Title I: Education Needs to Monitor States' Scoring of Assessments
Published: 2002-04-01T00:00:00

Fast Facts:

Highlights:
section_title: What GAO Found
paragraphs: Concerned that Title I of the Elementary and Secondary Education Act (ESEA) had not significantly improving the educational achievements of children at risk, Congress mandated major changes in 1994. States were required to adopt or develop challenging curriculum content and performance standards, assessments aligned with content standards, and accountability systems to measure progress in raising student achievement. In return, states were given greater flexibility in the use of Title I and other federal funds. The No Child Left Behind Act of 2001 augments the assessment and accountability requirements that states must implement and increases the stakes for schools that fail to make adequate progress. The 1994 legislation required states to comply with the requirements by January 2001 but allowed the Department of Education to extend that deadline. Education has granted waivers to 30 states to give them more time to meet all requirements. If states fail to meet the extended timeliness, they are subject to the withholding of some Title I administrative funds. Title I directors indicated that a state's ability to meet the 1994 requirements improved when both state leaders and state agency staff made compliance a priority and coordinated with one another. Most directors said that inadequate funding hindered compliance. Many of the states reported taking action to ensure that Title I assessments were scored accurately, that any exemptions for students with limited English proficiency were justified, and students with disabilities were receiving appropriate testing accommodations. As of March 2002, 17 states had complied with the 1994 assessment requirements; 35 states had not.

section_title: Letter
paragraphs: Title I of the Elementary and Secondary Education Act (ESEA), the largest  source of federal funding for education, will provide states with $10.3  billion in fiscal year 2002 to improve the educational achievement of  children at risk. Title I serves about 12.5 million children in all 50 states,  the District of Columbia, and Puerto Rico. In response to concerns that  Title I funding was not significantly improving the educational  achievement of at-risk students, in 1994 Congress mandated major  changes to Title I, including changes to how states measure student  performance. As part of the 1994 ESEA reauthorization, states were  required to adopt or develop challenging curriculum content and  performance standards, assessments aligned with content standards, and  accountability systems to assess schools’ and districts’ progress in raising  student achievement. In exchange for meeting these requirements, states  were given increased flexibility in the use of Title I and other federal  funds. New legislation that reauthorizes ESEA – The No Child Left Behind  Act of 2001 – has since been passed. The new legislation does not reduce  or eliminate any of the 1994 requirements. Instead, it augments the  assessment and accountability requirements that states must implement  and increases the stakes for schools that fail to make adequate progress.  This report provides a snapshot of how close states had come to meeting  the 1994 requirements when the 2001 requirements were signed into law.
In light of the increasingly important role played by the required  assessment and accountability measures, we have collaborated with other  audit organizations to review aspects of how states are implementing  these measures and ensuring that data used to assess schools’ progress in  raising student achievement are complete and accurate. This report is one  of several on this topic to be issued separately by the various collaborating  audit organizations, which include the U.S. Department of Education’s  Office of the Inspector General (OIG), the Texas State Auditor’s Office, the  Pennsylvania State Auditor’s Office, and the City of Philadelphia  Controller’s Office. In this report, we provide GAO’s findings regarding (1)  the status of states’ compliance with key 1994 Title I requirements, (2)  factors that have helped or hindered states in meeting the requirements,  and (3) the actions states are taking to ensure that Title I assessments are  scored accurately, exemptions for students with limited English  proficiency are justified and students with disabilities are appropriately  accommodated during testing according to Title I regulations.
