited told us  that schools received state funds for school improvement activities.  Maryland provides its schools guidelines on how the funds can and cannot  be used and the guidelines emphasize that whenever possible, the funds  should be used to improve instruction, such as purchasing textbooks or  hiring more school staff. Schools in California and New York apply for  state funds and must include a plan for how the funds will be used.
section_title: Education Provides Technical Assistance and Research on School Improvement, Including Some Specific Information on School Restructuring
paragraphs: Education provides technical assistance and research results to states  primarily through its Comprehensive Centers Program, consisting of   16 regional centers and 5 content centers (fig. 10). The department  replaced its former assistance centers and various education consortiums  to meet the requirements of the Education Sciences Reform Act of 2002.  The primary task of the content centers is to provide knowledge and  assistance by experts in school improvement to regional centers. The  regional centers are to provide technical assistance to states on a wide  range of topics related to NCLBA, in part based on information provided  by the content centers.
One content center, the Center on Innovation and Improvement, provides  a variety of services related to school improvement. The center developed  a guide, Handbook on Restructuring and Substantial School  Improvement, which it has disseminated to regional centers, state  educational agencies, and other organizations. The handbook provides  information on using student data to identify a restructuring option and  focusing instruction on state standards, among other topics. Other  services include the center’s annual 2-day training for representatives from  the regional centers and additional workshops throughout the year on  various improvement topics. The center produced a series of Web-based  seminars during the spring and summer of 2007, also based on the  handbook, for use by the regional centers. In addition, each regional  center has developed an annual work plan, negotiated with the states for  which it is responsible. For example, the New York Regional Center  provides assistance to the state of New York and has negotiated a work  plan with several goals related to school improvement. One goal is to help  the New York State Education Department build its school improvement  capacity by assisting with delivery of research-based professional  development related to adolescent literacy.
Education developed the What Works Clearinghouse to review studies of  educational interventions to determine which studies were conducted  with a sound methodology and to what extent the interventions are  effective. The clearinghouse has reviewed studies on topics such as  preventing dropouts and increasing elementary and middle school  achievement in mathematics. While these topics are likely to be of interest  for schools in corrective action and restructuring, the clearinghouse has  not reviewed studies that specifically deal with practices employed by  schools in corrective action and restructuring. Moreover, several state,  district, and school officials we interviewed indicated that they needed  more information on practices for improving schools in corrective action  and restructuring. For example, an official in one district told us that they  had been attempting to create their own approaches to improve schools,  but said that there was insufficient information, from federal or other  sources, on improvement practices. Recognizing the need for information  that may be more suited for teachers, principals, and other educators,  Education officials reported that the department will launch a Web site in  September 2007 related to their initiative, Doing What Works. Through this  initiative, Education would review studies identified by the clearinghouse  and develop materials, called “practice guides” for educators. According to  Education, a practice guide on school restructuring is in development and  may be available by the end of 2007.
In addition to the Comprehensive Centers and What Works Clearinghouse  programs, Education implemented a variety of other initiatives that may  assist officials in their efforts to improve schools. The department revised  its guidance in July 2006 to provide more information on school  restructuring. In addition, Education operates 10 Regional Education  Laboratories that provide research on a variety of topics. For example, the  Northwest Regional Education Laboratory is currently examining  statewide systems of support and the factors that have helped schools  make AYP. The laboratories are also available to provide assistance to any  entity, such as school districts or schools, that may request information  from them. Other resources include the Support for School Improvement  newsletter, developed by the Council of Chief State School Officers and  funded in part by Education. The newsletter focuses on topics such as  school improvement policies and closing achievement gaps among student  groups. Education also funds a clearinghouse for Comprehensive School  Reform, which disseminates research on effective approaches to school  reform through publications such as a recent report on what improvement  practices might work for schools in restructuring.
