No Child Left Behind Act: More Information Would Help States Determine Which Teachers Are Highly Qualified
Released: 2003-07-17T00:00:00

Letter

Background

Recently, a body of research has shown that quality teachers are significant to improving student performance. For example, a 1996 study by Sanders and Rivers examined the effect of teacher quality on academic achievement and found that children assigned to effective teachers scored significantly higher in math than children assigned to ineffective teachers. Research has also shown that many teachers, especially those in high- poverty and rural districts, were not certified and lacked knowledge of the subjects they taught. For example, a report from The Education Trust found that in every subject area, students in high-poverty schools were more likely than other students to be taught by teachers without even a minor in the subjects they teach.

States are responsible for developing and administering their education systems and most have delegated authority for operating schools to local governments. States and local governments provide most of the money for public elementary and secondary education. In 2002, Education reported that 49 percent of the revenue for education was from state sources, 44 percent from local sources, and 7 percent from federal sources. Therefore, it is mostly state and local funds that are used to cover most of the major expenses, such as teacher salaries, school buildings, and transportation. Although the autonomy of districts varies, states are responsible for monitoring and assisting their districts that, in turn, monitor and assist their schools.

The federal government plays a limited but important role in education. The Department of Education’s mission is to ensure equal access to education and promote educational excellence throughout the nation by, among other things, supporting state and local educational improvement efforts, gathering statistics and conducting research, and helping to make education a national priority. Education provides assistance to help states understand the provisions or requirements of applicable laws, as well as overseeing and monitoring how states implement them. With the passage of the No Child Left Behind Act, on January 8, 2002, the federal government intensified its focus on teacher quality by establishing a requirement in the act for teachers across the nation to be “highly qualified” in every core subject they teach by the end of the 2005-06 school year.

While the act contains specific criteria for highly qualified teachers by grade and experience levels, in general, the act requires that teachers: (1) have a bachelor’s degree, (2) have state certification, and (3) demonstrate subject area knowledge for each core subject they teach. Table 1 lists the specific criteria by grade and experience levels as defined in the act.

For Title II, Part A of the act, Congress appropriated $2.85 billion to the Teacher and Principal Training and Recruiting Fund in fiscal year 2002—about $740 million more than states received in fiscal year 2001 under the previous two programs that it replaced—the Eisenhower Professional Development and Class Size Reduction programs. The purpose of the fund is to increase student academic achievement by providing support for states and districts to implement authorized activities cited in Title II to help them meet the requirement for highly qualified teachers. (See apps. II and III for state and district authorized activities.)

States had to complete an application in order to receive funds. All applications were due by June 2002, and states received the funds by August 2002. The funds were to be distributed according to the formula defined in the act. Specifically, states and districts received an amount equal to what they received for fiscal year 2001 under the two previous programs. The additional $740 million was distributed to states and districts based on the number of families with children ages 5 to 17 who had incomes below the poverty threshold and the relative population of children ages 5 to 17. The act requires states to ensure that districts target funds to those schools that have the highest number of teachers who are not highly qualified, the largest class sizes, or have been identified as in need of improvement.

To help states understand and implement the new law, Education took a number of actions. The department established a Web site, developed an application package for the formula grant program, issued draft guidance, and held informational conferences for states and districts. Figure 1 summarizes Education’s assistance to states.

In June 2002, Education issued draft guidance entitled “Improving Teacher Quality State Grants” which has served as Education’s principle form of assistance to states. In December of 2002, Education expanded and modified the draft guidance and issued final regulations on NCLBA that included some criteria related to the requirement for highly qualified teachers. Education does not plan to issue a final version of its draft guidance; instead, the draft includes the statement that it “should be viewed as a living document” that will be updated (1) as new questions arise, (2) if there is a change in the program statute that requires modification, or (3) when Education determines that more information would be helpful.

Many States Were Uncertain about Numbers of Highly Qualified Teachers

In-depth discussions with officials in 8 states revealed that they could not determine the number of highly qualified teachers with accuracy because of one or more factors. All state officials said they did not know the criteria for some of their teachers because Education’s draft guidance changed and was not complete. Officials also did not have all the information they needed to develop methods to evaluate subject area knowledge for their current teachers. Accordingly, officials in all of the states interviewed and nearly all surveyed said they needed complete and clear guidance before they could comply with the law. Most of the states we visited also did not have data systems that could track teacher qualifications by core subject taught, which they would have to do to ensure that teachers were teaching only those subjects for which they had demonstrated subject area knowledge. Finally, many state officials we visited were reluctant to say that their certified teachers might not be highly qualified.

