No Child Left Behind Act: Education Actions Could Improve the Targeting of School Improvement Funds to Schools Most in Need of Assistance
Published: 2008-02-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Under the No Child Left Behind Act (NCLBA), the federal government provides millions of dollars annually to assist schools that have not met state academic goals. In the 2006-2007 school year, over 10,000 such schools were identified for improvement. NCLBA requires states to set aside 4 percent of their Title I funds to pay for school improvement efforts. GAO was asked to determine (1) the extent to which states have set aside these funds and used other resources for school improvement, (2) which schools received improvement funds and the extent funds are tracked, (3) the activities states and schools have undertaken and how activities are assessed, and (4) how Education supports states' improvement efforts. GAO administered a survey to state education officials and received a 100 percent response rate, matched survey data to an Education database, and conducted site visits to five states.
section_title: What GAO Found
paragraphs: A statutory requirement--known as a hold-harmless provision--has limited some states' ability to target the full 4 percent of Title I funds for school improvement to low-performing schools. However, many states have used other federal and state funds for this purpose. While the hold-harmless provision is designed to protect school districts from reductions in their Title I funding, it has also kept 22 states from setting aside the full portion of Title I school improvement funds since 2002 because they did not have enough funds to do so after satisfying the hold-harmless provision. To address this, Education has proposed repealing the hold-harmless provision. However, it is not known how removing this provision would affect districts protected by it. In addition to Title I funds, 38 states have dedicated other federal funds, and 17 have contributed state funds for school improvement. Though states generally target improvement funds to the most persistently underperforming schools, some states did not fulfill key NCLBA requirements. Specifically, 4 states did not follow all requirements to ensure that schools most in need of assistance received funds. Although Education monitors how states allocate improvement funds, it did not identify this issue. Also, 4 states were unable to provide a complete list of schools that received improvement funds, as required by law. Education has not provided guidance on this requirement and does not monitor compliance with it. Schools and states are engaged in a variety of improvement activities, and most states use student data and feedback to assess activities. Most states reported that schools receiving improvement funds used the funds for professional development and for reorganizing curriculum or instruction time. Nearly all states assisted schools with school improvement plans and professional development. Most states use student achievement data and feedback from schools and districts to assess improvement activities. Education provides a range of support for school improvement, including technical assistance and research results. Nearly all states want more help, such as more information on promising improvement practices. Education has a new Web site to provide additional resources and plans to collect more information on promising practices through a new grant program.

section_title: Letter
paragraphs: Over the past 40 years, the federal government has invested billions of  dollars annually in grants to states and school districts to improve  educational opportunities for economically disadvantaged students. The  most recent reauthorization of the Elementary and Secondary Education  Act of 1965 (ESEA), known as the No Child Left Behind Act of 2001  (NCLBA), sought to hold schools, districts, and states accountable for  student progress. Specifically, states are required to develop academic  standards and tests, measure student proficiency in certain grades and  subjects, and determine whether schools are meeting proficiency goals.  Schools that fail to meet state academic goals for 2 or more years are to be  identified for improvement and are required to take a series of actions  intended to improve student performance. The number of schools  identified for improvement under NCLBA increased from about 8,400 in  school year 2004-2005 to over 10,700 in 2006-2007, and if this trend  continues, more schools will be identified for improvement in the future.  To assist these schools, NCLBA requires states to set aside 4 percent of  their Title I funds to help pay for school improvement efforts, which in  fiscal year 2005-2006 totaled close to $500 million nationally. States are  required to target funds to districts that serve the lowestachieving schools,  have the greatest need for assistance, and are committed to using funds to  help their lowest performing schools meet annual goals. However, the  availability of these funds may be limited because of a hold-harmless  provision that prevents states from giving any district less Title I funds  than it did in the previous year as a result of setting aside improvement  funds.
While states have spent over a billion federal dollars on school  improvement since NCLBA was enacted in 2002, questions remain about  how Title I school improvement dollars are allocated and expended, or the  types of improvement activities schools use and find effective. Further, in  a report accompanying the fiscal year 2006 appropriations bill for the  Department of Education (Education) and other departments, the Senate  Appropriations Committee expressed concern about the hold-harmless  provision and its effect on high-poverty districts as well as states’ ability to  set aside the full 4 percent. To shed light on these issues and to assist  Congress in the reauthorization and funding of NCLBA, you asked GAO to  determine (1) the extent to which states have been able to set aside Title I  school improvement funds and dedicated other federal and state funds to  school improvement since NCLBA was enacted, (2) the schools to which  states targeted school improvement funds and the extent to which these  funds are tracked, (3) the types of activities that states and schools have  undertaken to improve schools and how the these strategies are being  assessed, and (4) how Education provides support to help states make the  best use of school improvement funds.
To do this work, we administered a survey to state education agency  officials in all 50 states and the District of Columbia between July and  October 2007 and received a 100 percent response rate. Because national  information is not available on states’ expenditures of school improvement  funds, we collected this information through our survey. In addition, we  requested information from each state on the schools receiving  improvement funds and linked data on these schools to Education’s  Common Core of Data (CCD) to identify school characteristics. Three  states were unable to provide this information, and 1 state provided partial  information, so our data on school characteristics are presented for only  those states that provided this information. We reviewed both the survey  data and the lists of schools receiving improvement funds for obvious  inconsistencies, errors, and completeness. When we found discrepancies,  we brought them to the attention of state officials and worked with them  to correct the discrepancies before conducting our analyses. On the basis  of these efforts, we determined that the survey data and lists of schools  were sufficiently reliable for the purposes of this report. We also  conducted site visits to 5 states—California, Georgia, Michigan, New  Mexico, and Ohio—which were selected based on having high percentages  of schools identified for improvement, variation in Title I set-aside funding  allocation methods and administrative structures, and geographic  diversity. We met with state officials in each state and, to understand the  local perspective, we met with officials in 12 districts and 22 schools.  Districts and schools were selected to provide variety in student  demographics, locale, and stage of improvement. We interviewed  Education officials and reviewed relevant federal laws, guidance, and  monitoring tools to learn about federal requirements for school  improvement funds and efforts to monitor these funds and activities. We  also interviewed officials from national interest groups and researchers  and reviewed published research and reports about school improvement  funding and activities. See appendix I for more information about our  survey and other data collection methods. We conducted our work from  January 2007 through February 2008 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
paragraphs: Under NCLBA, states are required to hold their Title I schools accountable  for students’ performance by developing academic standards and tests,  measuring student proficiency in certain grades and subjects, and  determining whether schools are meeting proficiency goals. Schools that  have not met state established goals for 2 or more consecutive years are  identified as in need of improvement and must implement certain activities  meant to improve student academic achievement. NCLBA also requires  states to set aside Title I funds to assist schools in implementing  improvement activities.