section_title: Conclusions
paragraphs: Schools that reach corrective action and restructuring status face many  challenges in raising the achievement levels of their students. These  schools typically serve low-income students, and many report that factors  such as neighborhood violence and student mobility pose additional  challenges to engaging students and improving their academic  performance. While most of these schools have implemented activities  that are required by NCLBA, it is possible that a significant number of  schools have not. Although Education has made efforts to provide  guidance to districts on what actions are required and when, the  department’s efforts do not address several specific issues that would  allow states, districts, and schools to make well informed decisions that  are in compliance with NCLBA. For example, many schools in corrective  action continued efforts implemented previously but did not implement a  new action. While this course of action may be a reasonable and  appropriate path for some schools to take, Education has not provided  guidance to districts delineating when continuing a corrective action—and  not taking an additional one—is appropriate and when it is not. Without  written guidance, some districts and schools that are not demonstrating  sustained improvement may continue previous efforts in order to avoid  having to make more changes. On the other hand, some districts may not  know they can comply with NCLBA by continuing an action that is moving  their schools forward and instead may be struggling to choose another  prescribed activity that is not needed.
While Education monitors states to ensure compliance with NCBLA—and  has found deficiencies in some districts’ reviews of schools’ improvement  plans—department officials told us that they were unaware that some  districts may not be implementing the required corrective action and  restructuring activities because they do not collect that specific  information. Collecting information on the activities of schools in  corrective action and restructuring and on compliance issues identified by  states would better position Education to target its guidance and  monitoring on areas of greatest need.
Finally, our review indicates that many schools may not be receiving all  the types of assistance that they are supposed to receive through their  districts. However, Education officials told us that they have not found any  instances in which schools in corrective action and restructuring have not  received required assistance, and officials noted that Education does not  track the extent to which states also have found such incidences. Schools  that are not receiving this assistance might not be able to make the kinds  of dramatic improvement needed for their students, in part because they  may not be receiving the resources to improve as envisioned by NCLBA.
section_title: Recommendations
paragraphs: The Secretary of Education should:    Ensure that guidance is provided to states and districts about when it  may be appropriate to allow schools to continue corrective action  implemented in earlier years of improvement and not take a new  activity as the school moves into corrective action status.
Obtain more specific information from states on district  implementation, such as the primary activity that each school in  corrective action and restructuring is implementing as well as more  specific information on compliance issues states have identified as part  of their monitoring activities. This information should be analyzed to  identify areas where further federal guidance is needed and to ensure  that areas of noncompliance are being addressed by states.
Take additional steps through Education’s monitoring process to  ascertain whether states are ensuring that districts provide the  assistance required by NCLBA.
section_title: Agency Comments and Our Evaluation
paragraphs: Education provided us with written comments on a draft of this report.  Education agreed with our three recommendations to provide more  guidance to states and districts, obtain more information on district  implementation of corrective action and restructuring activities, and take  additional steps to determine whether districts are providing assistance  required by NCLBA. Specifically, Education agreed to explore options for  sharing guidance on when schools may continue a corrective action while  not taking a new one and commented that it will explore sharing guidance  that address other issues related to schools in corrective action and  restructuring that it has asked states to identify. While Education noted  that it is generally informed on the actions taken in schools in corrective  action and restructuring, it agreed that more information is needed from  states on district implementation of corrective action and restructuring  activities and that it will consider options for gathering additional  evidence on how states ensure that districts are complying with corrective  action and restructuring requirements. Finally, Education agreed to  consider ways for revising its monitoring procedures in order to obtain  more information on how states determine whether districts are providing  technical assistance to these schools, the types of assistance they provide,  and the actions states take to address areas of noncompliance. See  appendix III for Education’s comments. Education also provided us with a  few technical comments that we incorporated.
We are sending copies of this report to the Secretary of Education and  other interested parties. We will also make copies available to others upon  request. In addition, the report will be made available at no charge on  GAO’s Web site at http://www.gao.gov.