To assess states’ progress in implementing important assessment and  accountability requirements introduced by Title I, we (1) interviewed  Education officials and reviewed Education memoranda and reports  regarding states’ compliance with the 1994 requirements, (2) surveyed  State Education Agency (SEA) Title I directors regarding the challenges  faced by states with and without approved assessment systems, and (3)  conducted telephone interviews with Title I and other state officials in  states that are in compliance with Title I to develop detailed information  on strategies for overcoming key barriers. We also conducted similar  interviews in some states still working to attain compliance with the 1994  requirements to determine factors that have hindered their progress. We  sent surveys to the 50 states, the District of Columbia, and Puerto Rico and  obtained 50 responses (96 percent). We conducted our work in  accordance with generally accepted government auditing standards  between June 2001 and March 2002. (See app. I for specifics on our scope  and methodology.)
subsections: section_title: Background
paragraphs: The original Title I legislation was passed in 1965, but the 1994  reauthorization of ESEA mandated fundamental changes to the Title I  program. One of the key changes involved the development of state  systems of standards and assessments to ensure that students served by  Title I were held to the same standards of achievement as all other  children. Prior to 1994, some states had already implemented assessment  systems, but these tended to be norm-referenced—students’ performance  was judged in relation to the performance of other students. The 1994  legislation required assessments that were criterion-based—students’  performance was to be judged against an objective standard. Every state  applying for Title I funds since 1994 agreed to implement the changes  described in the 1994 law and to bring its assessment systems into  compliance. States are also required to develop a definition of adequate  yearly progress based on the assessments to hold schools accountable for  educational progress. To help states that could not meet the proposed  2001 timeline, Education had authority to grant timeline waivers and  compliance agreements to states under certain conditions. In its 2001  ESEA reauthorization, Congress increased testing requirements for states  as well as the consequences for not improving test scores in schools and  did not eliminate any of the requirements of the 1994 legislation. As shown  in table 1, the 1994 and 2001 legislative requirements for assessment and  accountability concern developing standards for content and performance;  measuring improvement; implementing and administering assessments,  including assessing students with limited English proficiency; reporting  assessment data; and applying consequences for not meeting performance  goals.
Almost all states employ contractors to perform services to help them  meet these requirements. Among states that we interviewed, contractors  included private companies, universities, nonprofit organizations, and  individual consultants. These entities were hired to provide services that  may include assessment development, administration, scoring, analysis,  and reporting of results. Some of these entities can provide combinations  of services to states, such as test development and test scoring. States are  responsible for monitoring contractor performance.
Congress allowed states to phase in the 1994 ESEA requirements over  time, giving states until the beginning of the 2000-01 school year to fully  implement them with the possibility of limited extensions. Education is  responsible for determining whether or not a state is in compliance with  these requirements and is authorized under ESEA, to give states more time  to implement the requirements as long as states are making adequate  progress toward this goal. States submit evidence to Education showing  that their system for assessing students and holding schools accountable  meets Title I requirements. Education has contracted with individuals with  expertise in assessments and Title I to review this evidence. The experts  provide Education with a report on the status of each state regarding the  degree to which a state’s system for assessing students meets the  requirements and deserves approval. Using this and other information, the  Secretary sends each state a decision letter that summarizes the experts’  review and communicates whether a state is in full compliance, in need of  a timeline waiver, or more seriously, a compliance agreement. Education  may withhold funds if a state does not meet the terms of its compliance  agreement. The 1994 legislation was not specific in the amount of  administrative funds that could be withheld from states failing to meet  negotiated timelines, but the 2001 legislation states that Education must  withhold 25 percent of state administrative funds until the state meets the  1994 requirements including the terms of any timeline waivers or  compliance agreements.
In June 2000, we issued a report on states’ efforts to ensure compliance  with key Title I requirements. At that time, we expressed concern about  the number of states that were not positioned to meet the deadlines in the  1994 law. To increase compliance, we made two recommendations. We  recommended that the Department of Education should (1) facilitate  among states the exchange of information and best practices regarding the  implementation of Title I requirements and (2) implement additional  measures to improve research on the effectiveness of different services  provided through Title I to improve student outcomes. Education  continues to work on the implementation of these recommendations. In  addition, we said that Congress should consider requiring that states’  definitions of adequate yearly progress apply to disadvantaged children, as  well as to the overall student population. The 2001 legislation does require  that states apply adequate yearly progress requirements and report on the  results by subgroups, including students in poverty, with disabilities, and  with limited English proficiency.