subsections: section_title: Title I
paragraphs: Title I of the Elementary and Secondary Education Act (ESEA), as  amended and reauthorized by NCLBA, authorizes federal funds to help  elementary and secondary schools establish and maintain programs that  will improve the educational opportunities of economically disadvantaged  children. Title I is the largest federal program supporting education in  kindergarten through 12th grade, supplying an estimated $12.8 billion in  federal funds in fiscal year 2007. Appropriations for Title I grew rapidly in  the years following the enactment of NCLBA, from about $8.8 billion in  fiscal year 2001 to $12.3 billion in 2004. However, Title I funding growth  slowed between 2004 and 2007. (See fig. 1.) Title I funds are allocated  through state educational agencies to districts using statutory formulas  based primarily on Census Bureau estimates of the number of students  from families below the poverty line in each district. States retain a share  for administration and school improvement activities before passing most  of the funds on to school districts. In turn, districts are required to allocate  Title I funds first to schools with poverty rates over 75 percent in rank  order, with any remaining funds distributed at their discretion to schools  in rank order of poverty either districtwide or within grade spans. A  school’s Title I status can change from year to year because school  enrollment numbers and demographics vary over time, and annual  allocations to districts under Title I formulas can vary considerably.
section_title: School Improvement under NCLBA
paragraphs: In 2002, NCLBA added several new provisions to the ESEA, as amended,  to strengthen accountability of all schools identified for improvement,  which included requiring states to develop academic achievement  standards and establish proficiency goals for making adequate yearly  progress (AYP) that will lead to 100 percent of their students being  proficient in reading, mathematics, and science by 2014. To measure their  progress, states administer an annual assessment to students in most  grade levels. In addition, each school’s assessment data must be  disaggregated in order to compare the achievement levels of students  within certain designated groups with the state’s performance goals. These  student groups include the economically disadvantaged, major racial and  ethnic groups, students with disabilities, and those with limited English  proficiency, and each of these groups generally must make AYP in order  for the school to make AYP.
The last reauthorization of ESEA prior to NCLBA—the Improving  America’s Schools Act of 1994 (IASA)—required that schools be identified  for improvement if they did not make AYP for 2 consecutive years and that  they take certain actions to improve student performance. NCLBA also  includes a timeline for implementing specific interventions based on the  number of years a school fails to make AYP and adds some interventions  that were not required under IASA. (See table 1.) Under NCLBA, schools  that fail to make AYP for 2 consecutive years are identified for  improvement and must develop an improvement plan in consultation with  the district, school staff, parents, and outside experts. This plan, which is  subject to district approval, must incorporate strategies to address the  specific academic issues that caused the school to be identified for  improvement. At this stage districts also must offer students in the school  the opportunity to transfer to a higher-performing public school in the  district—an option that is called offering public school choice. After the  third year, districts must also offer supplemental educational services  (SES), such as tutoring. Under NCLBA, if a school fails to make AYP for 4  consecutive years, it is required to implement one of the corrective actions  identified in the law, such as implementing a new curriculum or extending  the school year or day. Finally, if a school fails to make AYP for 5 or more  years it must make plans to restructure its governance and implement  those plans. Schools exit improvement status if they make AYP for 2  consecutive years. In addition, all schools identified for improvement are  required to spend at least 10 percent of their Title I funds on professional  development for the school’s teachers and principal as appropriate.
section_title: Both Districts and States Provide Technical Assistance to Schools in Improvement
paragraphs: School districts bear the primary responsibility for ensuring that their  schools in improvement receive technical assistance. Specifically, districts  must ensure that each school identified for improvement receives  assistance based on scientifically based research in three areas: analysis of  student assessment data, identifying and implementing instructional  strategies, and analysis of the school budget, as shown in table 2.
States provide technical assistance to districts and schools through their  statewide systems of support, with a priority given to those in  improvement status. In developing their statewide system of support, the  state educational agency must (1) establish school support teams that  include individuals who are knowledgeable about scientifically based  research and practice to assist schools throughout the state that are  identified for improvement in areas such as strengthening instructional  programs; (2) designate and use distinguished teachers and principals who  are chosen from Title I schools and have been especially successful in  improving academic achievement; and (3) devise additional approaches to  improve student performance, for example, by drawing on the expertise of  other entities such as institutions of higher education, educational service  agencies, or private providers of scientifically based technical assistance.
section_title: States Are Required to Set Aside a Percentage of Their Title I Funds to Support School Improvement Activities
paragraphs: NCLBA requires states to set aside a portion of Title I funds to allocate to  districts for use by and for schools for school improvement activities and  to carry out the state’s responsibilities for school improvement. In fiscal  years 2002 and 2003, states were required to reserve 2 percent of the Title I  funds for school improvement, and in fiscal years 2004 to 2007, states were  required to reserve 4 percent. However, states may not always be able to  reserve the full amount for school improvement because of a hold- harmless provision that prevents states from reducing the amount of Title  I funds any district receives from what it received the prior year. The hold- harmless provision is intended to protect school districts from declines in  Title I funding from year to year, by preventing the state from giving them  less funds than the year before. If the total increase in Title I funds from  districts with increasing allocations is less than 4 percent of a state’s total  Title I allocation, then that state would not be able to set aside the full 4  percent of Title I funds for school improvement.
States are generally required to allocate 95 percent of the 4 percent set-aside  to districts for schools identified for improvement. States may use the  remaining 5 percent of the 4 percent set-aside to carry out their  responsibilities related to school improvement, including creating and  maintaining their statewide system of support. (See fig. 2.) NCLBA  establishes priorities and requirements for the distribution of school  improvement funds to districts. Specifically, under NCLBA states must give  funding preference to districts that serve the lowest-achieving schools,  demonstrate the greatest need for assistance, and demonstrate the strongest  commitment to using the funds to assist their lowest-performing schools with  meeting progress goals. States may either allocate these funds directly to  districts for schools identified for improvement to be used for activities  required under the school improvement section of the law or, with the  permission of districts, retain funds to provide for these activities for schools  identified for improvement.
While NCLBA directs 95 percent of improvement funds to schools through  districts, some flexibility exists for funds to be used at the state or district  level for improvement-related activities. For example, NCLBA gives states  authority to use some of the 95 percent funds at the district level if the  state determines that it has more funding than needed to provide  assistance to schools in improvement. In addition, states may use some of  their 5 percent funds generally retained at the state level for districts to  support district-level activities.
