Disadvantaged Students: School Districts Have Used Title I Funds Primarily to Support Instruction
Published: 2011-07-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Title I of the Elementary and Secondary Education Act (ESEA), as amended, is the largest federal education funding source for kindergarten through grade 12. In fiscal year 2010, Congress appropriated $14.5 billion for Title I grants to school districts to improve educational programs in schools with high concentrations of students from lowincome families. ESEA includes accountability requirements for schools and districts that focus primarily on measuring academic outcomes rather than prescribing exactly how Title I funds are to be spent. ESEA, as amended, includes a mandate that requires GAO determine how selected districts expend Title I funds. In response, GAO addressed (1) how selected school districts spent their Title I funds and (2) what federal mechanisms are in place to oversee how Title I funds are used and what is known about the extent of noncompliance with relevant requirements. To do this, GAO visited a nongeneralizable sample of 12 school districts in 4 states and analyzed their Title I expenditures for the 2008-2009 school year. GAO also reviewed federal and local audit findings for a wider range of states and districts. Districts were selected based on criteria in the mandate including variation in size, student demographics, location, and economic conditions.
section_title: What GAO Found
paragraphs: GAO found that 12 selected districts in Louisiana, Ohio, Rhode Island, and Washington used Title I funds primarily for instructional purposes, consistent with findings from other research. Most selected districts focused Title I activities at the elementary level, where they expected the greatest improvement in academic achievement. Title I funds supported district initiatives to improve academic outcomes, such as reducing class sizes, extending class time, and coaching Title I teachers. The selected districts generally spent the majority of Title I funds on salaries and benefits, largely for instructional personnel. Districts with schools that failed to meet state adequate yearly progress goals for two or more consecutive years were required by law to reserve funds for various initiatives, such as transportation for public school choice, supplemental educational services, and professional development. In some districts such set-asides, which do not flow directly to schools, accounted for sizable portions of funds, amounting in two districts to 28 percent of Title I revenue. Predictably, such districts spent more than other districts on purchased services, such as tutoring for students eligible for supplemental educational services. Title I recipients are subject to various oversight mechanisms, which provide some information on noncompliance with relevant spending requirements, but are not designed to provide estimates of the prevalence of noncompliance. The Department of Education (Education) has conducted state-level monitoring to assess states' Title I program implementation. It has identified common issues, such as failure to ensure that districts properly calculate or reserve funds for specific purposes. To guard against fraud and abuse, Education's Office of Inspector General (OIG) uses risk-based criteria, such as past audit findings, to select districts for financial audit. In such districts, OIG has found instances of unallowable expenditures of Title I funds. Also, all states and districts that spend more than $500,000 in federal awards must file an annual audit that focuses on financial management and compliance with provisions of selected federal programs. Roughly 18 percent of districts that filed a fiscal year 2009 audit in which Title I compliance was reviewed had findings related to Title I, which most commonly dealt with unallowable costs and cost principles. However, only a subset of districts are audited for Title I compliance in any given year. When any type of oversight identifies noncompliance, school districts and states must identify and take corrective actions. Education also uses results of oversight and monitoring to target future monitoring efforts and to develop technical assistance and training to assist states and school districts in using their resources and flexibility appropriately.
section_title: What GAO Recommends
paragraphs: GAO is not making recommendations. Education provided technical comment on a draft of this report, which we incorporated as appropriate.

section_title: Letter
paragraphs: Title I of the Elementary and Secondary Education Act of 1965 (ESEA),  as amended, provides flexible funding to state and local educational  agencies to expand and improve educational programs in schools with  high concentrations of students from low-income families. Title I funds  may be used to provide additional instructional staff, professional  development for instructional staff and administrators, after-school  programs, and other strategies for raising student achievement. Congress  appropriated $14.5 billion in fiscal year 2010 for Title I grants to school  districts, making Title I the largest federal funding source for kindergarten  through grade 12 education, and. Under the American Recovery and  Reinvestment Act of 2009, an additional $10 billion was provided to  school districts for Title I programs for use through fiscal year 2010.  ESEA, as amended in 2001, included a mandate that requires us to  identify how school districts expend Title I funds, including the extent to  which funds were expended on academic instruction. In 2003, we  reported on this issue pursuant to the mandate. At that time, we found  that selected districts spent at least 84 percent of their Title I funds on  activities related to instruction. As Congress plans for the reauthorization  of ESEA, interest remains in better understanding how these funds are  spent and how much federal education funding reaches the classroom.  To respond to this mandate and the continued interest in Title I  expenditures, we determined (1) how selected school districts spent their  Title I funds, and (2) what federal mechanisms are in place to oversee  how Title I funds are used, and what is known about the extent of  noncompliance with relevant requirements.
To determine how selected districts used Title I funds, we selected and  visited three school districts in each of four states—Louisiana, Ohio,  Rhode Island, and Washington. Combined, these 12 districts comprise  463 schools serving more than 230,000 students. We selected these  states and districts based on the characteristics described in the  mandate, including variation in size, student demographics, economic  conditions, and geographic locations. We reviewed Title I plans, audits,  and budget and expenditure reports that detailed district uses of Title I  funds, and conducted semi-structured interviews with state and district  officials to better understand these uses. Districts tended to use a  consistent set of categories to describe expenditures on items, such as  salaries, benefits, supplies, and services. We were generally able to  ascertain what proportions of staff (almost always the largest category of  expenditures funded by Title I) were in administrative, instructional, and  instructional support positions; however, districts did not consistently  classify all types of expenditures in a way that always allowed us to  ascertain their purpose—for example, instructional versus  noninstructional. Although we were not able to directly compare all  instructional versus noninstructional expenditures for all districts, our  comparison of the proportion of staff funded by Title I in each category  accounted for a substantial portion of districts’ expenditures and allowed  us to draw conclusions for the selected districts. We assessed the  reliability of the expenditure data provided to us by the districts by (1)  reviewing data for obvious inconsistencies, errors, and completeness; (2)  comparing it with other available expenditure data to determine data  consistency and reasonableness; (3) interviewing district Title I and  financial officials about expenditure data quality control procedures; and  (4) selecting transactions in varied expenditure categories and reviewing  documentation for those transactions to determine whether the amount  and expenditure category were accurate. We determined that the  expenditure amounts and object categories were sufficiently reliable for  our purposes of describing the nature of district Title I expenditures and  making broad comparisons of districts’ expenditures. Due to the limited  number of districts selected, our findings cannot be generalized to school  districts nationwide. However, we conducted a literature review to  determine what researchers have found regarding how Title I funds are  spent nationwide. In addition to studies identified in our 2003 report, we  identified one additional study that met our criteria. We also analyzed  relevant federal laws, regulations, and guidance related to Title I  spending.