States Did Not Have Complete or Consistent Criteria to Determine the Number of Highly Qualified Teachers

During our review, Education changed its criteria for teachers who were in alternative certification programs and it reissued the draft guidance to qualify only teachers in certain programs. The revised draft guidance stated that only those teachers enrolled in alternative certification programs with specific elements, such as teacher mentors, would be considered highly qualified. As a result, state officials had to recount this group of teachers by determining which alternative certification programs met the standard and then which teachers participated in those programs. In one state we visited, there were about 9,000 teachers in alternative certification programs and all were considered highly qualified until the revised draft guidance was issued. As of May 2003, an official said she was still trying to determine the number of teachers who were highly qualified.

Also during our review, state officials were uncertain about the criteria for special education teachers. The draft guidance that was available during most of our visits did not address special education teachers. As a result, state officials could not know, for example, whether a special education teacher teaching math and reading would have to demonstrate subject area knowledge in both or neither of the subjects. For school year 1999-2000, special education teachers represented about 11 percent of the national teacher population, so that, on average, state officials were unable to determine whether at least a tenth of their teachers met the highly qualified criteria. In some districts, special education teachers represented a larger portion of the workforce. For example, in one high- poverty urban district that we visited, special education teachers were 21 percent of their teachers. Education issued final Title I regulations on December 2, 2002, with an appendix that discussed the highly qualified requirements for special education teachers, among other things. However, the requirements are not discussed in the federal regulations nor are they discussed in the Title II draft guidance that was issued December 19, 2002. In addition, as of March 2003 some officials still had questions about the requirements. Perhaps because the guidance was issued in an appendix, it was not given the prominence needed to ensure that all officials would be aware of the information.

Furthermore, neither Education’s draft guidance nor its regulations provided more information than the law to help state officials develop methods other than tests to evaluate their current teachers’ subject area knowledge. The law allows states to use a “high, objective uniform state standard of evaluation” instead of a test. Education’s draft guidance repeated the language of the law, but provided no further interpretation. In addition, Education officials said they would review states’ implementation of this provision when they conduct compliance reviews and then determine if the state evaluation is in compliance with the law. State officials said they needed more information, such as examples, to be confident of what Education would consider adequate for compliance with the law. State officials prefer evaluations instead of tests, according to an official at the Council of Chief State School Officers (CCSSO), because they expect evaluations to be less expensive, more flexible, and more acceptable to teachers and unions. Such evaluations might be done through classroom observations, examination of portfolios, and peer reviews. In March 2003, CCSSO held a conference attended by about 25 state officials and several Education officials to discuss the implementation of state evaluations. At that conference, state officials said Education’s lack of specificity was particularly a problem for evaluating middle and high school teachers who had not demonstrated subject area knowledge. According to our survey data, 23 of 37 state officials said they would have difficulty fulfilling the highly qualified requirement for middle school teachers and 14 anticipated difficulty for high school teachers. According to district survey results, 20 percent anticipated difficulties in meeting the federal criteria for middle school teachers and 24 percent for high school teachers. Furthermore, as table 2 shows, a significantly higher percentage of high-poverty districts reported they would have greater difficulty fulfilling the requirement for teachers, especially at the middle and high school levels, than would low-poverty districts.

State officials from the 8 states we visited said they could not determine the number of highly qualified teachers because the draft guidance was changing, not clear, or incomplete. Most, 32 of 37, state officials responding to our survey said they needed clear and timely guidance to help them meet the law.

State Data Systems Did Not Track Federal Criteria

Officials from 7 of the 8 states we visited told us they did not have data systems that would allow them to track teachers’ qualifications according to the federal criteria by every subject taught. Officials in one state projected that it would take at least 2 years before the state could develop and implement a system to track teachers by the federal criteria. State officials we visited said since their state certifications had not required some teachers to demonstrate subject area knowledge as required in the federal criteria, their information systems did not track such information. In written comments to our survey, for example, one official said, “Questions are impossible to answer at this point because we not have finished the identification of those who need to be tested or evaluated.” Another respondent wrote that the data system “was designed years ago for state certification purposes… has not yet been updated to include all NCLBA criteria for teachers.” Other state officials also told us during our visits and through survey comments that their state certifications did not always require teachers to demonstrate subject area knowledge, so they did not have information on many teachers’ qualifications for this criteria. Another state official wrote, “ do not have data on teachers who were grand fathered in before 1991 or from out of state… who do not have subject matter competency.” Given the cost and time they thought it would take, some state officials expressed reservations about changing their data systems before Education provided complete guidance.