Please contact me at (202) 512-7215 if you or your staff have any questions  about this report. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this report.  Major contributions to this report are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: To address the objectives of this study, we used a variety of methods. To  obtain a national perspective, we conducted descriptive analyses of  characteristics of schools in corrective action and restructuring and  compared them to all other Title I schools nationwide. We selected a  nationally representative sample of these schools and conducted two Web- based surveys—one of principals whose schools were in corrective action  and another for schools implementing restructuring—to obtain  information on implementation of corrective action and restructuring and  school district and state assistance to such schools. We also conducted  site visits during which we interviewed state, district, and school officials  representing 5 states and 10 school districts within these states, and we  conducted phone interviews with state officials from 4 other states. We  spoke with officials at Education involved in oversight and  implementation of corrective action and restructuring in schools and  reviewed Education’s data on schools identified for improvement. We also  interviewed several experts in the field of school improvement. We  reviewed federal laws, regulations, and agency guidance. We conducted  our work from August 2006 through August 2007 in accordance with  generally accepted government auditing standards.
subsections: section_title: Objective 1: Analysis of School Characteristics
paragraphs: To address the first objective, we obtained lists of schools in corrective  action, planning for restructuring, and implementing restructuring status  and their school districts from Education. States submitted these lists to  Education through the No Child Left Behind Act (NCLBA) Consolidated  State Performance Reports (CSPR) for school year 2004-2005, which  contained each school’s improvement status for the 2005-2006 school year,  among other data. Because states provided the names of schools in  corrective action and restructuring in their 2004-2005 CSPRs, these  schools comprised the national population of such schools. In some cases,  states used different labels for identifying schools in corrective action and  restructuring. For example, one state identified schools in corrective  action by labeling them as “Year 3” schools. When states used terms other  than corrective action and restructuring to indicate schools’ improvement  status, we contacted state officials to clarify the label the state used.  Education also provided us with numbers of schools in corrective action  and restructuring for the 2006-2007 school year, which we compared to  numbers from prior years. On the basis of our review of the data on  improvement status for school years 2005-2006 and 2006-2007, we  determined these sources to be sufficient for the purposes of our work.  We used the lists of schools in corrective action and restructuring for the  2005-2006 school year to develop our survey samples and for comparisons  with other Title I schools not identified as needing improvement.
Also in the CSPR, states provided each school’s nationally unique  identification number, allowing us to link data on these schools with data  provided in Education’s Common Core of Data (CCD). The CCD is a  database of Education’s National Center for Education Statistics, which  annually collects data from state educational agencies about all public  schools, public school districts, and state educational agencies in the  United States. At the time we began our analysis, the latest CCD data  available were from the 2004-2005 school year. Although we based our  analysis on schools in corrective action and restructuring in 2005-2006, the  characteristics were based on one year prior. Upon linking schools  identified in the CSPR to those in the CCD, we obtained data on the  following characteristics:  locale: whether the school was located was in an urban, suburban, or  rural area or town;    minority status: the percent of students in the school classified as  American Indian/Alaskan Native, Asian/Pacific Islander, Black/Non- Hispanic, or Hispanic;    poverty status: the percent of students in the school who qualified for  free- or reduced-priced meals; and    grade levels served: whether primary, middle, or high school grades.
To define these levels, we used the definitions provided in the CCD, as  listed in table 9.
Schools that did not fit these grade-level configurations were classified as  “other,” meaning any other combination, from the low grades of  prekindergarten, kindergarten or first grade up to twelfth grade, consistent  with the CCD definition.
We compared the percentage of schools in corrective action and  restructuring with all other Title I schools within each category of the  characteristics of locale and grade levels served. For minority status and  poverty status, we compared schools in corrective action and  restructuring with all other Title I schools by comparing the  characteristics of the median school within each group. The median is the  school in the middle of a list of schools when they are listed from highest  to lowest along any given characteristic, such that one-half of the schools  are listed above and the other half are listed below that school. For  example, when all corrective action and restructuring schools were listed  from highest to lowest in terms of poverty status, the school in the middle  of that list had a poverty rate of 96 percent. In contrast, when all other  Title I schools were listed from highest to lowest, the school in the middle  of that list had a poverty rate of 37 percent. We chose to use the median  school instead of calculating the average for all schools or all students,  because so many schools had high rates of poverty and minority student  representation, that the median more accurately characterized the typical  school in our dataset than did the average.