Among other requirements regarding the allocation of funds, states are  required to make publicly available a list of the schools that have received  funds or services from the school improvement set-aside and the  percentage of students in each of these schools from families with  incomes below the poverty line.
section_title: Other Funds States May Use for School Improvement Activities
paragraphs: In addition to the Title I set-aside, Education officials told us that states  may use state funds for school improvement or incorporate other federal  funds to support school improvement efforts, including the School  Improvement Grant Program under NCLBA, Comprehensive School  Reform, Reading First, and Title II teacher and principal quality programs  (see table 3). These programs either establish funding priorities for  schools identified for improvement or allow for state flexibility to  establish such priorities.
section_title: Education Oversees School Improvement Funds through Compliance Monitoring
paragraphs: Education oversees how states allocate school improvement funds as part  of its overall monitoring of state compliance with Title I and NCLBA.  Education monitors states in two ways: (1) by routinely gathering and  analyzing data collected from Web-based searches and documents, such as  the Consolidated State Performance Reports, and (2) by conducting on- site visits to state educational agencies and selected districts and schools  within each state to interview officials and review relevant documents.  Education has a 3-year monitoring cycle for visiting each state. During  these visits, Education reviews whether states provide guidance to  districts related to the use of school improvement funds and activities and  how the state monitors school improvement plans. Education’s monitoring  guide includes specific questions about how the state allocated school  improvement funds, whether all the funds have been spent, and what  guidance the state provided to districts—and was recently updated to  include some additional questions on whether states are monitoring  expenditures of school improvement funds at the school level and  assisting schools in effectively using their resources to make AYP and exit  improvement status.
section_title: A Statutory Requirement Limits Some States’ Ability to Target Title I School Improvement Funds to Lowest- Performing Schools, but Many States Have Used Other Resources for School Improvement Efforts
paragraphs: The hold-harmless provision, which is designed to protect school districts  from reductions in their Title I funding, prevented some states from being  able to target school improvement funds to low-performing schools.  However, many states have used other federal and state funds for school  improvement efforts. The hold-harmless provision prioritizes maintaining  the Title I funding of all eligible districts over ensuring that states can set  aside the full 4 percent for schools identified for improvement—the lowest  performing schools. Twenty-two states have been unable to set aside the  full 4 percent of Title I funds for school improvement for 1 or more years  since NCLBA was enacted because they did not have enough funds to do  so after satisfying the hold-harmless provision. Schools identified for  improvement are, by definition, performing worse than other schools— and may be among the neediest. When states cannot set aside the full 4  percent for school improvement, it is difficult for them to plan and provide  consistent assistance to these schools. In addition to Title I funds for  school improvement, many states have dedicated other federal funds and  state funds to school improvement efforts. In the period since NCLBA was  enacted, state funds used for this purpose totaled almost $2.6 billion,  compared to $1.3 billion in federal Title I funds.
subsections: section_title: A Statutory Requirement Limits Some States’ Ability to Target School Improvement Funds to the Lowest-Performing Schools
paragraphs: While the hold-harmless provision is designed to protect school districts from  reductions in their Title I funding, it has prevented some states from being able  to set aside the full amount of funds for school improvement, which are  intended for the lowest-performing schools. While the total amount of Title I  funds a state receives does not decrease in any one year as a result of  calculating the 4 percent set-aside, the hold-harmless provision can affect how  those funds are allocated within a state. Specifically, when states set aside  funds for school improvement, the hold-harmless provision prevents the state  from reducing the Title I funding for any school district from the previous year.  Sometimes, after taking into consideration the hold-harmless provision, there  are not enough funds available from those districts with increasing Title I  allocations to cover the full 4 percent set-aside. Specifically, 22 states have been  unable to set aside the full portion of Title I funds for school improvement for 1  or more years since NCLBA was enacted because they did not have enough left  over after satisfying the hold-harmless provision. Six of these—Florida,  Kansas, Kentucky, Maine, Massachusetts, and Michigan—have been unable to  set aside the full amount for 3 or more years. (See fig. 3). Title I allocations are  distributed through states to school districts based on poverty levels, and the  hold-harmless provision protects districts from receiving less than they  received the previous year. In other words, if a district’s population of low- income students decreases, the hold-harmless provision ensures that a district  does not receive less Title I funds than the previous year as a result of the  school improvement set-aside. Consequently, states can only set aside funds  for school improvement that would otherwise have been allocated to school  districts slated for Title I increases. In addition to the 22 states affected by the  hold-harmless provision, 4 states did not set aside the full portion of Title I  school improvement funds for other reasons. For example, 1 state reported that  it did not set aside the entire set-aside amount because it had few schools  identified for improvement. In 2006, 12 states were unable to set aside the full 4  percent of Title I funds for school improvement due to the hold-harmless  provision, with set-asides ranging from as little as 0.2 percent in Kansas to 3.75  percent in Florida.
The lowest-performing schools—schools identified for improvement—are  affected when states cannot set aside the full 4 percent for school  improvement. These schools—which are the targets of the school  improvement funding—have failed to meet state performance goals and  are, by definition, performing worse than other schools. Effectively, the  hold-harmless provision prioritizes preserving the Title I funding of all  eligible Title I districts over ensuring that the lowest-performing schools  receive funds for school improvement. Furthermore, schools identified for  improvement may be among the neediest. In fiscal year 2006, schools  identified for improvement in the 12 states that were unable to set aside  the full 4 percent had higher average percentages of students in poverty  and minority students compared to other Title I schools that were in need  of improvement in those states. (See table 4.)
When states cannot set aside the full portion of Title I funds for school  improvement, it is difficult for states to provide consistent assistance to  schools identified for improvement. States that were unable to set aside  the full 4 percent for school improvement experienced large decreases in  their school improvement funds from year to year compared to all other  states. (See table 5.) For example, Ohio officials told us that they  experienced a decline of $14 million in Title I allocations to districts  between fiscal years 2004 and 2005 due to a decrease in census estimates  of the number of low-income students. Since the state still had to provide  all districts with no less Title I funds than the year before, it set aside 58  percent, or $9.3 million, less in school improvement funds than it had in  the previous year. An Ohio official said this variability made it difficult to  commit school improvement assistance to districts. To address this issue,  Ohio now retains a portion of its total Title I school improvement set-aside  each year to help ensure that school improvement funds will be available  if there are future decreases in school improvement funds as a result of  the hold-harmless provision.
There is also wide variation among states in the average amount of school  improvement money available per school in improvement. (See fig. 4).  The average amount per school in improvement varies due to differences  in overall Title I allocations as well as the number of schools identified for  improvement in each state. For example, Massachusetts received over  $200 million in Title I funds in fiscal year 2006 and set aside less than  $780,000 for its 455 schools identified for improvement, for an average of  approximately $1,700 available per school identified for improvement. In  contrast, Texas received over $1 billion in Title I funds in fiscal year 2006  and set aside $47 million for its 291 schools identified for improvement,  averaging approximately $163,000 per school identified for improvement.
Education, recognizing challenges associated with the hold-harmless  provision, has proposed eliminating the provision as part of its 2007  budget justification and again as part of its proposals for reauthorization  of NCLBA. In its 2007 budget justification, Education estimated states’  ability to set aside the full 4 percent of Title I funds for school  improvement for fiscal year 2005 and contended that the hold-harmless  provision, in conjunction with Title I funding fluctuations, limited many  states’ ability to reserve these funds. Additionally, the department pointed  out that districts slated for Title I increases disproportionately contribute  to the Title I school improvement set-aside. Congress has not repealed the  hold-harmless provision and is currently deliberating the reauthorization  of NCLBA.
section_title: Many States Have Dedicated Other Federal Funds and State Funds to School Improvement Efforts
paragraphs: In addition to Title I funds for school improvement, many states have  dedicated other federal funds to school improvement efforts. To further  support school improvement efforts, 38 states targeted funds from other  federal programs intended to improve student achievement, including the  Comprehensive School Reform Demonstration Program (CSR), Reading  First, and teacher and principal quality programs under Title II of NCLBA.  Several states we visited reported incorporating CSR funds and Reading  First funds into their school improvement strategies. For example, in Ohio,  CSR funds were prioritized toward school improvement purposes under  NCLBA. Ohio’s school improvement funding scheme provided Title I set- aside funds to schools for up to 3 years, after which schools could obtain  funds from the CSR program.