Some State Officials Reluctant to Report Teachers Not Highly Qualified

Officials in 6 of the 8 states visited were reluctant to report their certified teachers might not be highly qualified. Three of these officials equated their state certification with the federal criteria for a highly qualified teacher even though they differed. They expressed a reluctance to say that their state certification requirements did not produce a highly qualified teacher even though the requirements did not match all the federal criteria, such as demonstration of subject area knowledge. Additionally, state officials expressed concern about the morale of teachers who are state certified but who would not meet the federal criteria. They were also concerned about how teachers and unions would react to testing already certified teachers. For example, in 5 states we visited officials told us that the unions in these states objected to the testing of certified teachers.

State and District Officials Reported Many Conditions as Hindrances to Meeting the Law

Many state officials responding to our survey reported that teacher salary issues and teacher shortages were hindrances. State officials also identified other conditions such as few programs to support new teachers, lack of principal leadership, teacher training, and union agreements. District officials also cited teacher salary and teacher development issues as conditions that hindered them. Our district survey also shows that significantly more high-poverty districts reported some conditions as hindrances than low-poverty districts, and rural districts officials we visited cited hindrances specific to their small size and isolated locations. In our state survey, officials indicated that they needed more information from Education on professional development programs, best practices, and developing incentives for teachers to teach in high-poverty schools.

State Officials Cited Several Problems as Hindrances

Many state officials responding to our survey reported that pay issues hindered their ability to meet the requirement to have all highly qualified teachers. These issues included low salaries, lack of incentive pay programs, and a lack of career ladders for teachers. For example, 32 of 37 state respondents said low teachers’ salaries compared to other occupations was a hindrance. Officials we visited said that because of the low salaries it has been more difficult to recruit and retain some highly qualified teachers, especially math and science teachers. Several occupations are open to people with a bachelor’s degree in math and science, such as computer scientists and geologists. During the late 1990s, there was an increase in demand for workers with math and science backgrounds, especially in information technology occupations. Between 1994 and 2001, the number of workers employed in the mathematical and computer sciences increased by about 77 percent while the number of teachers increased by about 28 percent and total employment increased by about 14 percent. Furthermore, the math and science occupations have generally paid higher salaries than teaching positions. The U.S. Department of Labor’s Bureau of Labor Statistics data indicate that in 2001 average weekly earnings was $1,074 for mathematical and computer scientist positions and $730 for teachers. Some research shows that teacher salary is only one of many factors that influence teacher recruitment and retention. For example, the American Association of School Administrators explained the relationship between pay and working conditions in a report on higher pay in hard-to-staff schools. The report stated “How money matters becomes much clearer if salary is viewed as just one of many factors that employees weigh when assessing the relative attractiveness of any particular job, such as opportunities for advancement, difficulty of the job, physical working conditions, length of commute, flexibility of working hours, and demands on personal time. Adjusting the salaries upward can compensate for less appealing aspects of a job; conversely, improving the relative attractiveness of jobs can compensate for lower salaries.”

Many state survey respondents also cited teacher shortages as a hindrance. Specifically, 23 of the 37 state officials reported teacher shortages in high-need subject areas—such as, math, science, and special education. Additionally, 12 state officials reported a shortage in the number of new highly qualified teachers in subject areas that are not high need, and 12 reported that having few alternative certification programs hindered their efforts. Education experts have debated the causes and effects of teacher shortages. Some experts argue that the problem is not in the number of teachers in the pool of applicants but in their distribution across the country. Others argue that poor retention is the real cause of teacher shortages. As for alternative certification programs, they were established to help overcome teacher shortages by offering other avenues for people to enter the teaching profession. However, in 1 state we visited officials said the success of these programs had been mixed because the content and length of the programs varied and some alternative certification teachers were better prepared than others.

