K-12 Education: Selected States and School Districts Cited Numerous Federal Requirements As Burdensome, While Recognizing Some Benefits
Released: 2012-07-20T00:00:00

Letter

Background

Sources of Federal Requirements and Efforts to Reduce Burdensome Requirements

The statutes that create federal programs may contain requirements that recipients must comply with in order to receive federal assistance. In addition, when Congress enacts a law establishing a program, it may authorize or direct a federal agency to develop and issue regulations to implement it. Congress may impose specific requirements in the statute; alternatively it may set general parameters and the implementing agency may then issue regulations further clarifying the requirements. Most federal agencies use the informal rulemaking procedures described in the Administrative Procedure Act. Those procedures, also known as “notice- and-comment” rulemaking, generally include publishing proposed regulations for public comment before issuing final rules. Comments from the public, particularly parties that will be affected by the proposed regulations, can provide agencies with valuable information on the regulation’s potential effects. In addition to regulations, agencies also use guidance and other documents to provide advice and information to entities affected by government programs. When agencies issue guidance documents, the Administrative Procedure Act generally allows them to forgo notice-and-comment procedures. In addition, agencies must comply with other rulemaking requirements, some of which direct agencies to estimate the burden of proposed regulations or assess their potential costs and benefits (see table 1).

OMB performs many functions related to federal agency rulemaking. For example, under Executive Order 12866, OMB reviews agency rulemaking to ensure that regulations are consistent with applicable law, the President’s priorities, and the principles in executive orders. OMB also ensures that decisions made by one agency do not conflict with the policies or actions taken or planned by another agency and provides guidance to agencies. In 2003, for example, OMB revised guidelines for agencies to use when they assess the regulatory impact of economically significant regulations and provided guidance for how agencies can improve how they evaluate the benefits and costs of regulations.

Selected Federal Education Programs and Reporting Requirements

Title I of ESEA, as amended, provides funding to states and school districts to expand and improve educational programs in schools with high concentrations of students from low-income families. Title I funds may be used for instruction and other supportive services for disadvantaged students to increase their achievement and help them meet challenging state academic standards. To receive Title I funds, states must comply with certain requirements. For example, states must develop (1) academic assessments, to provide information on student achievement, and (2) an accountability system, to ensure that schools are making adequate yearly progress (AYP).

Education developed 20 indicators to implement these monitoring requirements. Examples of indicators include the percent of youths with IEPs who graduate with a regular diploma and the percent which drop out of high school. For more information on the priority areas and indicators, see Education’s web site on the IDEA Part B State Performance Plan and Annual Performance Report: http://www2.ed.gov/policy/speced/guid/idea/bapr/index.html, accessed June 19, 2012. receive federal funds from discriminating against students based on their race, color or national origin, sex, disability, or other characteristics.

Other federal agencies also administer grant programs and issue associated regulations with which states and school districts must comply. For example, USDA has issued regulations and guidance to states and school districts to implement the national school meals programs, which provide federal assistance to help provide nutritionally balanced reduced-price or free meals (breakfast, lunch, and snacks) to low-income students. These programs, in part, aim to address the adverse effects that inadequate nutrition can have on children’s learning capacity and school performance. In fiscal year 2010, almost 32 million students participated in the largest school meal program, the National School Lunch Program. The Healthy, Hunger-Free Kids Act of 2010revised some requirements for school meal programs, most notably by requiring USDA to update nutrition standards for meals served through the National School Lunch and School Breakfast programs.

Key Education Stakeholders and State and School District Officials Cited Many Federal Requirements as Both Burdensome and Beneficial

Consistent with Key Education Stakeholders, Officials in Selected States and School Districts Identified 17 Federal Requirements as Most Burdensome

Key education stakeholders we interviewed said many federal requirements related to ESEA Title I, IDEA Part B, or national school meals programs were burdensome to states and school districts. For example, representatives from the National Governors Association identified multiple federal requirements as burdensome, such as the requirement for school districts to spend 20 percent of their Title I allocation on specified school improvement activities, including Supplemental Educational Services (SES), and the requirement to provide Title I services on an equitable basis to eligible children attending private school. (See appendix I for a description, including the sources, of these requirements as well as all other requirements cited throughout our report.) Also, representatives from the Council of Chief State School Officers told us of a study they conducted in which they found that states must comply with numerous duplicative reporting requirements.Specifically, their study found that states are required to report over 200 data elements multiple times to Education through collections such as the ESEA Consolidated State Performance Report (CSPR), the IDEA Part B Annual Performance Report, and the CRDC. Representatives from other organizations we interviewed—such as the American Association of School Administrators, the Council of the Great City Schools, and the National Rural Education Association—identified other federal requirements as burdensome for states and school districts. These requirements include data collection and reporting requirements for IDEA Part B and monitoring of SES providers under ESEA.