To determine what is known about the extent of noncompliance with  requirements related to Title I spending, we reviewed the findings from  various oversight mechanisms that have examined Title I spending,  namely those described in 2009 Department of Education (Education)  monitoring reports, audit reports issued by Education’s Office of the  Inspector General (OIG), and fiscal year 2009 single audit reports for  school districts. To describe the results of single audits, we analyzed  selected data that were reported to the Federal Audit Clearinghouse by  school districts.  We assessed the reliability of the Federal Audit  Clearinghouse data on single audits by (1) performing electronic testing of  required data elements, (2) reviewing existing information about the data  and systems that produced them, and (3) interviewing U.S. Census  Bureau officials knowledgeable about the database. We determined that  these data were sufficiently reliable for the purpose of presenting  descriptive analysis of single audits of school districts. However, because  not all districts are required to submit reports and some that are required  to do so may not, our findings describe those districts that have submitted  reports and are not generalizable to districts nationwide. For more  information on our scope and methodology, see appendix I.
We conducted this performance audit from May 2010 through June 2011  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: Educational Expenditures
paragraphs: School districts receive funding from a variety of sources, including local,  state, and federal governments. Title I funds, received by more than 90  percent of the nation’s school districts and more than 55 percent of all  public schools, make up a small portion of most districts’ overall funding.  Specifically, in fiscal year 2008, the most recent year for which data were  available, about 8 percent of districts’ funding came from federal  programs and about 2 percent of districts’ funding came from Title I,  which is generally the largest of the federal funding sources for  kindergarten through grade 12. In individual districts, the share of funding  from Title I ranged from zero to 36 percent in 2008. Generally, Title I  allocations to districts are based on the district’s size and percentage of  students from low-income families, as well as the population of the  district’s state and how much that state spends per pupil on education.
The National Center for Education Statistics reports information about  school district expenditures based on data collected by the U.S. Census  Bureau.  These data include information on how much districts spend for  particular activities, such as instruction, administration, and instructional  support. They also include information on the types of goods and services  purchased, such as salaries, benefits, and equipment. However, they do  not indicate which funding sources (such as Title I) these expenditures  are made from. According to data reported by the National Center for  Education Statistics for 2007–2008, 61 percent of total school district  expenditures (from all revenue sources) were for instruction.
section_title: Requirements
paragraphs: Title I funds are awarded to states, which distribute the vast majority of  them for use by school districts, and Title I does not describe allowable  uses of funds for specific goods or services. To provide for local flexibility  in determining how to use funds, ESEA requires districts to measure  academic outcomes and achieve benchmarks, but does not generally  dictate how funds are to be spent. Title I funds are intended for  instruction and other supportive services for disadvantaged children so  that they can master challenging curricula and meet state standards in  core academic subjects. Title I does not include a definition of costs  related to instruction, or costs unrelated to instruction that school districts  must use. While Education has issued guidance on Title I, it has not  prescribed specific uses of Title I funds. According to Education officials,  the agency is reluctant to endorse spending on any particular good or  service, as Education wants to allow schools to spend the money to meet  their unique needs and to be free to spend the money creatively.
Schools may run two types of Title I programs—targeted and schoolwide.  Schools where more than 40 percent of students are from low-income  families may operate schoolwide programs, enabling them to serve all  children at the school with Title I funds. In targeted-assistance schools,  Title I funds may only be used to benefit children who are determined to  be eligible by being identified as failing, or most at risk of failing, to meet  the state’s student academic achievement standards. Schoolwide  programs offer schools more flexibility than targeted programs in using  Title I funds because they may use these funds to support all students,  regardless of students’ Title I eligibility, and to fund a comprehensive  school plan to upgrade all the instruction in a school. Schoolwide  programs also offer additional fiscal flexibility when schools combine  separate program resources into a single accounting fund. The  schoolwide model has become the dominant model as schools have  opted to take advantage of the flexibility to serve all students. However,  schools and districts are still responsible for maintaining appropriate  internal controls over all federal education funds.
While Title I is a flexible funding source, ESEA contains some provisions  requiring a minimum percentage or limiting the maximum percentage of  funds that can be used for specific purposes. For example, the law  requires that, generally, a state spend no more than 1 percent on  administration. States are required to reserve 4 percent of Title I funds  to provide school districts with funds for school improvement activities,  unless this amount would reduce school districts’ Title I grant below the  amount received in the prior year. States may also reserve up to 5  percent of Title I funds in excess of the state’s previous year allocation for  academic achievement awards to schools. Similarly, the law requires  that school districts in need of improvement reserve at least 10 percent of  Title I funds for teacher professional development. School districts with  schools in need of improvement must also spend specific percentages of  Title I funds to provide student transportation to support public school  choice and supplemental educational services to students in those  schools.
Among other provisions, the law also contains several fiscal  requirements, including a maintenance of effort requirement that districts’  state and local funding levels not decrease by more than 10 percent in  any year; a stipulation that Title I funds be used to supplement, not  supplant, state and local funds; and a requirement that state and local  funds be used to provide comparable services to schools receiving funds  and those not receiving funds.
While ESEA limits the percentage of Title I funds that states may use for  administrative purposes, it does not limit the amount that school districts  may use. We noted in our 2003 report that there is no specific definition of  administrative activities for Title I and that Education’s general  administrative regulations and guidance address the issue of how  grantees should identify administrative costs. Education’s general  administrative regulations state that “administrative requirements mean  those matters common to grants in general, such as financial  management, kinds and frequency of reports, and retention of records.”  In 1998, Education issued a report entitled The Use of Federal Education  Funds for Administrative Costs, which discussed various definitions of  administrative costs and activities in common use. Guidance issued by  Education on what constitutes administrative costs states that “he costs  of administration are those portions of reasonable, necessary and  allowable costs associated with the overall project management and  administration. These costs can be both personnel and nonpersonnel  costs and both direct and indirect.” The guidance provides a list of  examples of direct administrative costs such as the salaries, benefits, and  other expenses of staff that perform overall program management,  program coordination, and office management functions.