Although states have been facing teacher shortages in some subject areas for years, the new requirement for highly qualified teachers could make it even more difficult to fulfill the demand for teachers. The new law requires states to ensure that teachers only teach subjects for which they have taken a rigorous state test or evaluation, completed an academic major or graduate degree, finished course work equivalent to such degrees, or obtained advanced certification or credentialing in the subjects. Previously, states allowed teachers to teach subjects without such course work or credentials. From its Schools and Staffing Survey, the National Center for Education Statistics, within the Department of Education, reported that in 1999-2000, 14 to 22 percent of students in middle grades and 5 to 10 percent of high school students taking English, math, and science were in classes taught by teachers without a major, minor, or certification in the subjects they taught. Also, the report indicated that in the high school grades, 17 percent of students enrolled in physics and 36 percent enrolled in geology/earth/space science classes were taught by out-of-field teachers.

Some states also cited several other conditions that might hinder their ability to meet the requirement for highly qualified teachers. For example, 13 of the 37 state respondents reported few programs to support new teachers, and 9 reported large classes as hindrances. State respondents also cited work environment factors such as teacher performance assessments, a lack of principal leadership, and lack of school supplies and equipment as hindrances. See table 3 for more information on hindrances reported by state officials.

Additionally, 7 state officials who responded to our survey cited union agreements as a hindrance. Officials in 5 states that we visited said that the teachers’ unions objected to testing currently certified teachers for subject area knowledge, and officials in 2 of these states also said that current teachers might leave rather than take a test. An official representing the American Federation of Teachers (AFT), an organization that represents teachers, school support staff, higher education faculty and staff, among others, said that AFT supports the federal definition for highly qualified teachers and incentive pay for teachers in high-need subject areas and that certified teachers should have a choice between taking a test and having a state evaluation to determine subject area knowledge. The National Education Association, an organization with members who work at every level of education, issued an analysis of the NCLBA that identified several changes it believes should be made in the law, including clarifying the requirement for highly qualified teachers. The union officials we spoke with from 2 states we visited said they also support the requirement for highly qualified teachers but expressed concerns about how their states would implement the legislation. One state union official said the current state process for certification requires multiple tests—more than is required in the legislation—and the union is concerned that the state will collapse the testing and streamline the teacher preparation process as part of its changes to meet the requirement. The union official from the other state said that his union was concerned because the state’s approach for implementing the requirement for highly qualified teachers has become a moving target and this causes frustration for teachers.

School Districts Reported Hindrances Similar to Those Reported by States and More High-Poverty Districts Reported Certain Hindrances

School district estimates from our survey show that, similar to state respondents, salary issues hinder districts’ efforts to meet the requirement for highly qualified teachers. Almost 60 percent of district officials cited low teacher salaries compared to other occupations as a hindrance, with a significantly higher number of high-poverty than low-poverty district officials reporting this as a hindrance. During our site visits to 4 rural districts, officials said that their salaries could not compete with salaries offered in other occupations and locations. One official said that pay in the rural districts was low compared to teacher salaries in surrounding states. Both state and district officials also said that these salary conditions affect the recruitment and retention of highly qualified teachers.

Our survey estimates also show that conditions related to teacher development were hindering districts’ ability to meet the highly qualified teacher requirement. The conditions reported by districts included (1) weak training for teachers in the use of technology (28 percent), (2) few alternative certification programs (18 percent), and (3) professional development programs that are not of sufficient duration to improve teacher quality (23 percent). Weak training programs can leave teachers unprepared to deal with all the challenges of teaching and lead to job dissatisfaction. Table 4 provides estimates of the percentages of districts reporting conditions that hinder their ability to meet the requirement for highly qualified teachers.

While the ranking of most of the hindrances reported by districts and states were similar, three conditions were reported among the top third of hindrances for districts but among the bottom third for states. Specifically, these conditions were (1) alternative certification programs do not provide teachers with adequate teaching skills, (2) teacher preparation programs do not provide teachers with adequate subject matter expertise, and (3) training for teachers in the use of technology is weak. The first two of these conditions relate to programs that are usually responsibilities of the state departments of education. States or districts can address the third condition, technology training. These conditions indicate areas in which states and districts can work together to improve programs and help meet the requirement for highly qualified teachers.

A significantly higher number of high-poverty districts than low-poverty districts identified some conditions as hindrances. As table 5 shows, in addition to teacher shortages and pay issues, a larger percentage of high- poverty districts cited few programs to support new teachers and few alternative certification programs, among others, as hindrances to meeting the requirement.