Officials we interviewed in 3 states and 12 school districts reported 17 federal requirements as most burdensome, and many of these were the same requirements identified by key stakeholders. The 17 requirements included in this report met the following criteria: (1) they were identified as burdensome by more than one state or school district; (2) they could potentially impact all schools, districts, or states; and (3) they are mandatory requirements established by Congress or a federal agency. Of these 17 requirements, 7 relate to ESEA Title I, 3 to IDEA Part B, and 4 to the national school meals programs. For example, multiple state and district officials identified certain data collection and reporting requirements for IDEA Part B, referred to as the IDEA Indicators, as burdensome. Education uses these indicators to monitor states on key priority areas that are identified in the IDEA, such as ensuring that students with disabilities receive a free appropriate public education. The remaining 3 requirements relate to more than one federal grant program. For example, as required by the Federal Funding Accountability and Transparency Act of 2006 and OMB guidance, recipients of federal funds totaling $25,000 or more must report basic information on awards, such as the name and location of the entity receiving the award, and the award amount.

As shown in figure 1, state and district officials we interviewed described many ways in which the identified requirements were burdensome to them: complicated, time-intensive, paperwork-intensive, resource- intensive, duplicative, and vague. Officials characterized 16 of the 17 requirements as being burdensome in multiple ways. For example, officials told us that collecting data for the IDEA Indicators requires a significant amount of time and resources because of the volume of data reported. In addition, these officials said that Education routinely changes what data is collected, which one official noted resulted in costly modifications to state and local data systems.

All of the requirements identified by state and school district officials as most burdensome were characterized as being complicated, time- intensive, or both. Officials described 15 of the 17 burdensome requirements as complicated, but also identified some benefits, as illustrated by the following requirements:

SES provider approval and monitoring. Under ESEA Title I, for schools that do not make AYP for 3 years, school districts must offer SES, such as tutoring and other academic enrichment activities, from state-approved providers selected by the parents of eligible students. State educational agencies must approve SES service providers and develop, implement, and publicly report on standards and techniques for monitoring the quality and effectiveness of their services. To approve providers, states told us they process applications, develop lists of approved providers, and address complaints from applicants who were not approved. A state official said that monitoring providers can also be challenging. For example, the official said it is difficult to know which providers are effective and that it is unclear whether SES has resulted in improvements in student achievement. School district officials told us they also struggle with their responsibilities under these requirements. School districts must notify parents about the availability of services annually and enter into a service agreement with any approved provider selected by parents of an eligible student. Districts must work with providers selected by parents, which, according to one district official, is burdensome because the districts have no control over the services provided. The official said her district employs teachers to monitor the SES providers and that in some cases the district has had problems with providers. Another district official said some of the challenges his district faced include providers not responding to the district in a timely manner, not submitting timely invoices, and submitting poorly crafted student learning plans. In contrast, according to a 2008 report, most parents of children receiving SES are satisfied with those services, which may In addition, be because parents are able to select service providers.one official we interviewed said that a benefit of SES is that students receive extended learning time. However, officials indicated they would like certain improvements. For example, one district official indicated she would like more input into which providers to use and how to monitor the services provided.