We performed a series of tests and took additional steps as needed to  assess the reliability of the data used. For the lists of schools obtained in  the CSPR and the CCD, we checked to ensure that data were consistent,  that subtotals added to overall totals and that data provided for 1 year  bore a reasonable relationship to the next year’s data and to data reported  elsewhere, including state education reports. We also spoke with  Education officials about their follow-up efforts to verify the data. At the  time of our review, Education reported that the 2004-2005 data had been  verified.
On the basis of our review of these data, we determined these sources to  be sufficiently reliable for the purposes of our work. We also considered  school improvement-related findings from Education studies, including  the National Assessment of Title I Interim Report, Vol. 1:  Implementation (2006). To ensure the findings from these studies were  sufficiently reliable, we reviewed each study’s methodology, including  data sources and analyses, limitations, and conclusions. We found these  studies to be sufficiently reliable for the purposes of our work.
section_title: Objectives 2 and 3: Implementation of Corrective Action and Restructuring and State and District Assistance
paragraphs: To address the second objective on school’s implementation of corrective  action and restructuring and the third objective on district and state  assistance, we designed and administered two Web-based surveys to a  nationally representative sample of school principals: one for schools in  corrective action and one for schools in restructuring, as of the 2005-2006  school year. The surveys were conducted between January and March  2007. To obtain the maximum number of responses, we sent follow-up   e-mail notifications with a link to the surveys to those who had not  completed the survey approximately 1 week after the initial launch and  additional six follow-up notifications every week thereafter. In addition,  approximately 3 weeks after the Web surveys began, we provided a mail  survey to those who had not responded. The surveys included questions  about corrective actions or restructuring options the school had taken.  Both surveys included questions about factors that may have influenced  student achievement and assistance provided by the state and district. We  also conducted site visits to 5 states and 10 school districts and 20 schools  within these states, during which we conducted interviews and obtained  documentation on school improvement efforts and related topics. Finally,  we reviewed Education’s regulations, guidance, and monitoring tools and  interviewed department officials about monitoring and guidance related to  corrective action and restructuring. Specifically, we reviewed the NCLBA,  associated regulations, Local Education Agency and School Improvement  Guidance (revised July 2006), monitoring tools and indicators used during  Education’s site visits, and selected monitoring reports and findings.
subsections: section_title: Corrective Action Survey
subsections: section_title: Sample Design and Errors
paragraphs: Based on data obtained from the CSPR, the study population of   1,163 schools consisted of all public Title I schools that were in corrective  action in the 2005-2006 school year. We selected a random sample of  schools in the population and calculated the sample size to achieve a  precision of plus and minus 8 percent at the 95 percent confidence level  for an expected proportion of 50 percent. To ensure the sample sizes were  adequate, we set the sample size assuming we would obtain a 70 percent  response rate. The total sample size was 240 schools. In the sample, each  school in the population had a known, nonzero probability of being  selected. Each selected school was subsequently weighted in the analysis  to account statistically for all the schools in the population, including  those that were not selected.
Because we surveyed a sample of schools, survey results are estimates of  a population of schools and thus are subject to sampling errors that are  associated with samples of this size and type. Since we followed a  probability procedure based on random selections, our sample is only one  of a large number of samples that we might have drawn. As each sample  could have provided different estimates, we express our confidence in the  precision of our particular sample’s results as a 95 percent confidence  interval (for example, plus or minus 8 percentage points). This is the  interval that would contain the actual population value for 95 percent of  the samples we could have drawn. As a result, we are 95 percent confident  that each of the confidence intervals in this report will include the true  values in the study population. We excluded 8 of the sampled schools,  because they were not in corrective action status in the 2005-2006 school  year, were not Title I schools or had closed, and therefore were  considered out of scope. All estimates produced from the sample and  presented in this report are representative of the in-scope population. All  percentage estimates included in this report have margins of error of plus  or minus 8 percentage points or less, unless otherwise noted.