During our site visits, officials from high-poverty districts told us they had great difficulty retaining teachers. For example, officials in one district said that although the district provided training for new teachers in the skills they needed, these teachers became more marketable after they completed the training and often left for higher paying teaching positions. According to these officials, the schools in this district did not always benefit from the district’s training programs. High-poverty district officials also said they could not compete with surrounding, wealthier districts in teacher pay. Officials in these districts and at the American Association of School Administrators also said that some unions do not support the use of incentive pay for high-poverty schools because they believe that salary scales should be equal for all schools within a district.

Rural district officials we visited and also those who provided survey comments said they faced unusual hindrances because some of them were very small, isolated, or had only one or two teachers in total at some schools. During our site visits, some officials from rural districts also said that they were facing teacher shortages because not enough teachers were willing to teach in rural districts. For example, one official in a large, rural state said that the state had only one university, which makes it difficult for teachers to obtain further course work to meet the federal criteria for subject area knowledge. Since many teachers in this state’s rural districts had to teach more than one core subject, with limited access to subject area training, they may not meet the highly qualified criteria for all subjects they teach. One survey respondent also wrote, “Rural schools have to assign teachers to several subject areas at secondary level. We do not have large numbers of students, and teachers have to wear more than one hat. Rural schools are also a long way from colleges and to require licensure in every subject they teach is ludicrous.” In a 2001 report to Congress, Education estimated that 84 percent of 4-year institutions would offer distance education courses in 2002. Such courses may help address this hindrance.

States Say They Need More Information from Education and Education Plans to Work with States on Some Issues

As districts work to address the conditions that affect their ability to meet the new federal requirement, they look to their state officials for guidance and technical assistance. In turn, states look to Education for help. Many of the hindrances that state and district officials reported related to conditions that they could address such as teachers’ salaries, the number of alternative certification programs, and certification requirements. However, states indicated they needed some additional information and assistance from Education. At least half of the 37 state respondents reported needing (1) information or other assistance to meet the requirement that professional development programs be based on recent scientific research and be of sufficient duration to have an effect on teacher quality, (2) information on best practices in the area of teacher quality, and (3) assistance in developing incentives for teachers to teach in high-poverty schools. Education’s 2002-07 strategic plan identifies several steps it will take to work with states. Specifically, the strategies listed under the plan’s goal for improving teacher and principal quality include supporting professional development in research-based instruction and encouraging innovative teacher compensation and accountability systems. Additionally, in December 2002, Education reorganized and established a new office to administer the Title II program.

To Help Teachers Meet the Requirement States Planned to Spend Most Title II Funds on Professional Development Activities, and Districts Will Spend Most on Recruitment and Retention Activities

To help meet the requirement for highly qualified teachers, state officials planned to spend most of their Title II funds on professional development activities, and district officials planned to spend a majority of their Title II funds on recruitment and retention activities. State and district officials planned to spend much larger amounts of other federal, state, and local funds than Title II funds on the activities authorized in the act. Generally, state and district officials told us they were continuing activities from previous years. The survey data also indicated high-poverty districts relied more on Title II funds for recruitment and retention activities than low- poverty districts. In addition, while the act requires districts to target their Title II funds to schools that meet certain criteria, until district officials know the number of highly qualified teachers and where they are located, they cannot fully comply with this requirement.

States Planned to Spend the Majority of Title II Funds on Professional Development

Generally, state educational agencies could use up to 2.5 percent of the state’s Title II funds for authorized state activities. Twenty-four state officials responding to our survey planned to spend about 65 percent of their Title II funds on professional development activities to develop and support highly qualified teachers and principals. For example, professional development activities could help teachers enhance their subject area knowledge and complete state licensing requirements to meet the criteria for highly qualified teachers. During our site visits, state officials described their professional development activities as seminars, conferences, and various instructional initiatives. For example, in one state we visited, officials planned to hold a workshop to provide middle and high school math teachers with technology training so that they could incorporate interactive Web sites in their instruction. Generally, state officials said they planned to use Title II funds to continue activities that were begun in previous years.

While professional development activities were to receive the largest share of funds, survey results show state officials planned to also spend Title II funds on other activities cited in the act. Officials in 28 states planned to spend about 18 percent on technical assistance activities, such as providing information about the requirement for highly qualified teachers to districts via the state Web site. Certification activities received the smallest percentage of Title II funds–2 percent. These activities include efforts to promote certification reciprocity with other states and efforts to establish, expand, or improve alternative routes for certification. (See fig. 2.)