section_title: Most States Are Not in Compliance with the 1994 Title I Accountability and Assessment Requirements
paragraphs: As of March 2002, 17 states were in compliance with the 1994 Title I  assessment requirements; however, 35 were not. (See table 2.)  Departmental approval of timeline waivers to give states more time to  reach compliance has been granted for 30 states. Education has asked five  states to enter into compliance agreements that will establish the final  date by which they must be in compliance before losing Title I funding.  Among other requirements, states that are not in compliance have most  frequently not met the specific requirements to assess all students and  break out assessment data by subcategories of students. The 2001  legislation requires states to implement additional assessments through  2008, thus substantially augmenting current assessment requirements.  Education has published a notice of proposed negotiated rulemaking in  the Federal Register and has solicited comments from outside parties in  preparation for establishing state compliance standards for the 2001  legislation.
When Education determines that a state is not in compliance with the 1994  Title I assessment requirements, it may grant the state a timeline waiver  for meeting those requirements. A waiver may not exceed 3 years.  Education officials indicate that the agency grants waivers to states that  have a history of success in implementing significant portions of their  assessment systems, have a clear plan with a definite timeline for  complying with the Title I requirements, and have the capacity to carry out  the plan and thus meet those requirements. When a state requests a  waiver, it must provide Education with a plan that includes a timeline for  addressing deficiencies in the state’s assessment system. Education  reviews this information to decide whether the waiver should be granted  and its duration. So far, Education has granted timeline waivers to 30  states. (see table 3.)
A compliance agreement is deemed necessary when Education determines  that a state will not complete the implementation of its assessment system  in a timely manner. According to Education officials, a state requiring a  compliance agreement generally does not have a history of successful  implementation, has not met a significant number of Title I requirements,  and does not have a plan in place for meeting those requirements.  Education recommends a compliance agreement so that a state may  continue to receive Title I funds. Before Education may enter into a  compliance agreement, a public hearing must be held in which the state  has the burden of persuading Education that full compliance with the Title  I requirements is not feasible until a future date. The state must be able to  attain compliance within 3 years of the signing of the compliance  agreement by the state and Education. The state then negotiates the terms  of the agreement with Education. Education’s written findings and the  terms of the compliance agreement are published in the Federal Register.  A state that enters into a compliance agreement to address requirements  of the 1994 Title I law and subsequently fails to meet the requirements of  the agreement can be subject to loss of some state Title I administrative  funds. Education is presently working on five compliance agreements  (Alabama, Idaho, Montana, West Virginia, and the District of Columbia)  and has held public hearings for each.
The 2001 reauthorization of ESEA was signed into law on January 8, 2002.  The act provides states not in compliance with the 1994 Title I  requirements at the time of the signing of the 2001 legislation with a 90-day  period that started on January 8, 2002 to negotiate changes in the dates by  which they must be in compliance with the 1994 requirements. After the  conclusion of this 90-day period, the legislation prohibits further  extensions for compliance with the 1994 requirements. States failing to  meet these negotiated timelines will be subject to loss of some of their  Title I administrative funds. According to senior Education officials, this  loss could be significant to states, as many use federal program  administrative funds to pay the salaries of state department of education  staff.
A review of documents from Education shows that noncompliant states  have most commonly not met two Title I requirements—assessing all  students and breaking out assessment data by subcategories of students.  Title I does not permit states to exempt any student subgroup from their  assessments and Education’s guidance states that individual exemptions  may be permitted by the states in extraordinary circumstances.  Nonetheless, many states allow substantial exemptions for students with  disabilities and limited English proficiency. Several states reported that  they have only recently amended laws that prohibited testing of some  students with limited English proficiency. Title I also requires states, local  districts, and schools to report the performance of students overall and in  a variety of subcategories. These categories are gender, race, ethnicity,  English proficiency status, migrant status, disability status, and economic  disadvantage. Many states disaggregated data for some but not all of these  categories. Documents from Education show that data for the disabled,  migrant, and economically disadvantaged subcategories are the most  common subgroups excluded from state, district, and school reports. In  addition, many states lag in other areas, such as aligning assessments to  state content standards.