Additionally, 17 states have contributed almost $2.6 billion in state funds  for school improvement activities since NCLBA was enacted, nearly  double the $1.3 billion in federal Title I school improvement funds  provided over the same period. In 2006, 14 states contributed state funds  for school improvement under NCLBA. (See table 6.) For example, in 2006,  Georgia spent $9.5 million of its funds on its statewide system of support,  nearly as much as it expended in Title I school improvement funds. The 5  percent of the Title I school improvement set-aside the state of Georgia  reserves under NCLBA for its own use supports 8 employees in its school  improvement division, which implements its statewide system of support.  The remaining 107 employees in the division are supported by Georgia’s  own state funds. We found no relationship between the usage of state  funds for school improvement and whether a state reserved the full Title I  set-aside amount required under NCLBA.
section_title: States Generally Target Funds to the Most Persistently Underperforming Schools, However, Some States Did Not Fulfill NCLBA Requirements for Allocating or Tracking Funds
paragraphs: States generally target improvement funds to the most persistently  underperforming schools, but some states did not fulfill some NCLBA  requirements for allocating or tracking funds. On our survey, states  generally reported that they provided more funds to the most persistently  underperforming schools, and those schools had higher percentages of  low-income and minority students than all other Title I schools. To  allocate school improvement funds, 37 states use state-established criteria  that include factors such as the number of years the school had been  identified for improvement, 2 states used a competitive grant process, and  8 used some other method. However, 4 states reported that they allocated  funds equally among schools in improvement, and may not have taken into  consideration factors required by NCLBA, such as focusing on the lowest  achieving schools. In addition, 1 state allocated Title I improvement funds  to districts without schools in improvement and did not take the required  steps to do this. Education did not identify these potential compliance  issues as part of its monitoring efforts. We referred these issues to  Education, and the department is following up with relevant states. Also, 4  states were unable to provide complete information on which schools in  their state received improvement funds, as required under NCLBA.  Education has not provided guidance on how states should provide this  information and does not monitor states’ compliance with this  requirement.
subsections: section_title: States Generally Target Improvement Funds to the Most Persistently Underperforming Schools
paragraphs: Generally, we found that states targeted school improvement funds to the  most persistently underperforming schools—those that had failed to make  AYP for several years—and states tended to provide more funds to these  schools. For example, the median grant amount for schools in  restructuring nationwide was about $40,000 more than for schools in  corrective action in 2006. (See fig. 5.)
Overall, schools receiving improvement funds differed from Title I schools  not in improvement and schools in improvement that did not receive  funds. For example, schools receiving improvement funds had higher  percentages of students in poverty and higher percentages of minority  students compared to Title I schools not identified for improvement. (See  table 7.) In addition, 54 percent of schools that received improvement  funds were located in urban areas compared to 24 percent of all other Title  I schools not identified for improvement. Nearly half of the schools that  received funds were primary schools and nearly one-third were middle  schools. While schools identified for improvement that received funds had  similar poverty and minority percentages as all other schools identified for  improvement, there were some differences between these two groups. For  example, 26 percent of schools that received improvement funds were  located in rural areas, compared to 12 percent of all other schools  identified for improvement. In the 2005-2006 school year, approximately 71  percent of schools identified for improvement received school  improvement funds.
section_title: States Use Varying Criteria to Prioritize Schools for School Improvement Funds, but Some States Did Not Fulfill NCLBA Requirements for Allocating Funds
paragraphs: Thirty-seven states established criteria on a state level to determine which  schools should receive Title I school improvement funds or services, and  the remaining states used other allocation methods. (See fig. 6.) Of the 37  states, 27 used criteria that included the number of years the school failed  to make AYP, and 21 states used criteria that included the number of  students in each school. For example, Michigan officials told us that their  allocation formula includes the year of school improvement as well as  overall student enrollment. The state also differentiates between schools  that failed to make AYP for academic reasons and those that missed AYP  targets for other reasons, such as graduation rate or attendance. Of the 14  states that used methods other than state-established criteria to allocate  funds, 2 states—Colorado and Idaho—distributed funds through a  competitive grant process. Eight states used other allocation methods  such as distributing funds to districts by ranking the schools identified for  improvement based on school performance and the number of low-income  students. However, we found that Delaware, New Hampshire, Virginia, and  the District of Columbia reported they required districts to provide each  school receiving school improvement funds an equal amount of funding,  and, thus, may not have prioritized the allocation of funds as required  under NCLBA. In addition to their various allocation methods, 9 states  gave districts flexibility in determining which schools received funds. For  example, New York allocates funds to districts based on state-established  criteria regarding schools in need of improvement. However, districts can  choose which schools receive funds and the amount of funds those  schools receive.
In addition to criteria used to allocate funds, states also varied in the  proportion of school improvement funds allocated to schools and retained  by the state. In 2006, 38 states allocated 95 percent of the school  improvement set-aside funds directly to local school districts for schools  identified for improvement, as NCLBA requires, with the remaining 5  percent retained by states to carry out their responsibilities. In 2006, 1  state that we visited retained less than 5 percent for its statewide system  of support and distributed more than 95 percent to districts for schools  identified for improvement. In contrast, some states retained more than 5  percent of their school improvement set-aside, as permitted under NCLBA  under certain circumstances. With the approval of districts, a state may  retain more than 5 percent to directly provide school improvement  services for schools or arrange for other entities to provide these services.  In 2006, 10 states retained more than 5 percent. (See fig. 7.) For example,  New Mexico officials told us that eligible districts agreed that the state  could retain the entire set-aside amount to support a systematic reform  model for school years 2006-2007 and 2007-2008. For participating schools,  state officials paid a contractor to provide leadership and instructional  training, reading and math interventions, and materials needed to support  the interventions for schools identified for improvement.
While most states retained the allowed 5 percent of the Title I school  improvement funds to carry out their state responsibilities, 23 states  reported that they have fully implemented their statewide system of  support. Of the remaining 28 states, 18 reported that their system was  mostly implemented and 10 reported they have partially implemented their  system. Education officials offered several reasons why states may not  have fully implemented these systems. For example, some states may not  have had enough funds to fully implement their statewide system of  support. In other states, statewide strategies may only reach a portion of  the schools identified for improvement because services are prioritized for  the lowest-achieving schools and districts. In addition, officials said some  states have experienced large increases in the number of schools  identified for improvement, necessitating significant changes to their  statewide system of support.