Title II Funds Are a Small Part of Total Funds

State officials reported they planned to spend much larger amounts of other federal and state funds than Title II funds on nearly all of the authorized Title II activities. For example, states reported that 85 percent of the total funds they planned to spend on professional development activities would come from other federal and state funds. The one exception was technical assistance activities, where Title II funds accounted for 77 percent of the total. (See fig. 3.) Providing technical assistance to districts is an important role for states. In our visits to districts, several officials said they needed more information and technical assistance from their state to understand and implement the law.

Districts Planned to Spend a Majority of Their Title II Funds on Recruitment and Retention Activities

Districts received about 95 percent of their state’s Title II funds for authorized activities. Based on our survey, district officials planned to spend an estimated 66 percent of their Title II funds on recruitment and retention activities and 34 percent on activities related to professional development. Class size reduction activities were the largest funded recruitment and retention activity and accounted for 56 percent of total Title II funds. In a majority of our site visits we learned that district officials used these funds to hire additional highly qualified teachers to continue activities developed under the previous Class Size Reduction Program. Class size reduction activities may help improve teacher retention because, according to an Education report, teachers in small classes spend less time on classroom management and more time providing instruction, thus raising the teacher’s level of job satisfaction. While class size reduction activities can be seen as a retention tool, they may also increase the number of highly qualified teachers that need to be hired. This may be a problem for some districts and states. In fact, officials in one large state we visited said class size reduction activities presented a challenge by increasing the number of classes not being taught by a highly qualified teacher.

Additionally, district officials in our site visits said that they implemented or planned to implement a broad range of professional development activities. For example, one district had a teacher-coach program for its math and science teachers. This program used senior teachers as full-time coaches to assist less experienced teachers with instructional strategies and curriculum preparation. Other programs focused on math and reading, varied instructional strategies for different types of students, and use of technology. District officials in our site visits said most activities were in place prior to the act.

While all districts spent more on recruitment and retention activities than professional development, there were differences between high- and low- poverty districts. From our survey, we estimate that high-poverty districts planned to spend a significantly larger percentage of Title II funds on recruitment and retention and a smaller percentage on professional development activities than low-poverty districts. (See table 6.)

Districts Planned to Spend Larger Amounts of Other Funds and Title II Funds Are a Larger Percentage of Total for High-Poverty Districts

From our survey, we estimated all districts planned to spend much larger percentages of other federal, state, and local funds than Title II funds on authorized activities but in high-poverty districts the share of the funds was lower. Overall, 80 percent of the total funds districts planned to spend on professional development activities came from other federal, state, and local funds. Title II funds represented a larger percentage of total funds spent on authorized activities for high-poverty districts than low-poverty districts. For example, in high-poverty districts Title II funds were 48 percent of the funds they planned to spend for recruitment and retention activities compared to 15 percent in low-poverty districts. There may be several reasons for these differences. For example, Title II allocated more funds to those districts with more high-poverty families, and low-poverty districts may have had more local funds to contribute to the total. Figure 4 shows the Title II percentage of total funds for professional development activities and recruitment and retention activities, for all, high-poverty, and low-poverty districts. A majority of district officials said they planned to fund activities that were begun in previous years.

Approximately One-Third of All Districts Were Targeting Funds

We estimated about one-third of all districts (34 percent) were targeting their Title II funds as required by the act. The act requires districts to target funds to those schools (1) with the highest number of teachers who are not highly qualified, (2) with the largest class sizes, or (3) in need of improvement. There was little difference between the percentages of high- and low-poverty districts that targeted their funds or between urban and rural districts. For example, 29 percent of high-poverty districts and 30 percent of low-poverty districts reported targeting some of their Title II funds. Additionally, some district officials we visited said they did not target funds according to the criteria listed in the act but that they targeted funds in other ways such as to support math and science programs for teachers and for administrative leadership programs. It may be too early for district officials to fully implement this targeting requirement. Until they know the true number of teachers who are highly qualified, they cannot target the schools with the highest numbers of teachers who are not highly qualified.