We took steps to minimize nonsampling errors that are not accounted for  through statistical tests, like sampling errors. In developing the Web  survey, we conducted several pretests of draft instruments. We pretested  the survey instrument with school officials in Aurora, Illinois; Berkeley,  California; and Orange, New Jersey, between October and November 2006.  We selected schools in these states because they contained large numbers  of schools in corrective action and thus it was likely that schools from  these states would be included in our sample. In the pretests, we were  generally interested in the clarity of the questions and the flow and layout  of the survey. For example, we wanted to ensure definitions used in the  surveys were clear and known to the respondents, categories provided in  closed-ended questions were complete and exclusive, and the ordering of  survey sections and the questions within each section was appropriate. We  revised the survey on the basis of information we gathered in the pretests.
A second step we took to minimize nonsampling errors was using a Web- based survey. By allowing respondents to enter their responses directly  into an electronic instrument, this method automatically created a record  for each respondent in a data file and eliminated the need for and the  errors (and costs) associated with a manual data entry process. To further  minimize errors, programs used to analyze the survey data and make  estimations were independently verified to ensure the accuracy of this  work.
While we did not fully validate specific information that school officials  reported in our survey, we took several steps to ensure that the  information was sufficiently reliable for the purposes of this report. For  example, data from mailed surveys were double-keyed to ensure data  entry accuracy, and the information was analyzed using statistical  software. We obtained corroborating evidence of schools’ improvement  status when the information provided by the school conflicted with the  information we had received from the Department of Education. In  addition, we verified the responses of those schools that reported that the  school had made AYP. When survey responses did not align with the  information that we obtained from state Web sites and school report  cards, we made changes to the survey responses based on documentary  evidence. After the survey was closed, we also made comparisons between  select items from our survey data and another national-level data set. We  found our survey data were reasonably consistent with the external  sources. On the basis of our checks, we believe our survey data are  sufficiently reliable for the purposes of our work.
section_title: Response Rate
paragraphs: We received survey responses from 68 percent of the Title I schools in  corrective action in our sample. After the survey was closed, we analyzed  the survey respondents to determine if there were any differences between  the responding schools, the nonresponding schools, and the population.  We performed this analysis for four characteristics—percentage of  minority students, percentage of students with free lunch, region, and  locale. We found no significant differences between the estimates for the  survey respondents and the overall population values for these  characteristics. On the basis of the 68 percent response rate and this  analysis, we chose to include the survey results in our report and produce  sample-based estimates to the population of schools in corrective action in  the 2005-2006 school year.
section_title: Restructuring Survey
subsections: section_title: Sample Design and Errors
paragraphs: The study population of 920 schools consisted of public Title I schools that  were implementing restructuring in the 2005-2006 school year. This  population was obtained from the CSPR data provided by Education, as  described above. We used the same sample design for the restructuring  Web survey as the design used for the corrective action survey. The total  sample size was 230 schools.
We determined that 12 of the sampled schools were out of scope because  they were not implementing restructuring in the 2005-2006 school year. All  estimates produced from the sample and presented in this report are  representative of the in-scope population. All percentage estimates  included in this report have margins of error of plus or minus 8 percentage  points or less, unless otherwise noted.
As with the corrective action survey, we took steps to minimize  nonsampling errors. We pretested the survey instrument with school  officials in Detroit, Michigan and Syracuse, New York, between October  and November 2006. We selected schools in these states because the states  contained large numbers of schools implementing restructuring and thus it  was likely that schools from these states would be included in our sample.  The pretests were conducted in the same manner as those done for the  corrective action survey. On the basis of the pretests, the Web instrument  underwent some revisions. Again, use of a Web-based survey also  minimized nonsampling errors as did independently verifying programs  used to analyze the survey data and make estimations.