Additionally, 21 states allocated some of their Title I school improvement  funds to districts for district-level activities, including at least 1 state that  may not have met NCLBA requirements for doing this. Districts have a  major responsibility for providing technical assistance to schools  identified for improvement. According to Education officials, while  NCLBA does not explicitly set aside funds for district-level activities, it  does allow for districts to use improvement funds to provide services to  these schools. In addition, Education officials said that funds can be used  for building district capacity if the funds are focused on providing services  for schools identified for improvement. In Massachusetts, for example,  some funds supported district-level specialists who provided direct  assistance to schools identified for improvement in areas such as data  analysis and implementing the school improvement plan. In addition,  according to Education officials, states have authority to use some of the  95 percent funds for districts identified for improvement but without  schools in improvement if the state determines that the amount of 95  percent funds exceeds the amount needed to provide assistance to schools  identified for improvement. In this situation, a state may take excess funds  from one district and give those funds to other districts based on state- determined need. Education officials told us that states must consult with  districts before claiming unused funds and have evidence that these  discussions took place. However, we found that 1 state may have  allocated Title I improvement funds to districts identified for improvement  without schools identified for improvement without first determining it  had excess funds. We identified this issue through our site visits and are  uncertain if other states may have also done this. Education officials said  they did not identify this issue during their recent monitoring visit. We  referred this matter to Education, which is following up on it.
section_title: While States Collect Some Information to Track Funds, Many States Are Not Able to Provide Information on Which Schools Receive Funds
paragraphs: Most states collect and track information on the use of school  improvement funds. Forty-eight states reported on our survey that they  collect information on the expenditure of Title I school improvement  funds at least annually from schools, districts, or other sources. Twenty- four states reported collecting expenditure information on each school  receiving improvement funds. Other states reported collecting expenditure  information from districts that provide aggregate information for all  schools that received improvement funds in the district, rather than for  each school receiving improvement funds. Seventeen states reported that  district officials monitor school improvement funds by comparing  activities that were funded to those identified in school improvement  plans. For example, some district officials we visited said they compare  school improvement expenditures to the school improvement plan before  approving disbursements. Forty-five states reported that state or district  officials conduct visits or monitor through other means how school  improvement funds were expended and what school improvement  activities were funded. State officials from 14 states reported that  monitoring was conducted in multiyear cycles rather than annually or that  a portion of schools were monitored annually. For example, as part of  Ohio’s monitoring and review process, officials said that district cohorts  are reviewed every 3 years with on-site reviews conducted at a minimum  of 10 percent of the cohort.
While most states monitor funds, 4 states were unable to make publicly  available the complete list of schools receiving improvement funds, as  required under NCLBA, because these states do not collect information on  each school receiving improvement funds, and Education has not provided  guidance on this requirement. Almost all states were able to provide a list  of schools receiving funds to us, but 3 states—Arkansas, Florida, and  North Carolina—provided information on districts that received funds, but  could not provide information on which schools received funds, and  California provided a partial list of schools that received funds. In a few  cases, we found that non-Title I schools had inappropriately received Title  I school improvement funds. State officials said that they would take steps  to address this issue, and we referred this matter to Education, which is  following up on it. Though Education monitors the allocation of school  improvement funds through its 3-year Title I monitoring cycle, Education  officials told us they had not uncovered these issues. In addition,  Education does not regularly check when and whether states have made  the lists of schools receiving improvement funds publicly available, as  required, and has not provided guidance on how states make lists of  schools receiving improvement funds publicly available.
section_title: Schools and States Are Engaged in a Variety of Improvement Activities and Mainly Assess Them Using Student Achievement Data and Feedback
paragraphs: Schools that received funds and states have employed a range of  improvement activities, and most states assess these activities by  reviewing trends in student achievement data and obtaining feedback from  district and school officials. At least 45 states reported that schools that  received school improvement funds were involved in professional  development, reorganizing curriculum or instructional time, or data  analysis. Nearly all states reported that they assisted schools identified for  improvement with school improvement plans and professional  development, and officials in 42 states consider this assistance key to  helping schools improve. To assess school improvement activities, 42  states reported that they track student achievement data or school  performance trends, and 36 of those states also use feedback from school  and district officials.
subsections: section_title: Schools That Received Funds Have Undertaken a Variety of Improvement Activities, and States Have Provided Support for Many of These Activities
paragraphs: Nearly all states reported on our survey that schools that received  improvement funds in school year 2006-2007 were engaged in activities  such as professional development and data analysis, and districts and  schools we visited also cited these and other activities. Forty-seven states  reported that schools receiving improvement funds were taking part in  professional development, 46 states said schools were reorganizing  curriculum or instructional time, and 45 states reported that schools were  using data analysis from the state’s assessment system or other  assessments. School officials in each state we visited also cited using  school improvement funds for professional development activities. For  example, at one school in California, staff received intensive training in  instructional strategies and data analysis software, which was designed to  help teachers analyze instructional practices and provided teachers with  specific steps to increase student achievement. In addition, schools and  districts in every state we visited mentioned using coaches who are  generally former principals, teachers, or other subject area specialists who  work with school administrators or teachers. School officials in Michigan  noted that coaches had served as a key resource in the development of  school improvement plans. In some of the schools and districts we visited,  officials pointed to the importance of examining test scores and student  data in helping schools improve. For example, a school district in Ohio  provided school leaders and teachers immediate access to test scores and  other information such as curriculum, professional development  resources, and student records online to help track student achievement.
While over 40 states reported that they assisted schools identified for  improvement with the school improvement plan, professional  development, and data analysis, or provided help from school support  teams, states generally reported providing more assistance to schools in  later stages of improvement (See fig. 8). In New Mexico, for example, all  schools identified for improvement are required to conduct certain  activities such as short cycle assessments several times a year, while  schools in restructuring are also required to send staff to training in areas  such as principal leadership. As another example, 44 states reported that  they provided assistance from school support teams to schools in  corrective action and restructuring, compared to 34 states that reported  providing this assistance to schools in earlier stages of improvement. The  only area in which states said they provided slightly more assistance to  schools in earlier stages of improvement was helping with the school  improvement plan.
Forty-two states considered helping schools identified for improvement  with the school improvement plan and professional development to be  somewhat to very effective forms of state support. For example, many  states provided schools and districts a template for improvement plans,  which can help ensure some consistency in plans across the state. In Ohio,  state officials showed us an electronic tool that they developed for both  district improvement plans and school improvement plans that they said  have been useful in aligning district and school improvement plans.
section_title: States Primarily Use Student Achievement Data and Feedback from Districts and Schools to Assess Improvement Activities
paragraphs: Forty-two states reported that they tracked changes in student  achievement data or school performance trends, and 36 of those states  also used feedback from district and school officials to assess  improvement activities. For example, Michigan officials said they require  schools to provide student achievement data annually and to describe  which improvement activities were working as well as what changes they  planned to make. We also found that some states we visited conduct more  extensive reviews of schools in corrective action and restructuring that  include site visits, assessments, and observation of staff and leadership.  Most districts and schools we visited also focus on student achievement  data to assess activities. One school in Georgia has students take interim  practice tests using questions similar to those of the state’s annual  assessment to track students’ progress. The school has a “data room” that  has test scores and other data by grade level and subgroups displayed in  lists, graphs, and charts to track progress and serve as a visual reminder of  its overall goals. (See fig. 9.) At the district and school levels, officials in  every state we visited emphasized the importance of using the school  improvement plans to identify specific actions and goals, and many use the  plan to monitor progress and make adjustments as needed.