Indirect costs represent the expenses that are not readily identified with a  particular grant function or activity, but are necessary for the general  operation of the district and the conduct of activities it performs. An  indirect cost rate is a mechanism for determining what proportions of a  district’s overall administration costs each program should bear and is  expressed as a percentage of some or all of the direct cost items in the  district’s budget. For example, the costs involved with providing office  space, financial services, or general payroll services to officials who  administer Title I grants cannot be directly allocated to the grant because  these services are provided to a large number of people. The indirect cost  rate, which is approved by the state, accounts for these types of  expenses.
section_title: Selected School Districts Used Funds to Support a Variety of Initiatives, Primarily Related to Instruction, to Improve Student Outcomes
subsections: section_title: District Title I Initiatives Were Generally Targeted at the Elementary Level and Included Reducing Class Sizes and Extending Instructional Time
paragraphs: The 12 selected school districts we visited used Title I funds for activities  intended to improve academic outcomes for low-income students,  primarily in elementary school, through a variety of initiatives, such as  reducing class sizes and expanding instructional hours. As seen in figure  2, these funds represented a relatively small proportion of total revenues  in our selected districts, from less than 1 to more than 8 percent.  However, Title I funds may be used in conjunction with local, state, or  other federal funding sources to support larger initiatives than Title I funds  alone could support. For example, Title I funds could be used along with  ESEA Title II (Improving Teacher Quality State Grants) funds to support a  literacy program or to support a supplemental component, such as small  group instruction, of a larger state-funded or locally funded literacy  initiative. In this case, the Title II funds might be used to provide  professional development to teachers in the literacy program, and Title I  might be used to hire teachers for small group instruction.
Given the relatively small proportion of funding they received from Title I,  8 of the 12 districts we visited chose to target Title I funds at the  elementary grade levels, where officials said they believed the funds  would provide the greatest improvements in academic achievement.  This strategy is consistent with the findings of a study of a nationally  representative sample of 300 school districts nationwide on targeting and  uses of federal education funds, which found that elementary schools  received 76 percent of Title I funds allocated to schools, considerably  more than their share of the nation’s low-income students (57 percent).
While most Title I funds are directed to elementary schools, two urban  districts that we visited provided funds to all schools in the district. In one  district, officials said that they began using Title I funds for high schools  only after state funding for high poverty schools became unavailable.
Nearly all of the schools in the 12 districts we visited used Title I funds for  schoolwide programs, rather than for targeted assistance programs.  Schoolwide programs offer flexibility by allowing schools to fund a  comprehensive schoolwide plan to upgrade all instruction in a high  poverty school without distinguishing between eligible and ineligible  children and also make it easier for schools to coordinate the use of Title I  and other funds. While schoolwide programs offer additional fiscal  flexibility when schools combine separate program resources into a single  accounting fund, the school districts we selected for review continued to  track the Title I dollars to individual eligible activities, even as they took  advantage of the flexibility to serve all children. In our selected districts,  the remaining 6 percent of schools with targeted assistance programs  tended to have lower poverty levels below or only slightly above the 40  percent threshold required for a schoolwide program.
The districts we visited used Title I funds in support of a variety of  initiatives. Funds were used to reduce teacher/student ratios and extend  instructional time. Our reviews of Title I grant applications and interviews  with district officials indicated that 10 districts used funds to pay for  additional teachers and teachers’ aides or assistants (paraprofessionals)  during the regular school day as a way to reduce class sizes in Title I  schoolwide programs, provide supplemental instruction to small groups of  Title I eligible students in targeted assistance schools, or provide  additional attention to students within a classroom, among other things.  Furthermore, eight districts used Title I funds to extend the time that  students spend in the classroom through after school and summer school  programs. Title I funds supported these initiatives in a variety of ways,  including paying for teachers’ time, instructional materials, and student  transportation to and from the program.
Of the 12 districts we visited, 10 used at least some portion of their Title I  funds to provide for the professional development of their teachers,  including districts that were required to spend not less than 10 percent of  Title I funds for this purpose as a result of being designated a district in  need of improvement. Professional development included traditional  classroom or workshop training as well as the use of math and literacy  coaches to help teachers implement training they received in the  classroom. Such coaches develop lesson plans and model the use of the  lesson plan. They observe teachers in the classroom and provide  feedback and coaching. Title I funds were used to purchase training  services, hire substitutes for teachers’ time spent in training, pay for  attendance at workshops or conferences, and pay the salaries and  benefits of math and literacy coaches.
Several selected districts used funds to purchase technology for the  classroom to assess student progress, to provide differentiated learning  experiences to students at various levels of achievement, or improve the  learning experience. Software purchases included both assessment  software as well as math and literacy software. For example, districts  purchased software that could produce reading materials that contained  similar content at different reading levels. Others purchased software that  assessed student reading levels and provided lessons that could be  adjusted based on reading levels. Several districts used Title I funds to  purchase hardware for classrooms including computers, printers, and  large screen displays. Districts also purchased tools such as interactive  whiteboards that allow teachers and students to project computer images  and interface with the technology at the board, voting devices that allow a  teacher to gauge student comprehension instantaneously, and document  cameras that allow teachers to project a photo of a scientific specimen or  share a document for a lesson.
section_title: Districts Generally Spent Most Title I Funds on Personnel, but Some Spent More on Purchased Services than Others Due to Title I Requirements
paragraphs: In the 12 districts we visited, which generally pursued personnel-intensive  strategies to improve academic outcomes, we found that salaries and  benefits, when combined, were the largest category of Title I  expenditures. In all but two districts, Providence and Orleans Parish,  salaries and benefits made up at least 70 percent of Title I expenditures,  (see fig. 3.) This finding is generally consistent with findings of the  Educational Research Service, which found that districts spend about 80  percent of all funds on salaries and benefits. For more detailed profiles  of Title I spending in the districts we visited, see appendix II.