To achieve compliance with the 2001 legislation, states will need to add  new standards and increase assessment efforts, as detailed in table 1. In  responding to our survey, 48 states reported that they have developed  content standards in science, but only 16 reported having annual  assessments for math and 18 reported annual assessments for reading in  all grades 3 through 8. In addition, states will not have the 2 to 3 year  timeline waivers available to them as they had when they worked to meet  the 1994 requirements. New 2001 requirements listed in table 1 have  deadlines that vary according to the requirement, and the Secretary of  Education can give states 1 additional year from those deadlines to meet  the new requirements, but only in case of a “natural disaster or a  precipitous and unforeseen decline in the financial resources of the state.”  Since the majority of states have not met the requirements of the 1994 law,  it appears that many states may not be well-situated as they work to meet  the schedule for implementing new requirements that build upon the 1994  requirements.
section_title: States Cited Support and Coordination as Furthering Compliance
paragraphs: States successful in meeting key Title I requirements attributed their  success primarily to four factors. These factors were (1) the efforts of  state leaders to make Title I compliance a priority; (2) coordination  between staff of different agencies and levels of government; (3) obtaining  buy-in from local administrators, educators, and parents; and (4) the  availability of state-level expertise. Survey respondents identified  inadequate funding as an obstacle to compliance. The state Title I officials  we interviewed said that their states’ commitment of resources to norm- referenced assessments that conflicted with the 1994 Title I requirements  contributed to this obstacle.
Almost 80 percent of the respondents identified state leaders’ efforts as a  factor that facilitated their meeting the 1994 Title I requirements. In every  state that had attained compliance with the Title I requirements, the  officials that we interviewed said that the governor, legislators, or business  leaders made compliance with the Title I requirements a high-priority.  States described the development of high-level committees, new state  legislation, and other measures to raise the visibility and priority of this  issue. For example, one governor spearheaded a plan that used  commissions to develop content standards and assessments aligned with  those standards. Some state officials we interviewed reported that efforts  by state department of education leaders resulted in major organizational  changes in the state education department. For example, according to one  Title I Director, the state changed the organizational structure and  reporting relationships of state offices to organize them by function rather  than by funding streams and to enhance coordination; according to  another Title I Director, state leaders who did not support changes  necessary to achieve compliance with Title I were replaced with staff that  did support the changes.
In responding to our survey, over 80 percent of the Title I officials  identified the ability of staff or agencies to coordinate their efforts with  one another as a factor that helped them meet requirements. In our  interviews, state officials cited the necessity of coordination between state  and local staff working in the areas of assessment, instruction, and  procurement. Two of the states we interviewed specifically noted that  when the assessment office shared a physical location with the Title I  office, coordination was easier and the ability to achieve compliance with  Title I was enhanced.
Title I and other officials we interviewed in those states that had met the  1994 Title I assessment requirements noted that they had made great  efforts to obtain buy-in from other state officials, local administrators,  educators, and the public. They said that efforts to ensure buy-in paved the  way for changes meant to ensure compliance with the assessment and  accountability requirements of the1994 legislation. Several officials we  interviewed reported holding public meetings and focus groups to obtain  input from parents, teachers and local administrators regarding how the  state should implement Title I requirements. They also reported  conducting public relations campaigns to educate the public about the  importance of complying with Title I requirements for standards-based  assessment. One state, for example, conducted 6 years of focus groups and  hearings and conducts a conference annually to allow local education  officials to gain advice from experts regarding any concerns or problems  they are having in implementing Title I requirements.
In responding to our survey, over 80 percent of state Title I directors  identified the availability of state level expertise as a factor that facilitated  their efforts to meet Title I requirements. State officials we interviewed  reported that training for teachers and district personnel was often needed  to apply new content standards in the classroom and to administer  assessments correctly. Two states, for example, used regional centers to  educate local staff on assessments and standards.