Conclusions

Education officials have had to interpret and help states implement many new requirements established by the NCLBA, including the highly qualified teacher requirement. During this first year of implementation, state officials were still determining how they could assess whether their teachers met all the criteria and identifying steps they needed to take to meet the new requirement. Generally, state and district officials continued to be challenged by many longstanding hindrances and they continued to fund activities from previous years.

Education issued regulations and draft guidance to help states begin to implement the requirement for highly qualified teachers and has plans to help states with some of their challenges. However, state officials need more assistance from Education, especially about methods to evaluate current teachers’ subject area knowledge. Without this information state officials are unsure how to assess whether their current teachers meet the highly qualified requirement. This would also help them accurately determine the number of teachers who are highly qualified and take appropriate steps, such as deciding on which activities to spend Title II funds and targeting Title II funds to schools with the highest numbers of teachers who are not highly qualified. It is important that states have the information they need as soon as possible in order to take all necessary actions to ensure that all teachers are highly qualified by the 2005-06 deadline.

Recommendation for Executive Action

In order to assist states’ efforts to determine the number of highly qualified teachers they have and the actions they need to take to meet the requirement for highly qualified teachers by the end of the 2005-06 school year, we recommend that the Secretary of Education provide more information to states. Specifically, information is needed about methods to evaluate subject area knowledge of current teachers.

Agency Comments and Our Evaluation

We received written comments on a draft of this report from Education. These comments are reprinted in appendix IV. In response to our recommendation related to requirements for special education teachers, Education stated that the appendix of the Title I Final Regulations clarifies how the highly qualified requirements apply to special education teachers. Consequently, we modified the report to reflect this information and we withdrew this recommendation.

Education indicated it plans to take steps to address our recommendation on the need for information about methods to evaluate subject area knowledge of current teachers. Education stated that it will continue to work with state officials and will actively share promising strategies and models for “high objective uniform State standard of evaluation” with states to help them develop ways for teachers to demonstrate subject area competency.

Also, Education commented that it views a “one–size fits all” approach to addressing many of the issues raised in the report as undesirable because states and districts will have to meet the requirement highly qualified teachers in a manner that is compatible with their teacher certification, assessment and data collection processes. Education stated that it will provide assistance wherever possible to help states meet the requirement. We generally agree that this is an appropriate approach.

Additionally, Education provided technical comments and we made changes as appropriate.

We are sending copies of this report to appropriate congressional committees, the Secretary of Education, and other interested parties. Copies will be made available to other interested parties upon request. In addition, the report will be available at no charge on GAO’s Web site at http://www.gao.gov. If you have any questions about this report, please call me at (202) 512-7215. Key contributors are listed in appendix V.

Appendix I: Scope and Methodology

In conducting our work, we administered a Web survey to the 50 states and the District of Columbia, and a separate Web survey to a nationally representative sample of 830 school districts, that included strata for high- poverty, low-poverty, rural, and urban districts. The response rate for the state survey was 71 percent and for the district survey 62 percent. The surveys were conducted between December 4, 2002, and April 4, 2003. We analyzed the survey data and identified significant results. See figure 5 for a geographic display of responding and nonresponding states.

The study population for the district survey consisted of public school districts contained in the Department of Education’s Core of Common Data (CCD) Local Education Agency (LEA) file for the 2000-2001 school year. From this, we identified a population of 14,503 school districts in the 50 states and the District of Columbia.

Sample Design. The sample design for this survey was a stratified sample of 830 LEAs in the study population. This sample included the 100 largest districts and a stratified sample of the remaining districts with strata defined by community type (city, urban, and rural) and by the district’s poverty level. Table 7 summarizes the population, sample sizes, and response rates by stratum.

Estimates. All estimates produced from the district sample in this report are for a target population defined as all public school districts in the 50 states and the District of Columbia for the 2002-03 school year. Estimates to this target population were formed by weighting the survey data to account for both the sample design and the response rates for each stratum. For our estimates of high- and low-poverty districts, we defined high-poverty districts as those with participation rates in the free and reduced meals program of 70 percent or above. Low-poverty districts were defined as those with free and reduced meals program rates at 30 percent and below. One of the advantages of this approach was that it allowed for a sufficient number of cases in each category to conduct statistical analyses.