In the 12 selected districts, we found that from 65 to 100 percent of full- time equivalents (FTE) whose salaries were paid for with Title I funds  were instructional staff, including teachers and paraprofessionals such as  teachers’ aides. Of the more than 1,300 FTEs whose salaries and  benefits were paid for with Title I funds in the 12 districts we visited, 82  percent were instructional personnel (see fig. 4). Education’s 2009 study  on targeting and uses of Title I and other federal funds found that, at the  individual school level, about 88 percent of personnel expenditures were  used to pay for teachers and paraprofessionals. The study also found  that the highest poverty schools spent a lower percentage of Title I funds  on instructional staff and a higher percentage on instructional support  staff, such as instructional coaches, librarians, or social workers, than the  lowest poverty schools did.
While a large portion of Title I FTEs were instructional personnel, the  types of instructional personnel varied by district, with some districts  paying only or primarily teachers and others paying primarily  paraprofessionals or teachers’ aides. On average, the 12 selected  districts used Title I funds to pay about 2.3 teachers for every teacher’s  aide. Education’s recent study found that Title I funds were increasingly  used to pay for teachers rather than paraprofessionals, such as teachers’  aides. From the 1997–1998 school year to the 2004–2005 school year,  measured in FTEs, the total number of Title I staff increased by 49  percent whereas the number of Title I teachers’ aides declined by 10  percent. The proportion of teachers’ aides among Title I school staff  declined from 47 to 35 percent, whereas the share of teachers rose from  45 to 55 percent during the same period.
In seven of the school districts we visited, Title I funds were also used to  pay for various instructional support personnel. Instructional support  personnel accounted for 10 percent of FTEs paid with Title I funds in the  12 districts we visited. These personnel included instructional coaches,  who coached teachers of Title I students; librarians to provide additional  literacy support for students in schoolwide programs that were not  meeting standards in reading; and counselors to support students who  were not meeting standards and their families by providing academic  support and information about academic requirements. Similarly,  Education’s study found that about 7 percent of Title I funds spent on  personnel at the school level were spent on instructional support staff.
Some personnel costs paid for with Title I funds were administrative  personnel, such as Title I directors or coordinators and administrative  assistants. The percentage of FTEs charged to Title I that were  administrative varied from 0 to 15 percent and accounted for 8 percent of  all Title I personnel in the school districts we visited. In a few school  districts we visited, administrative personnel also included personnel who  supported parental involvement activities. On the other hand, one district  opted not to charge Title I for any of its administrative costs. Larger  districts with greater levels of Title I funds and more schools in need of  improvement had more personnel dedicated to overseeing the use of Title  I funds. Education’s study found that 5 percent of Title I funds spent on  personnel at the school level were spent on administrative personnel.
Prior studies have also found that more than 80 percent of Title I funds  are spent or budgeted for instruction-related (versus administrative)  purposes. Although we were not able to compare the percentage of all  expenditures selected districts made in the instructional, instructional  support, and administration categories, Education’s study of Title I budget  and expenditures found that, on average, districts expended 10 percent of  Title I funds for administrative costs. It also found that more than 70  percent of Title I funds were spent on instruction, primarily for salaries  and benefits for instructors, but also including some instructional  materials and equipment. The same study found that less than 20 percent  of funds were used for instructional support, which includes professional  development, student support, in addition to instructional support  personnel. In our 2003 report on Title I spending by school districts, which  focused on selected districts using a common financial system, we  reported that the 6 selected districts we reviewed spent 0 to 13 percent of  Title I funds on administration and that each district spent at least 84  percent of Title I funds on activities related to instruction. In addition, we  identified several studies that had focused on the use of Title I funds for  administrative purposes and had generally found that districts spent 4 to  10 percent of Title I funds on administrative activities, but definitions of  administrative expenditures varied.
Title I requirements appeared to drive increased spending on purchased  services by larger districts. The larger, more urban school districts we  visited, which also had larger percentages of schools in need of  improvement, spent substantially more of their Title I funds on purchased  or contracted services than other districts, due to requirements that they  provide supplemental educational services and transportation for school  choice and spend a certain percentage on professional development. As  shown in figure 5, 8 of the 12 districts spent less than 5 percent on  services, while the other 4 urban districts spent 9 to 28 percent on  services. Purchased services accounted for 17 percent of all Title I  expenditures in the districts we visited. Three of the four districts that  spent 9 to 28 percent on services had 23 to 72 percent of their schools in  need of improvement. The eight remaining districts spent 0 to 5 percent of  their Title I funds on services, and had 0 to 11 percent of their schools  designated as in need of improvement. Service expenditures for the  larger, urban districts included payments to vendors chosen by parents to  provide supplemental educational services and consultants to assist  schools with activities such as curriculum development and redesign or to  provide professional development for teachers. The smaller districts with  few or no schools in need of improvement had service expenditures for  other types of services, such as license agreements for software.
Materials and supplies, including instructional materials, made up 0 to 20  percent of Title I expenditures in the school districts we visited and  averaged 9 percent for all districts we visited (see fig. 6). Material and  supply expenditures included supplementary reading kits; supplementary  work books; office supplies; and food and publicity for parent involvement  activities.
Seven of the districts we visited spent Title I funds on equipment. The  most spent in any district on this category of expenditures was just less  than 6 percent ($1.8 million) of their Title I funds. On average, this  category of expenditures accounted for 2 percent of all Title I  expenditures in the 12 school districts we visited. In those districts that  had expenditures in this category, the expenditures were generally for  computer and other electronic equipment. Some school districts classified  all electronic equipment as equipment, property, or capital purchases,  while other districts distinguished between types of equipment based on  dollar value or susceptibility to theft. For example, a laptop computer  costing $800 might be considered a supply, but a mobile docking module  costing $6,600 that allows a teacher to transport all necessary computer  equipment from room to room could be considered equipment or  property.
In addition to the expenditures directly attributable to the Title I program,  the 12 selected districts charged 0 to 12 percent of their Title I grant to  indirect administrative costs (see fig. 7). On average, about 4 percent of  Title I expenditures in the districts we visited were for indirect  administrative costs. Several small districts with small grants chose not to  charge an indirect cost rate to their Title I grants.
As part of the budgeting process, school districts submitted detailed  budgets to state educational agencies that included amounts set aside or  reserved from the Title I grant for specific uses by the district, including  district-managed services, such as professional development. Some of  these reservations are mandatory, and others are optional. Each state  had different categories of optional reservations or set-asides. Optional  set-asides included funds for administration or summer school.