Fifty percent of survey respondents identified inadequate funding as an  obstacle in moving toward compliance and noncompliant states cited this  problem more often than compliant ones. In our interviews, Title I and  assessment officials from noncompliant states reported that progress  toward compliance with Title I requirements was stalled because of  investments they had made in assessment systems that predated and  conflicted with the requirements of the 1994 Title I reauthorization.  Respondents said that they had made substantial investments of time and  money in systems of assessment that often relied upon norm-referenced  assessments and did not meet the 1994 requirement for criterion-based  tests. They noted that it took their states several years to change from the  old system of assessment to one meeting the requirements specified by the  1994 reauthorizing legislation. According to the officials we interviewed,  building support to start again on another system and obtaining the  funding made it more difficult to make the necessary changes in a timely  manner. In addition, one survey respondent from a very small state noted  that due to the state’s size it has a small number of staff and does not have  the technical expertise needed to develop a new system, thus hampering  the state’s ability to meet the requirements.
section_title: Most States are Taking Some Action To Ensure Accurate Scoring, Justification for Exemptions, and Appropriate Accommodations, but Actions are Limited
paragraphs: Most states are taking some action to ensure that Title I assessments are  scored accurately, that any exemptions for students with limited English  proficiency are justified, and that students are receiving appropriate  accommodations when these are needed to gather an accurate assessment  of their abilities. Most states hire a contractor to score Title I assessments  and about two-thirds of these states monitored the scoring performed by  the contractor. Some states that hire contractors have found errors in the  scoring the contractors did, and in some cases, these errors have had  serious negative consequences for schools and students. Most states  reported taking some actions to ensure that students with limited English  proficiency and disabilities received appropriate accommodations during  testing. Education is redesigning its current compliance and monitoring  program to better monitor states’ implementation of Title I.
subsections: section_title: Problems Found in Contractor Scoring
paragraphs: According to our survey results, most states (44) hire a contractor for test  scoring, but 16 of these states identified no monitoring mechanism to  ensure the accuracy of their contractor’s scoring and reporting. Among  those states that did report one or more monitoring mechanisms, 15  reported that they monitored the contractor’s scoring by comparing a  sample of original student test results to the contractor’s results. A few  states also reported, in interviews with us, that they compared their most  recent test scores with those from previous years and looked for  significant variations that suggested potential errors in scoring. However,  in our interviews, some assessment officials indicated that they use this  type of monitoring rather informally.
The problems identified in assessment scoring suggest that these  approaches do not always provide adequate assurance of complete and  accurate results. Indeed, several of the states that use contractors to score  tests reported that they have had problems with errors in scoring whether  or not they had monitoring measures in place. In some cases, contractors  marked correct answers as incorrect and in other cases the contractors  calculated the scores incorrectly. The errors were discovered by a number  of individuals, including local district officials, parents, and state agency  staff. These scoring errors had impacts on students, families, and school  and district resources. Based on erroneous scores calculated by a  contractor, one state sent thousands of children to summer school in the  mistaken belief that their performance was poor enough to meet the  criterion for summer intervention. In addition to disrupting families’  summer plans and potentially preventing student promotions, this may  have drawn resources away from other necessary activities. In another  case, based on a contractor’s erroneous scoring, a state incorrectly  identified several schools as “in need of improvement,” a designation that  carries with it both bad publicity and extra expense, for example, districts  may have to fund the needed improvements.
A few state officials that we interviewed told us that they have begun  instituting processes to check the accuracy of scoring. For example, three  states said that they had hired individuals who were experts in test scoring  or they hired other third parties to conduct independent audits. States that  were in compliance with 1994 Title I assessment requirements generally  had more complete monitoring systems, including measures such as  technical advisory committees to review results, conduct site visits, and  follow a sample of tests through the scoring and reporting process. In  contrast, several states indicated they are still relying on contractor self- monitoring to ensure accurate scoring.