Twenty-four states reported that they conduct evaluations, either on the  state, district, or school level to assess activities. Based on information  provided by some states, these assessments were not in line with  Education’s definition of high-quality reviews of educational effectiveness  but included approaches to assess activities and track school  improvement. In some cases, states we visited told us they are working  with or plan to work with an independent evaluator or other entity to  conduct a more formal evaluation of school improvement activities.
section_title: Education Provides a Range of Support for School Improvement, Including Some New Efforts Aimed at Areas in Which States Want More Help
paragraphs: Education directly supports states with school improvement through  written guidance, staff assistance, policy letters, and information provided  at national conferences. In July 2006, Education published nonregulatory  guidance on district and school improvement that updated and expanded  its earlier guidance in this area. Education staff also provide direct  assistance by responding to states’ questions. In some cases, Education  officials said they send policy letters to individual states to address state- specific questions and post the letters on its Web site. For example, one  state requested clarification from Education on allocating Title I school  improvement funds to districts, and Education responded with a policy  letter. In addition, Education also provides guidance and disseminates  information through national conferences such as the annual Title I   National Conference.
In addition to direct support, Education provides a number of technical  assistance and research-related resources to assist states, districts, and  schools in their school improvement efforts. These include the  Comprehensive Centers Program, Regional Education Laboratories, the  Center for Comprehensive School Reform and Improvement, the What  Works Clearinghouse, and a new Doing What Works Web site.   (See fig. 10).
Education provides a number of services to states through its  Comprehensive Centers Program—consisting of 16 regional centers  and 5 content centers. The regional centers are located across the  country and provide training and technical assistance to address state  needs and priority areas, which largely focus on school improvement.  Each of the 5 content centers focuses on one of the following areas:  accountability, instruction, teacher quality, innovation and  improvement, or high schools. The content centers provide expertise,  analysis, and research in the five content areas. According to an  Education official, a key focus of the comprehensive centers is helping  states build their statewide systems of support. Currently, the  comprehensive centers have 8 regional initiatives and 35 individual  state initiatives related to this topic. In addition, there are 2 regional  initiatives and 26 individual state initiatives to address district and  school improvement.
One content center, the Center on Innovation and Improvement,  provides a variety of services related to school improvement. The  center gathers data and information on districts and schools making  sustained gains to identify successful improvement strategies. It has  developed two guides on this topic, a Handbook on Restructuring and  Substantial School Improvement and a Handbook on Statewide  Systems of Support, which it has distributed to regional centers, state  educational agencies, and other organizations. The center also  facilitates information sharing on school improvement topics through  its annual 2-day training for representatives of the regional centers and  additional workshops throughout the year. In addition, the center  collaborates with the Council of Chief State School Officers to issue  monthly School Improvement e-newsletters, which focus on school  improvement efforts at the state and district levels.
Education also compiles and disseminates relevant research on  effective educational interventions. Education operates 10 Regional  Education Laboratories to provide research on a variety of topics, such  as statewide systems of support and factors that have helped schools  make AYP. The laboratories are also available to provide assistance to  any entity, such as school districts or schools, if they request  assistance. Education also funds the Center for Comprehensive School  Reform and Improvement to assist schools and districts in  implementing comprehensive school reform and improvement by  providing information about research-based strategies and assistance  in using that information to make changes. In addition, Education  developed the What Works Clearinghouse to review studies of  educational interventions to determine which studies were conducted  with a sound methodology and to what extent the interventions are  effective. In November 2007, Education implemented a Doing What  Works Web site to help educators adapt and use the research-based  practices identified by the What Works Clearinghouse.
State officials reported that Education’s written guidance, national  meetings or conferences, and comprehensive centers were the most  helpful forms of assistance and the What Works Clearinghouse was  relatively less helpful (See fig. 11.) For example, in several states we  visited, state officials told us that comprehensive centers have been  helpful in areas such as building state school improvement capacity and  facilitating discussions with other states. Although 15 states reported that  the What Works Clearinghouse was moderately to very helpful, 20 states  reported that it provided some to no help. District officials said that it has  not been useful for reasons such as it is difficult to figure out how to  translate the research on the What Works Clearinghouse into practical  application at the classroom level.
Almost all states also reported that they could benefit from additional  assistance from Education. Fifty states reported that they could benefit  from more tool kits and sample documents, and 48 states said they could  benefit from more national or regional conferences to share lessons  learned and promising practices. Education officials said that they have  also heard that states want more opportunities to share information and  are looking for ways to do this. Forty-three states also reported that they  could use additional assistance in evaluating the effectiveness of school  improvement activities, and 42 states said they could benefit from more  help with monitoring and assessing school improvement activities.
Education has taken steps to address concerns about the What Works  Clearinghouse and to provide additional resources aimed at addressing  areas in which states want more help. An Education official told us that  the recently implemented Doing What Works Web site is aimed at helping  educators adapt and use the research-based practices on the What Works  Clearinghouse. To do this, the Doing What Works Web site provides the  following: (1) information to help make the research on effective practices  more understandable for educators, (2) links to real-life examples such as  interviews with teachers and pictures from classrooms to help show the  practices in action, and (3) tools and resources that educators can use in  their own planning and training efforts. As far as providing more help on  monitoring and evaluating school improvement activities, Education  officials told us that they plan to collect additional information about  successful school improvement practices as part of the new school  improvement grants—authorized under NCLBA and funded for the first  time in 2007. States receiving these grants will be required to track and  report outcomes such as increased student proficiency and how school  improvement activities helped schools improve. Education plans to  compile this information and discuss this topic at a meeting of state Title I  directors in early 2008. In addition, the Administration, as part of its  proposed revision to the school improvement section of NCLBA, is  recommending that Education be allowed to reserve up to 1 percent of  Title I funds to conduct research, evaluation, and dissemination activities  related to effective school and district school improvement activities.
section_title: Conclusions
paragraphs: While the hold-harmless provision is intended to shield districts from  receiving less in Title I funds than in the previous year as a result of the  school improvement set-aside, we found some evidence that it may be  preventing some of the neediest schools that face the most challenges to  improving the academic achievement of their students from obtaining  these funds. When states cannot set aside the full 4 percent of Title I for  school improvement, their ability to target funds at the lowest-performing  schools is diminished. Effectively, the hold-harmless provision prioritizes  preserving the Title I funding of all eligible Title I districts over ensuring  that the lowest-performing schools receive funds for school improvement.  Furthermore, the variability from year to year in state Title I funds can  affect some states’ ability to sustain a steady stream of support for low- performing schools. Removing the hold-harmless provision, as Education  has proposed, would clearly increase states’ ability to target improvement  funds to the lowest-performing schools. However, while Education points  out that set-aside funds come from districts with increasing Title I  allocations, it is still not known how removing the hold-harmless provision  would affect those districts protected by it. It would be helpful for  Congress as it deliberates reauthorization of NCLBA to know the  characteristics of districts that contribute to the set-aside compared to  those that are protected by the hold-harmless provision, particularly in  terms of student characteristics and school performance.