The five selected districts we visited that reserved funds for supplemental  educational services and transportation set aside 4 to 18 percent of their  Title I funds for those purposes. While the districts we visited with schools  in need of improvement typically set aside larger amounts for  supplementary educational services, transportation to support school  choice was typically not a large budget item. In two cases, this was  because the district provided choice and transportation to all students  regardless of their schools’ performance, and paid for this with local  funds. In one district, the number of students opting to transfer to a  different school was relatively small.
Total mandatory and optional amounts set aside, including amounts for  district-managed services such as administration, professional  development, or supplemental educational services, accounted for 0.1 to  68 percent of Title I funds in the districts we visited. In a few of the larger  districts we visited, the total mandatory and optional amounts set aside  exceeded 50 percent of the Title I grant. Mandatory set-asides alone  amounted to as much as 28 percent in two districts. This is consistent  with the findings of Education’s study, which reported that from the 1997– 1998 school year to the 2004–2005 school year, the share of Title I funds  allocated to individual schools declined from 83 to 74 percent, while the  share used for district-managed services rose from 9 to 21 percent.
section_title: Various Title I Oversight Mechanisms Exist, But Are Not Designed to Yield Estimates of the Full Scope of Spending Noncompliance
paragraphs: Title I recipients are subject to various oversight mechanisms, which  provide some information on noncompliance with relevant spending  requirements, but are not designed to provide estimates of the prevalence  of noncompliance with requirements regarding use of funds. Table 1  summarizes the strengths and limitations of these oversight mechanisms  for this purpose, along with further information.
Education monitors how well states ensure school district compliance with  Title I requirements; however, this monitoring is not designed to capture  all district noncompliance with spending requirements. Education  generally monitors state implementation of the Title I program and  evaluates the extent to which states ensure district and school  compliance with a broad array of Title I requirements. As a part of its  assessment of state oversight of districts and schools, Education reviews  Title I compliance in two to three school districts in each state being  reviewed. Some Title I requirements reviewed by Education relate to how  Title I funds are spent. However, many other requirements deal with  nonfiscal programmatic issues. While ensuring compliance with Title I  spending requirements plays a part in Education’s monitoring strategy,  officials we spoke with cautioned that monitoring is not designed to  capture all instances of noncompliance. For instance, Education officials  do not conduct detailed reviews of districts’ Title I expenditures to identify  unallowable expenses, but rely primarily on other sources of oversight,  such as OIG audits, for this purpose. Education uses the results of its  monitoring efforts and others’ oversight efforts to design technical  assistance and training initiatives to assist states and school districts in  using their resources and flexibility appropriately. They also use results to  target future monitoring efforts based on risk. In some cases, Education  may place conditions on the further receipt of grant funds.
We reviewed Education’s 2009–2010 monitoring reports and other  relevant documents for findings related to how Title I funds were spent in  the 16 states and the District of Columbia that Education monitored that  year. Among findings Education identified as common, some dealt with  program compliance issues that were unrelated to how Title I funds were  spent, such as failing to ensure that districts notified parents about  supplemental educational services or school choice in a timely manner or  failing to post information about school choice on their Web sites. Other  findings were related to how Title I funds were spent, such as failure to  ensure that school districts allocated funds according to Title I  requirements, met various fiscal requirements, or used Title I funds to  support only paraprofessionals who had the required qualifications.  For  instance, sampled districts in several states did not distribute at least 95  percent of parental involvement funds to schools, as required. In other  cases, states failed to ensure that districts accurately calculated the  amount of Title I funds to reserve for services to participating private  school students. There were also cases in which states did not prevent  districts from using Title I funds to supplant state and local funds, which is  prohibited under Title I. For example, one Arkansas district required its  Title I schools to use Title I funds to pay for electricity and cleaning  supplies, while other schools used nonfederal general funds for these  items. Education required Arkansas to notify the district that this practice  was not allowable and submit evidence that the district subsequently  provided general funds to its Title I schools for these purposes. In  addition, Education identified instances where districts paid  paraprofessionals at Title I schools who did not meet Title I qualification  requirements, indicating that Title I funds may have been used to support  ineligible staff. For instance, 82 paraprofessionals in one Illinois school  district did not have the required qualifications. The state was required to  submit an action plan demonstrating how it would ensure that all  paraprofessionals would meet qualification requirements prior to the  beginning of the next school year.
subsections: section_title: OIG Audits
paragraphs: Education’s OIG also conducts audits of selected districts, using risk- based criteria including tips, past audit findings, and other known  weaknesses according to officials. OIG has conducted a number of audits  examining fiscal controls over funds from the Title I program and other  federal Education grants, and Education and OIG officials we spoke with  concurred that these audits tend to involve more in-depth financial  reviews than Education’s monitoring activities. OIG audits likely provide a  more comprehensive look at specific districts’ controls over Title I funds  than other oversight mechanisms; however, since OIG selects districts  due to known risk factors, the weaknesses it identifies are not necessarily  representative of those of Title I recipients at large.
Education’s OIG has identified some instances in which selected districts  spent Title I funds for unallowable purposes, did not adequately document  Title I expenditures, or used Title I funds to supplant state and local funds.  OIG has also found that inadequate policies and procedures, including  inadequate state monitoring of districts, are a common cause of such  violations. An OIG final management information report released in 2009  described the results of 41 final audit reports with findings related to  district fiscal controls over formula grant programs, most frequently   Title I. OIG identified unallowable personnel costs in 8 out of 16 audits  where such costs were reviewed. OIG also identified unallowable  nonpersonnel costs in 9 out of 20 audits where such costs were reviewed  because they were unnecessary, unreasonable, or not in keeping with  program purposes. As an example, OIG found in 2009 that the Dallas  Independent School District spent about $142,000 in Title I funds for  salaries and benefits of non-Title I employees and $17,000 for books  distributed to non-Title I schools. OIG recommended that the district  return these funds to Education. Completion of corrective action to  address this audit finding was pending as of May 2011. To address the  systemic issues that OIG identified, Education responded that it would  use the information provided in the management information report in the  development of its technical assistance plan and training curricula to  provide enhanced guidance to states and school districts.