Steps taken to ensure that the information was sufficiently reliable for the  purposes of this report mirror those taken for the corrective action survey,  including obtaining corroborating evidence of schools’ improvement  status when the information provided by the school conflicted with the  information we had received from the Department of Education. When a  survey response did not align with the information that we obtained from  state Web sites and school report cards, we made changes based on our  documentary evidence. We checked a sample of schools that claimed to  have made AYP to verify these responses and found that the responses  were accurate. Again, we made comparisons between select items from  our survey data and other national-level data sets, and found our survey  data were reasonably consistent with the external sources. On the basis of  our checks, we believe our survey data are sufficient for the purposes of  our work.
section_title: Response Rate
paragraphs: We received survey responses from 74 percent of the Title I schools  implementing restructuring in our sample. After the survey was closed, we  analyzed the survey respondents to determine if there were any  differences between the responding schools, the nonresponding schools,  and the population, as was done for the corrective action survey. We  found no significant differences between the estimates for the survey  respondents and the overall population values for these characteristics.  On the basis of the 74 percent response rate and this analysis, we chose to  include the survey results in our report and produce sample-based  estimates to the population of schools in restructuring in the 2005-2006  school year.
section_title: Combined Surveys
paragraphs: Many of the questions on the corrective action survey and restructuring  survey were the same. For example, on both surveys we asked about the  assistance provided by the state and district, the factors that impeded or  facilitated student achievement, and the factors that helped or hindered  implementation of school improvement efforts. For such questions, we  combined the survey responses for reporting purposes. We weighted the  respondents so that the estimates are for the in-scope combined  population of corrective action and implementing restructuring schools.  Because we surveyed a sample of schools, our results are estimates of a  population of Title I schools in corrective action and implementing  restructuring and thus are subject to sampling errors that are associated  with samples of this size and type. All percentage estimates included in  this report have margins of error of plus or minus 8 percentage points or  less, unless otherwise noted.
section_title: Site Visits
paragraphs: To understand corrective action and restructuring implementation at the  local level, we conducted site visits to 5 states and 10 districts and   20 schools within these states between October 2006 and March 2007. The  5 states we chose were: California, Illinois, Maryland, New York, and  Pennsylvania. Together, these 5 states had 59 percent of schools in  corrective action and restructuring nationwide in the 2005-2006 school  year and are located in a variety of geographic regions. We interviewed  state officials on state efforts to oversee and assist schools in corrective  action and restructuring.
Within each of the 5 states, we visited 2 school districts, for a total of   10 school districts, as shown in table 10. The 10 districts were selected  because they had experience implementing corrective action and  restructuring. When viewed as a group, the districts also provided  variation across characteristics such as geographic location and district  size.
During the site visits, we interviewed state and district officials as well as  officials representing 20 schools, including principals, teachers, and other  school staff involved with school improvement activities in order to  provide in-depth information and illustrative examples of our more general  findings. The selected schools resembled the population of schools in  corrective action and restructuring in terms of the grade levels served, and  the students’ racial, ethnic, and economic characteristics. While in many  cases district officials selected the schools we visited, all of the schools  had experience implementing corrective action or restructuring. Through  our interviews with state, district, and school officials, we collected  information on corrective actions and restructuring options implemented,  factors affecting student achievement, and state and district assistance  provided to schools in corrective action and restructuring.
section_title: Objective 4: Education’s Efforts to Support State Implementation
paragraphs: To address the fourth objective on Education’s efforts to assist states’  implementation of corrective action and restructuring provisions, we  conducted interviews with representatives of the offices of Title I,  Planning, Evaluation, and Policy Development, What Works  Clearinghouse, Comprehensive Centers Program, and General Counsel.  We also interviewed officials with the Center on Innovation and  Improvement, the California and New York Regional Centers, and the  Northwest Regional Education Laboratory.