Although Education is obligated under the Federal Managers’ Financial  Integrity Act of 1982 and the Single Audit Act to ensure that states that  receive federal funds comply with statutory and regulatory requirements  to monitor contractors, it currently takes limited action regarding states’  monitoring of assessment contractors. Education’s inspector general has  reported deficiencies in an important vehicle for such oversight - - Education’s compliance reviews of state programs. The compliance  reviews are conducted on a 4-year cycle and include an on-site visit that  lasts 1 week. Specifically, the OIG cited insufficient time to conduct the  reviews, lack of knowledge among Education staff about areas they were  reviewing, and a lack of consistency in how the reviews were conducted.  Senior Education officials told us the department is redesigning the  current compliance and monitoring program used for its on-site visits to  better focus on outcomes and accountability in Title I and that it is  addressing the OIG’s recommendations. However, a senior Education  official who is working on the redesign of the compliance reviews told us  that the current draft plans did not include specific checks on state  monitoring of assessment scoring. Confidence in the accuracy of test  scoring is critical to acceptance of the test results’ use in assessing school  performance.
section_title: Some Actions Taken To Ensure Exemptions Justified and Accommodations Appropriate
paragraphs: According to our surveys and interviews, 33 states have taken at least  minimal actions to ensure any exemptions for students with limited  English proficiency are justified and 41 states take actions to ensure  accommodations for students with disabilities are appropriate. Most  states reported that they had developed standards for districts to follow in  accommodating these students so that assessments could yield accurate  measures of their performance. However, states reported few actions that  would ensure that these guidelines were being followed. For example, 17  states reported that they compare the number of students with limited  English proficiency tested within a given year against the number for the  previous year. They used this comparison as their means of verifying that  the numbers of students receiving exemptions were reasonable. As the  pool of students in a particular school can change substantially from year  to year, this comparison has obvious limitations. Moreover, students’  status, for example with respect to English proficiency, can change from  year to year. Similarly, 37 states reported using an annual comparison of  the number of students with disabilities being tested as a check for  appropriate accommodations. However, it is not evident how such  comparisons would allow states to ascertain the appropriateness of the  accommodations.
Survey results and interviews did indicate that more states are taking  actions to monitor accommodations for students with disabilities than for  students with limited English proficiency. For example, while 25 states  reported that they had standards for accommodating students with limited  English proficiency, 36 had standards for accommodating students with  disabilities. The state officials that we interviewed told us that this was  because districts built upon steps they had taken under the Individuals  with Disabilities Education Act (IDEA) to document the accommodations  needed by students with disabilities. In general, states said that the  districts have more experience and technical expertise for assessing and  supporting students with disabilities because of working under IDEA for  many years. In contrast, some states lacked consistent standards for  identifying students with limited English proficiency and more states were  still working to develop alternate assessments or accommodations for  these students. Augmenting the 1994 requirements, the new 2001  legislation requires that states annually assess the language proficiency of  students with limited English proficiency by the 2002-03 school year.  States do conduct cyclical monitoring of the implementation of all their  programs that might be used to assess the appropriateness of district  policy and practice with regard to testing accommodations. However, in a  recent review,we found that states varied dramatically in the frequency  of their on-site visits. The average time between visits to districts ranged  from 2 years or less (6 states) to more than 7 years (17 states).
section_title: Conclusions
paragraphs: This snapshot of the states’ status with respect to the 1994 Title I  requirements suggests that many states may not be well-positioned to  meet the requirements added in 2001. Only 17 states were in compliance  with the assessment requirements of the 1994 law in March of 2002;  therefore, the majority of states will still be working on meeting the 1994  requirements as they begin work toward meeting the new requirements.