In other cases, OIG found that districts had inadequate documentation  supporting Title I expenditures. For example, the school district of the City  of Detroit was cited in 2008 for failure to maintain required time and effort  certifications or personal activity reports for staff funded wholly or partially  through Title I funds totaling about $48 million. These activity reports  help ensure that the amount of Title I funds budgeted and claimed for  Title I personnel is accurate. OIG recommended that Education instruct  the state to require the district to return personnel expenditures that could  not be adequately documented, but the majority of this finding was  disputed by the state and district because, among other reasons, they  claimed that they provided credible after-the-fact documentation.  Completion of corrective action to address this audit finding was pending  as of May 2011. OIG identified other districts that used Title I funds to  supplant regular nonfederal funds. For instance, OIG found that a school  district in New York inappropriately reclassified about $68,000 in textbook  costs from general funds to Title I expenditures. The state and district  agreed with OIG’s recommendation to return these funds to Education  with interest.
section_title: Single Audits
paragraphs: Single audits, which were completed on nearly 9,000 school districts that  spent $11.8 billion in Title I funds in fiscal year 2009, are another  important Title I oversight mechanism, but the single audit requirement  does not cover school districts with less than $500,000 per year in federal  expenditures. Because of the large number of school districts that had  single audits, analyzing data on the audits can provide useful information  about the audited school districts’ compliance with requirements related  to Title I expenditures. However, available summary data do not provide  in-depth information about the nature and severity of identified  weaknesses.
Of the 8,720 school districts with Title I expenditures that submitted a  fiscal year 2009 single audit report to the Federal Audit Clearinghouse,  4,005 (46 percent) of the single audits reported that the Title I program  was a major program and were therefore tested by the auditors for  compliance with the requirements that could have a direct and material  effect on Title I. The auditor did not report any findings for 82 percent of  those audits. We analyzed data on the remaining 737 audits to determine  the type of compliance finding most commonly reported in the audit  reports. The allowable costs/cost principles category of compliance  requirement was cited most frequently. This finding occurred in about 301  (8 percent) of the 4,005 audits that examined Title I spending, or in about  40 percent of the 737 single audits that resulted in one or more findings  related to Title I. Costs charged to a project must generally be allowable  under the terms of the grant, actually associated with the project to which  they are charged, and reasonable. Therefore, the single audit findings  related to allowable costs/cost principles indicate that the audited district  did not comply with one or more of these criteria.
Of the 737 single audits with findings, the nature and severity of the  findings varied. For instance, in one single audit we reviewed, one finding  indicated the district failed to maintain time and effort documentation that  certified that the employee worked solely on Title I activities for an  employee that was paid out of Title I funds. Not maintaining appropriate  records could lead to Title I funds being used for costs not related to the  program or allowable under the terms of the grant. In other cases,  auditors reported that some school districts had used Title I funds in a  manner inconsistent with Title I requirements. For instance, auditors  reported that one district did not meet the requirement that 100 percent of  teachers of core academic subjects be highly qualified. The auditor found  that 5 of the 33 full-time instructional employees were not highly qualified,  and, therefore, the district was not in compliance with the requirement. In  such cases, states are responsible for issuing a written evaluation of the  audit finding that specifies the necessity for corrective action.
Auditors also test and report on internal controls over compliance for  major programs when performing single audits. We reviewed selected  single audits that reported material weaknesses in internal controls over  compliance related to Title I grants. For example, the auditor reported  that one school district failed to allocate Title I funds to each participating  school attendance area or school in rank order, based on the number of  low-income children residing in the area or attending the school, as  required by Title I. As a result of this material weakness, this district may  have funded lower-poverty schools at the expense of higher-poverty  schools. Of the 8,720 single audits, about 550 (6 percent) identified a  material weakness in internal control over compliance in at least one  federal program examined. However, because we relied on summary  data in our analysis, we could not determine the proportion of these  material weaknesses specifically related to Title I, as opposed to other  federal programs included in the audits.
section_title: Agency Comments
paragraphs: We provided a draft copy of this report to the Secretary of Education for  review and comment.  We received technical comments and incorporated  them where appropriate.
We are sending copies of this report to relevant congressional  committees, the Secretary of Education, and other interested parties. In  addition, this report will be available at no charge on GAO’s Web site at  http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-7215 or scottg@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff that made key contributions to this report  are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: To perform this work, we visited 12 school districts, 3 in each of 4  states—Louisiana, Ohio, Rhode Island, and Washington. We selected  states and school districts based on the characteristics described in the  mandate, including variation in size, student demographics, economic  conditions, and geographic locations. For instance, we first selected  states in different regions of the country. Then, we selected districts that  were urban, rural, and suburban, and had a mixture of poverty levels and  demographic diversity.
We reviewed Title I plans, audits, and budget and expenditure reports  that detailed the use of Title I funds by selected school districts. Districts  tended to use a consistent set of categories to describe what was  purchased, such as expenditures for salaries, benefits, supplies, and  services. However, selected districts did not consistently classify  expenditures in a way that allowed us to ascertain their purpose (for  example, instructional versus noninstructional). Therefore, while we were  able to ascertain what proportions of staff funded by Title I were in  administrative, instructional, and instructional support positions, we were  not able to directly compare all instructional versus noninstructional  expenditures.
We also assessed the reliability of the expenditure data provided to us by  the districts by (1) reviewing data for completeness and obvious  inconsistencies, (2) comparing them with other available expenditure data  to determine data consistency and reasonableness, (3) interviewing  district Title I and financial officials about expenditure data quality control  procedures, and (4) selecting transactions in varied expenditure  categories and reviewing documentation for those transactions to  determine whether the amount and expenditure category were accurately  recorded. We selected a nongeneralizable sample of transactions from  major categories, such as salaries, benefits, or services, to include  expenditures that appeared typical as well as expenditures that did not  appear to fit the category they were in. We determined that the amounts  and object categorization of expenditures were sufficiently reliable for the  purpose of describing the nature of district Title I expenditures and  making broad comparisons of districts’ expenditures. However, we did not  determine whether all costs were allowable or met all documentation  requirements. Due to the limited number of districts selected, our findings  from these districts cannot be generalized to school districts nationwide.
We conducted semi-structured interviews with state and local education  officials to better understand and discuss their states’ or districts’ use of  Title I funds. State and local education officials described their procedures  for ensuring funds were spent appropriately, but we did not test these  procedures.