Thousands of schools have received Title I school improvement funds  intended to help schools raise student achievement, and states have  generally targeted these funds to schools with the most persistent  achievement problems. However, without additional monitoring steps by  Education to ensure that states are appropriately allocating funds for  district-level activities and prioritizing funds to the lowest-achieving  schools, some schools most in need of assistance may not receive funding.  While Education monitors every state’s improvement program every 3  years, it has not uncovered several compliance issues that we identified.  Further, because some states do not track which schools receive  improvement funds and could not make this information publicly  available, as required under NCLBA, Education and others have not been  in the best position to ensure that school improvement funds are used only  for Title I schools and targeted to the lowest-performing schools. Ensuring  that states track which schools receive improvement funds and can make  this information publicly available enhances transparency and  accountability, and better enables the public, Education, and states to  track compliance and progress.
section_title: Recommendations for Executive Action
paragraphs: To enhance state efforts to target improvement funds to schools most in  need of assistance, we are making the following three recommendations to  the Secretary of Education:    To further support the department’s proposal to eliminate the hold- harmless provision, develop an analysis comparing the characteristics  of districts that contribute to the set-aside with those protected by the  hold-harmless provision. Such an analysis could identify differences in  school performance or student characteristics.
Review the Title I monitoring process to ensure that steps are in place  to ensure that states comply with NCLBA requirements for allocating  school improvement funds to districts for district-level activities and  prioritizing funds to the lowest performing schools.
Ensure that states track which schools receive improvement funds and  can comply with the requirement to make a list publicly available of all  schools receiving Title I improvement funds by providing guidance to  clarify when and how this information is to be made available and by  monitoring state compliance.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Education for  review and comment. In its written response, included as appendix II,  Education agreed with our three recommendations.  Specifically,  Education agreed to explore options to determine the types of analyses  that would be helpful to inform the debate on eliminating the hold- harmless provision.  Education also agreed to review its monitoring  process and consider changes to gather additional evidence on whether  school improvement funds are being allocated and prioritized as required  by statute. In addition, Education agreed that it will explore options for  providing guidance to states on the NCLBA requirement that states make  publicly available a list of all schools receiving Title I school improvement  funds.  Education also identified some of the steps it has taken to collect  additional information on the allocation and use of school improvement  funds and to identify successful school improvement strategies.
Copies of this report are being sent to the Secretary of Education, relevant  congressional committees, and other interested parties.  We will also make  copies available to others upon request. In addition, the report will be  made available at no charge on GAO’s Web site at http://www.gao.gov.  Please contact me at (202) 512-7215 if you or your staff have any questions  about this report. Other contacts and major contributions are listed in  appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: To address the objectives of this study, we used a variety of methods. To  obtain nationally representative information on states’ school  improvement funding, types of activities being funded, and federal  assistance, we administered a survey to state education agency officials in  all 50 states and the District of Columbia. To get a national perspective of  schools in improvement, we conducted descriptive analyses of  characteristics of schools that received improvement funds and compared  them to all schools identified for improvement and all other Title I schools  nationwide. We also conducted site visits during which we interviewed  state, district, and school officials representing 5 states and 12 school  districts within these states. We spoke with officials at Education involved  in oversight and distribution of school improvement funds and reviewed  Education’s data on schools identified for improvement. We also  interviewed several experts in the field of school improvement. We  reviewed relevant federal laws, regulations, and agency guidance. We  conducted our work from January 2007 through February 2008 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: Survey of States
paragraphs: To better understand states’ school improvement efforts, particularly how  states are allocating and tracking school improvement funds and activities,  we designed and administered a survey to state education agency officials  in all 50 states and the District of Columbia between July and October  2007 and had a 100 percent response rate.
The survey included questions on the amount of Title I improvement funds  states have reserved and expended, what other federal or state funds are  being used, what types of improvement activities are being funded, how  activities are being monitored and assessed, and assistance received from  Education.
Because this was not a sample survey, there are no sampling errors.  However, the practical difficulties of conducting any survey may introduce  nonsampling errors, such as variations in how respondents interpret  questions and their willingness to offer accurate responses. We took steps  to minimize nonsampling errors, including pretesting draft instruments  and following up with states to discuss questionable responses.  Specifically, during survey development, we pretested draft instruments  with officials in Rhode Island, Ohio, Illinois, Montana, and Florida  between May and June 2007. In the pretests, we were generally interested  in the clarity of the questions and the flow and layout of the survey. For  example, we wanted to ensure that definitions used in the surveys were  clear and known to the respondents, categories provided in closed-ended  questions were complete and exclusive, and the ordering of survey  sections and the questions within each section were appropriate. On the  basis of the pretests, the survey instrument underwent some slight  revision. A second step we took to minimize nonsampling errors was  contacting state officials via phone and e-mail to follow up on obvious  inconsistencies, errors, and incomplete answers. We also performed  computer analyses to identify inconsistencies in responses and other  indications of error.  In addition, a second independent analyst verified  that the computer programs used to analyze the data were written  correctly.
section_title: Education and State Data
paragraphs: For our analysis, we used data from three sources—state-provided data on  schools that received Title I improvement funds in each state, Education’s  Common Core of Data (CCD), and Education’s Consolidated State  Performance Reports (CSPR). For comparison, we created three discrete  groups of schools: (1) schools identified for improvement that received  funds and services, (2) schools identified but not receiving funds and  services, and (3) all other Title I schools that were not identified for  improvement for school year 2005-2006.
To obtain information on the characteristics of schools receiving school  improvement funds, we requested information from each state on the  schools identified for school choice, supplemental educational services,  corrective action, or restructuring in their respective state that received  Title I set-aside school improvement funds or services pursuant to  §1003(a) of the No Child Left Behind Act (NCLBA) during the 2004-2005,  2005-2006, and 2006-2007 school years. We also asked states to indicate the  percentage of students from families with incomes below the poverty line  for each school that received improvement funds during the 3 school-year  time frame. In addition, we asked states to provide information on each  school that included (1) the school’s full name; (2) the school’s address,  city, and state; (3) the school’s district name; and (4) the school’s National  Center for Education Statistics (NCES) school identification; (5) the  school’s year of improvement under NCLBA: first year of improvement  (school choice), second year of improvement (school choice and  supplemental educational services), third year of improvement (school  choice, supplemental educational services, and corrective action), fourth  year of improvement (school choice, supplemental educational services,  and plan for restructuring), or fifth year of improvement (school choice,  supplemental educational services, and implementing a restructuring  plan); and (6) we asked states, if possible, to provide the amount of Title I  set-aside funds (and any other federal/state improvement funds, if  applicable) that each school received.
Three states were unable to provide this information, and 1 state provided  partial information, so our data on school characteristics are presented  only for those states that provided this information. We reviewed the lists  of schools receiving improvement funds for obvious inconsistencies,  errors, and completeness. When we found discrepancies, we brought them  to the attention of state officials and worked with them to correct the  discrepancies before conducting our analyses. On the basis of these  efforts, we determined that the data were sufficiently reliable for the  purposes of this report.