IEP processing. Under IDEA Part B, for each eligible student with a disability, an IEP must be in place at the beginning of each school year. The IEP must be developed, reviewed, and revised in accordance with a number of requirements. For example, the IEP must include information about the child’s educational performance and goals, and the special education and related services that will be provided. The IEP team (consisting of, at a minimum, the parents, a regular education teacher, a special education teacher, a representative of the school district, and the child, when appropriate) must consider specific criteria when developing, reviewing, or revising each child’s IEP. Officials described this multistep process as complicated, in part because of unclear terms in the IEP paperwork. For example, an official told us that special education service providers on the IEP team often misinterpret questions on the IEP regarding the student’s performance and progress. Another form official said the paperwork required for an IEP meeting takes 2 to 3 hours to complete and the meeting itself takes another 2 to 3 hours. Although meetings can be consolidated or held via conference call, this official said that each of these time commitments takes away from classroom instruction time and provision of support services. Despite these challenges, IEPs provide benefits for students with disabilities. For example, one advocacy group noted that the IEP contains goals and includes progress reporting for parents so that the IEP team will know whether or not the child is actually benefiting from his or her educational program. Also, one district official we interviewed said that having IEPs online has allowed special education administrators to give immediate feedback to teachers and other special education service providers on changes to students’ educational needs. Other officials acknowledged that these requirements are designed to ensure that parental and student rights are protected, but believe those rights can be protected in a less-complicated way.

Officials described 13 of the 17 requirements as time-intensive. For example, officials said disseminating state and district report cards is time-intensive, and according to one official this is due to the large amount of time devoted to developing data for the reports and printing and mailing them. States and districts that receive ESEA Title I funds are required to disseminate annual report cards that include, among other information, student achievement data at each proficiency level on the state academic assessments, both in the aggregate for all students and disaggregated by specified subgroups. They also include information on the performance of school districts in making AYP and schools identified for school improvement, as well as the professional qualifications of teachers in the state.report cards can also include state-required information. To comply with these and other ESEA requirements, states maintain a large amount of student demographic and assessment data, which they use to provide information about the academic progress of students in the schools and districts. An official also noted that processes for collecting, verifying, and reporting these data take large amounts of state and local officials’ time and resources. In addition, these report cards can be quite long; one state official said report cards for districts in his state can be 20 to 30 pages in length. A district official we interviewed recognized that the information on state and district report cards is important to help inform parents about the academic performance of their children’s school. However, officials suggested ways to streamline the report cards, including that states and districts be allowed to distribute one page of data highlights along with a reference to where the full report is available publicly, such as online or in the school library. In its guidance on state and district report cards, Education stated that because not all parents and members of the public According to Education officials, state and district have access to the Internet, posting the report cards on the Internet alone is not sufficient to meet the dissemination requirement.

Several of the most burdensome requirements identified are reporting requirements, which state and district officials told us contained duplicative data elements. Specifically, officials said some data collections may require the same or similar data elements to be reported multiple times. For example, through the CSPR used for ESEA reporting as well as the Annual Performance Report used for IDEA reporting, states are required to report graduation and dropout rates for students with disabilities. Additionally, officials from eight school districts told us that the CRDC required them to provide data directly to Education that had previously been submitted to the state. Examples of data elements reported as duplicative by district officials include student enrollment; testing; and discipline, which includes suspensions and expulsions.

State and school district officials characterized other burdensome federal requirements as paperwork-intensive (7 of 17), resource-intensive (6 of 17), and vague (4 of 17). For example, officials said time distribution requirements, established by OMB,to these requirements, in order for state and local grant recipients to use federal funds to pay the salaries of their employees who perform activities under multiple grants, they must maintain documentation of the employee’s activities. One district said that IDEA funding is used to pay for teachers working directly with students with disabilities, but because these students are included in general education classrooms it is difficult to document exactly how much time is spent working with these students. Two officials we interviewed said that complying with time distribution requirements provided no benefit to them. Officials described requirements to administer academic assessments as resource-intensive due to the costs needed to establish and maintain appropriate data systems. However, one state official noted that, as a result of the requirements, assessment data on student performance can be provided immediately to teachers and administrators. Also, some officials said they are paperwork-intensive. According were uncertain about requirements to implement the Healthy, Hunger- Free Kids Act of 2010, because, at the time of our interviews, some of the requirements had not gone into effect.

States and School Districts Generally Do Not Track Their Costs to Comply with Federal Requirements, According to Those We Interviewed

According to key stakeholders and state and school district officials we interviewed, states and districts do not generally collect information about the cost to comply with federal requirements. Stakeholders we interviewed said there were many reasons that states and school districts generally do not collect data on compliance costs. For example, some stakeholders told us most states and districts do not have the capacity to track spending on compliance activities. In addition, three stakeholders told us that school districts often have difficulty determining whether requirements are federal requirements or state requirements, and may not be able to separately track costs associated with federal requirements.