We analyzed relevant federal laws, regulations, and guidance related to  spending of Title I and other Department of Education (Education) funds,  as well as accounting methods and protocols issued by the states.  Additionally, we conducted a literature search to determine what  researchers have found regarding how Title I funds have been spent. We  searched online databases, including ERIC, Dialog Databases, NTIS,  PolicyFile, ProQuest, and Statistical Insight using keyword “Title I” alone  and along with “spending,” “expenditures,” and “administrative” to identify  references, including studies, journal articles, and other material, that  focused on expenditure of Title I funds. We also searched for studies that  cited studies we had identified in our 2003 report. Overall, we identified  99 references in material published from 2001 to 2010. To further winnow  down the list of publications, we refined our search to studies that  examined Title I expenditures for multiple districts. We were left with only  one study that met our criteria. We also interviewed researchers of the  identified study and Education officials to determine if there were other  relevant studies. They did not identify any that described Title I  expenditures.
We reviewed findings from Education’s fiscal year 2009 monitoring  efforts, audits conducted by Education’s Office of the Inspector General  from fiscal years 2003 to 2009 that included a review of fiscal controls  over Title I funds, and data on school district single audits for fiscal year  2009 to determine whether Title I funds were used in accordance with  relevant requirements. Findings from each of these oversight tools  provide useful information about types of noncompliance seen among  local school districts, but it is important to note that they are not designed  to provide estimates of the extent or severity of such noncompliance.
School districts expending at least $500,000 in federal funds are required  to obtain a single audit and file audit results with the Federal Audit  Clearinghouse, which has been designated as the central collection point,  repository, and distribution center for single audit reports and maintains a  database of single audit results. To describe the results of single audits,  we analyzed selected data that were reported to the Federal Audit  Clearinghouse by school districts. We assessed the reliability of the  Federal Audit Clearinghouse data on single audits by (1) performing  electronic testing of required data elements, (2) reviewing existing  information about the data and system that produced them, and (3)  interviewing U.S. Census Bureau officials knowledgeable about the  database. While the Federal Audit Clearinghouse conducts testing to help  ensure that submitted data are internally consistent, and that all required  data fields are completed, and requires that both the submitter and the  independent auditor certify the report, it does not verify the accuracy of  reported data or that all entities required to report data do so. It is,  therefore, important to note that many school districts are not required to  obtain single audits, and are therefore not represented in this database.  Additionally, some entities required to report may not do so, and others  may report inaccurate data. Despite these limitations, we determined that  these data were sufficiently reliable for the purpose of describing Title I- related findings in submitted audits of school districts.
In order to isolate and analyze single audit data for school districts, we  used codes indicating the type of entity being audited as assigned by U.S.  Census Bureau staff reviewing single audit submissions. We included all  entries coded as pertaining to school districts with Title I expenditures in  our universe. Due to complexities in how school districts are organized,  as well as potential inconsistencies in how entities are coded by U.S.  Census Bureau staff, we manually reviewed entries with Title I  expenditures that were either missing an entity code or had an entity code  that did not clearly indicate that the audited entity was a school district.  We kept all entries in categories where we were able to determine that  the large majority of records corresponded with school districts, and  removed all entries in categories where this was not the case.
We conducted this performance audit from May 2010 through June 2011  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: School District Profiles
paragraphs: The following district profiles provide a snapshot of Title I expenditures in  the 12 school districts we reviewed for the 2008–2009 school year. We  obtained data from a variety of sources, including the districts  themselves, the states, and the National Center for Education Statistics.  We attempted to provide data that are comparable, but each state, and in  some cases, each district, had its own accounting system and its own  accountability systems. Districts did not account for the same types of  expenditures in the same ways. Similarly, each state has its own tests for  8th grade reading and mathematics. While it may be appropriate to  compare achievement results within a state, it would not be appropriate to  compare achievement results across states. In addition, we provide some  background and demographic information on each district, but each  district has unique needs and characteristics that may not be reflected in  the background information provided in this appendix.
subsections: section_title: District characteristics
paragraphs: Geographic category: town (fringe)
Total schools in district: 36 Number of schools receiving  Title I funds: 22 (61%)
Schoolwide programs: 21 (95%)  Targeted assistance  programs: 1 (5%)
subsections: section_title: Total number of students: 13,797
section_title: Percentage of students on free or reduced lunch: 66%
section_title: Student demographics
paragraphs: Desktop computers for reading program (2 vendors)
Title I staff (full-time equivalents)
subsections: section_title: African American: 44.5%
section_title: Asian/Pacific Islander: 3.5%
section_title: Native American: 0.2%
section_title: District report card
subsections: section_title: Graduation rate: 76.3%
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
Geographic category: suburb (small)
Total schools in district: 54 Number of schools receiving  Title I funds: 21 (39%)
section_title: Student demographics
paragraphs: Title I staff (full-time equivalents)
subsections: section_title: African American: 19.1%
paragraphs: Instructional support  (1 librarian/other)
section_title: District report card
subsections: section_title: Graduation rate: 77.2%
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: city (midsize)
Total schools in district: 19 Number of schools receiving  Title I funds: 19 (100%)
subsections: section_title: Total number of students: 10,109
section_title: Percentage of students on free or reduced lunch: 69%
section_title: Student demographics
paragraphs: Computers (skills practice)
subsections: section_title: African American: 76.5%
paragraphs: Title I staff (full-time equivalents)
section_title: Asian/Pacific Islander: 5.7%
paragraphs: Instructional support (1 librarian/other)
section_title: District report card
subsections: section_title: Graduation rate: 91.1%
paragraphs: Overall Title I budget (showing discretionary and required reservations)
Southeast Local School District (Wayne Co.)