In addition, despite the enhanced emphasis on assessment results, states  still appear to be struggling with ensuring that assessment data are  complete and correct. The 1994 and 2001 ESEA reauthorizations raised  student assessments to a new level of importance. The assessments are  intended to help ensure that all students, including those who have  disabilities and those who have limited English proficiency are meeting  challenging standards. In addition, assessment results are a key part of the  mechanism for holding both schools and states accountable for improving  educational performance. Thus, ensuring the completeness and accuracy  of assessment data is central to measuring students’ progress and ensuring  accountability. Without adequate oversight of assessment scoring, efforts  to identify and improve low-performing schools could be hindered by lack  of confidence in assessment results or uncertainty regarding whether  particular schools have been appropriately identified for improvement.  Education’s current monitoring does not include specific oversight of how  states ensure the quality of scoring contractors’ work, but Education’s  revision of its monitoring process provides the agency with an opportunity  to help states ensure that scoring done by contractors is accurate.
section_title: Recommendation
paragraphs: To enhance confidence in state assessment results, we recommend that  when the Department of Education monitors state compliance with  federal programs, it include checks for contractor monitoring related to  Title I, Part A. Specifically, Education should include in its new  compliance reviews a check on the controls states have in place to ensure  proper test scoring and the effective implementation of these controls by  states.
section_title: Agency Comments
paragraphs: We provided Education with a draft of this report for review. The  Department’s official comments are printed in appendix II. In its  comments, Education agreed with our recommendation. Education also  provided us with technical comments that we incorporated in the report as  appropriate.
We are sending copies of this report to appropriate congressional  committees and other interested parties. If you have any questions about  this report, please contact me on (202) 512-7215 or Betty Ward-Zukerman  on (202) 512-2732. Key contributors to this report were Mary Roy, G. Paul  Chapman II, Laura Pan Luo, Corinna Nicolaou, and Patrick DiBattista.
section_title: Appendix I: Scope and Methodology
paragraphs: We conducted this review in conjunction with our partners in the  Domestic Working Group. The Domestic Working Group’s objective is to  allow officials in the federal, state, and local governmental audit  communities to interact on a personal and informal basis on various topics  of mutual concern. The group consists of 18 (6 federal, 6 state, and 6 local)  top officials and is intended to complement the work of the  intergovernmental audit forums and other professional associations.
For this review, the Texas State Auditor's Office conducted a detailed  assessment of data quality at the state and local levels in Texas, while the  Department of Education's Office of Inspector General did so at the state  and local levels in California and conducted additional work on control  processes at the Department of Education.  In Pennsylvania, the  Pennsylvania Department of Auditor General conducted work at the state  level and the Philadelphia Controller's Office pursued the same goal within  the city of Philadelphia.
To complement these efforts, GAO surveyed all states and conducted  detailed interviews with several regarding their experiences in  implementing major provisions of Title I.  Specifically, we reviewed three  key questions:  (1) the status of states’ compliance with key 1994 Title I  assessment requirements; (2) factors that have hindered or helped states  move toward meeting the requirements; and (3) the actions states are  taking to ensure that Title I assessments are scored accurately,  exemptions for students with limited English proficiency are justified, and  students with disabilities are accommodated during testing according to  federal regulations.
We obtained information on the first objective from the Department of  Education. We met with Education officials and obtained updated listings  of compliance throughout the audit. In addition, we reviewed state  decision letters, peer reviews of state assessment systems, and reports  completed or commissioned by Education’s Planning and Evaluation  Service.
To address the second and third questions, we used both a state survey of  Title I directors and detailed interviews with state Title I officials and  other state officials who played a key role in Title I compliance - often  assessment officials and sometimes Special Education, program  evaluation, and information technology officials. We sent the survey to all  50 state directors and to the District of Columbia and Puerto Rico. We  received 50 completed surveys. We followed up with 19 states to clarify  and expand on questions in the interview related to contracting for the  scoring of tests. We interviewed officials from 5 states that had assessment  systems approved by Education and 3 states that were still trying to attain  compliance. We also interviewed two expert reviewers, Education officials  with responsibility for Title I and program review, three officials at  Education’s regional assistance centers, and officials at the Council of  Chief of State School Officers. We coordinated our work and findings with  our audit partners, who provided us with information relative to their  states’ activities.