Sampling Error. Because we surveyed a sample of school districts, our results are estimates of a population of school districts and thus are subject to sampling errors that are associated with samples of this size and type. Our confidence in the precision of the results from this sample is expressed in 95 percent confidence intervals. The 95 percent confidence intervals are expected to include the actual results for 95 percent of the samples of this type. We calculated confidence intervals for our study results using methods that are appropriate for a stratified, probability sample. For the percentages presented in this report, we are 95 percent confident that the results we would have obtained if we had studied the entire study population are within plus or minus 10 percentage points of our results, unless otherwise noted. For example, we estimate that 34 percent of the districts target at least some funds to specific types of schools. The 95 percent confidence interval for this estimate would be no wider than plus or minus 10 percent, or from 24 percent to 44 percent.

Nonsampling Error. In addition to these sampling errors, the practical difficulties in conducting surveys of this type may introduce other types of errors, commonly referred to as nonsampling errors. For example, questions may be misinterpreted, the respondents’ answers may differ from those of districts that did not respond, or errors could be made in keying questionnaire data. We took several steps to reduce these errors.

To minimize some of these errors, the state and district questionnaires were each pretested three times to ensure that respondents would understand the questions and that answers could be provided. To increase the response rate, sampled districts received two calls encouraging them to complete and return the questionnaire.

We also performed an analysis to determine whether some sample-based estimates compared favorably with known population values. We performed this analysis for 12 estimates providing information on students, teachers, number of schools, and administrators that covered major segments those groups. For example, we did an analysis on all full- time equivalent classroom teachers but not on teachers of ungraded students, which is a very small proportion of all teachers. We used these values for the 511 sample respondents to produce sample estimates to the total population of all 14,503 districts. These estimated values, their associated 95 percent confidence intervals, and their true population values are presented in table 8.

For 11 out of the 12 estimates we examined, the population value falls within the 95 percent confidence interval for the estimate, thus providing some indication that respondents to this survey reflect the 12 characteristics we examined in the population. Although these characteristics were selected because they might be related to other characteristics of district teachers and district administration, we do not know the extent to which the survey respondents would reflect the population characteristics for the specific questions asked on our survey. For example, we are not certain whether districts responding to the survey were further along in the implementation of Title II requirements than the districts that did not respond.

Our sample was not designed to produce geographical area estimates, and we did not explicitly stratify our sample by state or region. However, our sample was selected nationally and all regions are represented in our sample. The following table summarizes sample size and responses for 10 regions.

On the basis of the national distribution of our sample and on the result of our comparison of a set of survey estimates to known population values from the CCD file, we chose to include the survey results in our report and to produce sample based estimates to the total population of school districts in our study population.

We chose not to report the survey responses to questions asking about the number of highly qualified teachers because other information from the survey and our in-depth discussions with officials during our site visits indicated that the respondents could not accurately answer the question. For example, three of five officials who completed the survey but did not answer this question commented in the survey that they could not answer because they could not count the number of teachers. Additionally, one official who reported that 100 percent of the teachers were highly qualified and another who reported 94 percent, also commented that they were unable to count their teachers. During our site visits we learned that officials did not have know the criteria for some groups of teachers, did not have data systems to allow them to track teachers by class and therefore, could not accurately determine how many teachers were highly qualified.

Other Methodology

We also visited 8 states with a range of characteristics that might affect their meeting Title II requirement for highly qualified teachers. Those states were California, Connecticut, Illinois, Iowa, Maryland, North Carolina, Delaware, and Wyoming. We visited and interviewed officials in 2 districts in each state, one of which was a high-poverty district, and one school in each district. We interviewed Department of Education officials, and officials and representatives from several professional organizations. We also reviewed the legislation, the regulations, and guidance as well as related reports and other relevant documents. We conducted our work between July 2002 and May 2003 in accordance with generally accepted government auditing standards.

Appendix II: Activities on Which States Can Spend Title II, Part A Funds

Table 10 lists our summaries of the authorized activities on which states can spend Title II funds and shows the five categories we used to group them.

Appendix III: Activities on Which Districts Can Spend Title II, Part A Funds

Table 11 lists our summaries of the authorized activities on which districts can spend Title II funds and shows the two categories we used to group them.

Appendix IV: Comments from the U.S. Department of Education

Appendix V: GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

In addition to those named above, the following individuals made important contributions to this report: Susan Higgins, Anjali Tekchandani, David Garten, Joel Grossman, Richard Kelley, Mark Ramage, Minnette Richardson, Susan Bernstein, and Jeff Edmondson.