Our other two data sources were data from Education’s CCD and CSPR.  The CCD is a program of Education’s National Center for Education  Statistics that annually collects data from state education agencies about  all public schools, public school districts, and state education agencies in  the United States. At the time we began our analysis, the latest CCD data  available were from the 2005-2006 school year. Although we based our  analysis on schools in improvement in 2006-2007, the characteristics were  based on those of the prior year. To compare the characteristics of schools  that received improvement funds to those of all schools in improvement  and all Title I schools for 2005-2006, we used data from CSPR, which is the  required data tool for each state, the District of Columbia, and Puerto Rico  and contains lists of schools identified for improvement by state. The  CSPR also provides each school’s nationally unique identification number,  allowing us to link data on these schools with data provided in the CCD.  For our analysis, we excluded Puerto Rico, Arkansas, Florida, and North  Carolina because they could not provide information on which schools  received funds. In addition, we did not have complete information from  California because state officials provided a partial list of schools that  received funds. We compared schools in improvement from the CCD for  school year 2005-2006 with all other Title I eligible schools not identified  for improvement. We also compared states’ lists of schools in  improvement that received funds or services from the 2005-2006 CSPR  with lists of schools that were in improvement but did not receive funding  or services.
We performed a series of tests and took additional steps as needed to  assess the reliability of the data used. Specifically, we assessed the  reliability of the data by (1) examining the data for obvious  inconsistencies, (2) reviewing existing information about the data and the  system that produced them, and (3) interviewing agency officials  knowledgeable about the data. We determined that the data were  sufficiently reliable for the purposes of this report.
section_title: Site Visits
paragraphs: To understand school improvement funding and implementation at the  local level, we conducted site visits to 5 states and 12 districts and 22  schools within these states between April and October 2007. The states we  chose were California, Georgia, Michigan, New Mexico, and Ohio, which  were selected based on having high percentages of schools identified for  improvement, variation in Title I set-aside funding allocation methods and  administrative structures, and geographic diversity. We interviewed state  officials on states’ efforts to allocate federal and state school improvement  funds, provide assistance to schools identified for improvement, and  Education’s assistance to states.
Within each of the 5 states, we met officials from 2 school districts, and in  Michigan, we met with officials from 4 school districts for a total of 12  school districts, as shown in table 8. The 12 districts were selected to  provide variety in demographics, geographic location, and stages of  improvement.
During the site visits, we interviewed state and district officials as well as  officials representing 22 schools, including principals, teachers, and other  school staff involved with school improvement activities in order to  provide in-depth information and illustrative examples of our more general  findings.  The selected schools represented varying stages of  improvement, grade levels served, and locales.  While, in many cases,  district officials selected the schools we visited, we instructed state and  district officials to consider each school’s stage of improvement and  percentage of economically disadvantaged students, among other  characteristics.  Through our interviews with state, district, and school  officials, we collected information on school improvement funding, school  improvement activities being undertaken, and state and district assistance  to schools identified for improvement.
section_title: Education and Expert Interviews and Studies
paragraphs: To learn more about Education’s oversight of Title I school improvement  funds and efforts to assist states in implementation of school improvement  provisions, we conducted interviews with representatives of the offices of  Student Achievement and School Accountability Programs; Planning,  Evaluation, and Policy Development; Institute of Education Sciences;  Office of School Support and Technology Programs; and the Office of  General Counsel.
In addition, we interviewed experts on school improvement, including  those at the American Institutes for Research, Center on Education Policy,  Council of Chief State School Officers, and the National Governors  Association. We also reviewed several studies on school improvement  funding and activities.
section_title: Appendix II: Comments from the Department of Education
section_title: Appendix III: GAO Contacts and Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: Bryon Gordon, Assistant Director, and Laura Heald, Analyst-in-Charge,  managed the assignment. Cheri Harrington, Cara Jackson, Charlene  Johnson, and Nathan Myers made significant contributions to this report  in all aspects of the work. Shannon Groff and Ayeke Messam provided  assistance in data collection; Cathy Hurley, Stuart Kaufman, and Jean  McSween provided analytical assistance; Charlie Willson provided  assistance on report preparation; Sheila McCoy provided legal support;  Tina Cheng and Mimi Nguyen developed the report’s graphics; and Lise  Levie verified our findings.
section_title: Related GAO Products
paragraphs: No Child Left Behind Act: Education Should Clarify Guidance and  Address Potential Compliance Issues for Schools in Corrective Action  and Restructuring Status. GAO-07-1035. Washington, D.C.: September 5,  2007.
Teacher Quality: Approaches, Implementation, and Evaluation of Key  Federal Efforts. GAO-07-861T. Washington, D.C.: May 17, 2007.
No Child Left Behind Act: Education Actions May Help Improve  Implementation and Evaluation of Supplemental Educational Services.  GAO-07-738T. Washington, D.C.: April 18, 2007.
No Child Left Behind Act: Education Assistance Could Help States Better  Measure Progress of Students with Limited English Proficiency.   GAO-07-646T. Washington, D.C.: March 23, 2007.
Reading First: States Report Improvements in Reading Instruction, but  Additional Procedures Would Clarify Education’s Role in Ensuring  Proper Implementation by States. GAO-07-161. Washington, D.C.:  February 28, 2007.
No Child Left Behind Act: Education Actions Needed to Improve  Implementation and Evaluation of Supplemental Educational Services.  GAO-06-1121T. Washington, D.C.: September 21, 2006.
No Child Left Behind Act: Education Actions Needed to Improve Local  Implementation and State Evaluation of Supplemental Educational  Services. GAO-06-758. Washington, D.C.: August 4, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic  Growth. GAO-06-948T. Washington, D.C.: July 27, 2006.
No Child Left Behind Act: Assistance from Education Could Help States  Better Measure Progress of Students with Limited English Proficiency.  GAO-06-815. Washington, D.C.: July 26, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic  Growth That Education’s Initiatives May Help Address. GAO-06-661.  Washington, D.C.: July 17, 2006.
No Child Left Behind Act: Improved Accessibility to Education’s  Information Could Help States Further Implement Teacher Qualification  Requirements. GAO-06-25. Washington, D.C.: Nov. 21, 2005.
No Child Left Behind Act: Education Could Do More to Help States Better  Define Graduation Rates and Improve Knowledge about Intervention  Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005.
No Child Left Behind Act: Most Students with Disabilities Participated  in Statewide Assessments, but Inclusion Options Could Be Improved.  GAO-05-618. Washington, D.C.: July 20, 2005.
No Child Left Behind Act: Education Needs to Provide Additional  Technical Assistance and Conduct Implementation Studies for School  Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004.
No Child Left Behind Act: Improvements Needed in Education’s Process  for Tracking States’ Implementation of Key Provisions. GAO-04-734.  Washington, D.C.: Sept. 30, 2004.
No Child Left Behind Act: Additional Assistance and Research on  Effective Strategies Would Help Small Rural Districts. GAO-04-909.  Washington, D.C.: Sept. 23, 2004.
No Child Left Behind Act: More Information Would Help States  Determine Which Teachers Are Highly Qualified. GAO-03-631.  Washington, D.C.: July 17, 2003.