Geographic category: rural (distant)
Total schools in district: 6 Number of schools receiving  Title I funds: 4 (67%)
section_title: Total number of students: 1,675
section_title: Percentage of students on free or reduced lunch: 35%
section_title: Student demographics
paragraphs: Title I staff (full-time equivalents)
subsections: section_title: Asian/Pacific Islander: 0.7%
section_title: District report card
subsections: section_title: Graduation rate: 97.2%
paragraphs: Overall Title I budget (showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: suburb (large)
Total schools in district: 10 Number of schools receiving  Title I funds: 6 (60%)
Schoolwide programs: 5 (83%)  Targeted assistance  programs: 1 (17%)
subsections: section_title: Percentage of students on free or reduced lunch: 45%
section_title: Student demographics
paragraphs: Title I staff (full-time equivalents)
subsections: section_title: African American: 9.5%
paragraphs: Instructional support (2 instructional coaches)
section_title: Native American: 0.4%
paragraphs: Instructional (25 teachers)
section_title: District report card
subsections: section_title: Graduation rate: 88.7%
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
Includes homeless, migrant, and limited English proficient students.
section_title: District characteristics
paragraphs: Geographic category: city (large)
Total schools in district: 112 Number of schools receiving  Title I funds: 108 (98%)
subsections: section_title: Total number of students: 52,358
paragraphs: Services delivered by top five vendors Supplemental educational services (4 vendors)
section_title: Percentage of students on free or reduced lunch: 81%
section_title: Student demographics
subsections: section_title: African American: 65.3%
paragraphs: Title I staff (full-time equivalents)
section_title: Native American: 0.3%
section_title: District report card
subsections: section_title: Graduation rate: 54.3%
paragraphs: Overall Title I budget (showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: rural (fringe)
Total schools in district: 5 Number of schools receiving  Title I funds: 1 (20%)
Schoolwide programs: none  Targeted assistance  programs: 1 (100%)
subsections: section_title: Number of Title I schools in need of improvement, corrective action, or restructuring: none
section_title: Total number of students: 1,713
section_title: Percentage of students on free or reduced lunch: 10%
paragraphs: Title I staff (full-time equivalents)
section_title: Student demographics
subsections: section_title: Asian/Pacific Islander: 1.0%
paragraphs: Instructional (2 teachers)
section_title: District report card
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
subsections: section_title: Graduation rate: 85%
section_title: District characteristics
paragraphs: Geographic category: city (small)
Total schools in district: 22 Number of schools receiving  Title I funds: 8 (36%)
Schoolwide programs: 4 (50%)  Targeted assistance  programs: 4 (50%)
subsections: section_title: Total number of students: 10,684
section_title: Percentage of students on free or reduced lunch: 28%
paragraphs: Computers and supplies (2 vendors)
section_title: Student demographics
paragraphs: Title I staff (full-time equivalents)
subsections: section_title: Asian/Pacific Islander: 6.9%
paragraphs: Administrative positions (<1 administrators)
section_title: District report card
subsections: section_title: Graduation rate: 79.5%
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: city (midsize)
Total schools in district: 47 Number of schools receiving  Title I funds: 47 (100%)
subsections: section_title: Total number of students: 23,710
section_title: Percentage of students on free or reduced lunch: 86%
paragraphs: Supplemental educational services (3 vendors)
section_title: Student demographics
subsections: section_title: African American: 22.0%
paragraphs: Title I staff (full-time equivalents)
section_title: Native American: 0.6%
section_title: District report card
subsections: section_title: Graduation rate: 66.5%
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: suburb (large)
Number of schools receiving  Title I funds: 12 (35%)
Schoolwide programs: 5 (42%)  Targeted assistance  programs: 7 (58%)
subsections: section_title: Total number of students: 20,911
section_title: Percentage of students on free or reduced lunch: 24%
section_title: Student demographics
subsections: section_title: Asian/Pacific Islander: 7.0%
paragraphs: Title I staff (full-time equivalents)
section_title: Latino: 6.8%
section_title: District report card
subsections: section_title: Graduation rate: 70.6%
paragraphs: Overall Title I budget (showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: suburb (midsize)
Total schools in district: 19 Number of schools receiving  Title I funds: 5 (26%)
Schoolwide programs: 3 (60%)  Targeted assistance  programs: 2 (40%)
subsections: section_title: Total number of students: 13,924
section_title: Percentage of students on free or reduced lunch: 33%
section_title: Student demographics
subsections: section_title: Asian/Pacific Islander: 13.1%
paragraphs: Title I staff (full-time equivalents)
Administrative positions (<1 clerical)
section_title: District report card
subsections: section_title: Graduation rate: 79.3%
paragraphs: Overall Title I budget (showing discretionary and required reservations)
section_title: District characteristics
paragraphs: Geographic category: city (large)
Total schools in district: 99 Number of schools receiving  Title I funds: 33 (33%)
Schoolwide programs: 31 (94%)  Targeted assistance  programs: 2 (6%)
subsections: section_title: Total number of students: 45,968
section_title: Percentage of students on free or reduced lunch: 39%
paragraphs: Supplemental educational services (4 vendors)
section_title: Student demographics
paragraphs: Title I staff (full-time equivalents)
subsections: section_title: African American: 21.1%
section_title: Native American: 1.9%
section_title: District report card
subsections: section_title: Graduation rate: 70.1%
paragraphs: Overall Title I budget (Showing discretionary and required reservations)
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: The following staff members made key contributions to this report:  Cornelia Ashby, Director; Betty Ward-Zukerman, Assistant Director; Lara  Laufer, Analyst-in-Charge; Matthew Alemu; Phyllis Anderson; James  Bennett; Jessica Botsford; William Colvin; Susannah Compton; Ranya  Elias; Catherine Hurley; Kimberly McGatlin; Sarah McGrath; Jean  McSween; Maria Morton; and Ellen Phelps Ranen.
section_title: Related GAO Products
paragraphs: Recovery Act: Opportunities to Improve Management and Strengthen  Accountability over States’ and Localities’ Uses of Funds. GAO-10-999.  Washington, D.C.: September 20, 2010.
Recovery Act: States Could Provide More Information on Education  Programs to Enhance the Public’s Understanding of Fund Use.  GAO-10-807. Washington, D.C.: July 30, 2010.
No Child Left Behind Act: Education Actions May Help Improve  Implementation and Evaluation of Supplemental Educational Services.  GAO-07-738T. Washington, D.C.: April 8, 2007.
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: Improvements Needed in Education’s Process  for Tracking States’ Implementation of Key Provisions. GAO-04-734.  Washington, D.C.: September 30, 2004.
Title I: Although Definitions of Administrative Expenditures Vary, Almost  All School Districts Studied Spent Less Than 10 Percent on  Administration. GAO-03-386. Washington, D.C.: April 7, 2003.
Disadvantaged Students: Fiscal Oversight of Title I Could Be Improved.  GAO-03-377. Washington, D.C.: February 28, 2003.