In addition, we interviewed experts in the field on school improvement,  including those at the American Institutes for Research, Center on  Education Policy, Council of the Great City Schools, Council of Chief State  School Officers, Education Commission of the States, and RAND  Corporation. We reviewed several studies on school improvement,  corrective action, and restructuring.
section_title: Appendix II: Number of Schools in Corrective Action, Planning for Restructuring, and Implementing Restructuring, by State in 2005- 2006 and 2006-2007
subsections: section_title: Planning for Restructuring
paragraphs: For the 2005-2006 school year, Georgia required schools in corrective action to plan for  restructuring. We reported these schools as in status as corrective action.
section_title: Appendix III: Comments from the Department of Education
section_title: Appendix IV: GAO Contacts and Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: Bryon Gordon, Assistant Director, and Elizabeth Morrison managed the  assignment. Cara Jackson, Jason Palmer, and Nancy Purvine made  significant contributions to this report in all aspects of the work.   Susannah Compton, Nancy Hess, Jean McSween, and Jerome Sandeau  provided analytical assistance. Sheila McCoy provided legal support, and  Karen Burke developed the report’s graphics.
section_title: Related GAO Products
paragraphs: Teacher Quality: Approach, Implementation, and Evaluation of Key  Federal Efforts. GAO-07-861T. Washington, D.C.: May 17, 2007.
No Child Left Behind Act: Education Actions May Help Improve  Implementation and Evaluation of Supplemental Educational Services.  GAO-07-738T. Washington, D.C.: April 18, 2007.
No Child Left Behind Act: Education Assistance Could Help States Better  Measure Progress of Students with Limited English Proficiency.   GAO-07-646T. Washington, D.C.: March 23, 2007.
Reading First: States Report Improvements in Reading Instruction, but  Additional Procedures Would Clarify Education’s Role in Ensuring  Proper Implementation by States. GAO-07-161. Washington, D.C.:  February 28, 2007.
No Child Left Behind Act: Education Actions Needed to Improve  Implementation and Evaluation of Supplemental Educational Services.  GAO-06-1121T. Washington, D.C.: September 21, 2006.
No Child Left Behind Act: Education Actions Needed to Improve Local  Implementation and State Evaluation of Supplemental Educational  Services. GAO-06-758. Washington, D.C.: August 4, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic  Growth. GAO-06-948T. Washington, D.C.: July 27, 2006.
No Child Left Behind Act: Assistance from Education Could Help States  Better Measure Progress of Students with Limited English Proficiency.  GAO-06-815. Washington, D.C.: July 26, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic  Growth That Education’s Initiatives May Help Address. GAO-06-661.  Washington, D.C.: July 17, 2006.
No Child Left Behind Act: Improved Accessibility to Education’s  Information Could Help States Further Implement Teacher Qualification  Requirements. GAO-06-25. Washington, D.C.: Nov. 21, 2005.
No Child Left Behind Act: Education Could Do More to Help States Better  Define Graduation Rates and Improve Knowledge about Intervention  Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005.
No Child Left Behind Act: Most Students with Disabilities Participated  in Statewide Assessments, but Inclusion Options Could Be Improved.  GAO-05-618. Washington, D.C.: July 20, 2005.
Charter Schools: To Enhance Education’s Monitoring and Research,  More Charter School-Level Data Are Needed. GAO-05-5. Washington, D.C.:  Jan. 12, 2005.
No Child Left Behind Act: Education Needs to Provide Additional  Technical Assistance and Conduct Implementation Studies for School  Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004.
No Child Left Behind Act: Improvements Needed in Education’s Process  for Tracking States’ Implementation of Key Provisions. GAO-04-734.  Washington, D.C.: Sept. 30, 2004.
No Child Left Behind Act: Additional Assistance and Research on  Effective Strategies Would Help Small Rural Districts. GAO-04-909.  Washington, D.C.: Sept. 23, 2004.
Special Education: Additional Assistance and Better Coordination  Needed among Education Offices to Help States Meet the NCLBA Teacher  Requirements. GAO-04-659. Washington, D.C.: July 15, 2004.
Student Mentoring Programs: Education’s Monitoring and   Information Sharing Could Be Improved. GAO-04-581. Washington, D.C.:  June 25, 2004.
No Child Left Behind Act: More Information Would Help States  Determine Which Teachers Are Highly Qualified. GAO-03-631.  Washington, D.C.: July 17, 2003.
Title I: Characteristics of Tests Will Influence Expenses; Information  Sharing May Help States Realize Efficiencies. GAO-03-389. Washington,  D.C.: May 8, 2003.