Information provided by the states and school districts we interviewed was generally consistent with views from these key stakeholders. Specifically, state and school district officials we interviewed said they do not collect information about the costs their agencies incur to comply with federal requirements, for a variety of reasons, including: (1) capacity limitations, such as limited staff and heavy workloads; (2) states and the federal government do not require them to report it; (3) it is too burdensome to collect the information; and (4) the information is not useful for improving student achievement or program administration and evaluation (see figure 2). When we asked state and district officials whether they could provide cost estimates on one requirement, most of them said they were unable to do so, and the estimates that were provided did not meet our criteria to include in the report.

Federal Agencies Are Taking Steps to Reduce Burden, but Potentially Duplicative Reporting Requirements and Statutory Limitations Remain

Federal Agencies Developed Plans, Offered Waivers, and Streamlined Other Processes to Reduce Burden on States and School Districts

Education and USDA developed plans, known as retrospective analysis plans, to identify and address burdensome regulations, as required by Executive Order 13563. The order required agencies to develop plans to periodically review their existing significant regulations and determine whether these regulations should be modified, streamlined, expanded or repealed to make the agencies’ regulatory programs more effective or less burdensome. Consistent with the order’s emphasis on public participation in the rulemaking process, OMB encouraged agencies to obtain public input on their plans and make their final plans available to the public. Education’s final plan, issued in August 2011 discussed its efforts to reduce the burden on states and school districts and identified a preliminary list of regulatory provisions for future review, including IDEA reporting requirements, which were mentioned as burdensome by several stakeholders and state and school district officials we interviewed.

Based on their review, Education officials told us they planned to consolidate several separate IDEA Part B data collections and include them in EDFacts beginning in October 2012. Education also said it would survey departmental program offices to ask program personnel to identify requirements they consider to be burdensome. However, department officials told us this survey has been delayed due to other priorities within the department, and they now expect to administer it in the fall of 2012.

20 U.S.C. § 7861. ESEA authorizes the Secretary of Education to waive, with certain exceptions, any statutory or regulatory requirement of ESEA for states or school districts that receive ESEA funds and submit a waiver request that meets statutory requirements. Under the ESEA, waivers can be effective for up to 4 years, although they may be extended. Education currently offers waivers from 10 ESEA provisions, including the timeline for 100 percent proficiency on state assessments and implementation of school improvement requirements. States that choose to apply must request waivers from 10 provisions and may choose to request waivers from an additional 3 provisions. For more information on the waivers, see http://www.ed.gov/esea/flexibility accessed June 19, 2012. distinguishes high-performing districts and schools from those that are lower-performing; and 3. commit to create and implement teacher and principal evaluation and support systems that will be used to continually improve instruction and assess performance using at least three performance levels.

After receiving and reviewing waiver requests, Education approved waivers for 19 states, and, as of May 2012, was reviewing the requests of 17 other states and the District of Columbia. The waivers are generally for a 2-year period, beginning in the 2012-2013 school year. The waivers may be extended, but Education has not specified the length of time an extension would be in effect. Of the three states included in our review, Education has approved requests from Massachusetts and Ohio and, as of May 2012, is considering one from Kansas. ESEA waivers may address some requirements officials and stakeholders identified as burdensome. For example, as a result of obtaining a waiver, Massachusetts will no longer require that school districts implement SES requirements. These exemptions are beneficial only to states which receive a waiver; states not approved for waivers must still comply with ESEA requirements. According to Education officials, the waivers may provide relief to many school districts by reducing certain reporting requirements and requirements to provide SES, among other provisions. However, we believe it is too soon to know whether states and school districts will encounter difficulties in implementing these waivers or what the ultimate benefits may be in terms of reducing regulatory burden. In prior work we reported that states faced challenges implementing multiple reforms and, as a result, some reform efforts have been delayed.Similar to these other efforts, states with ESEA waivers may face challenges taking the steps needed to implement the required principles.

As stated in its retrospective analysis plan, USDA implemented the direct certification process, which streamlined the approval process for free school meals. Direct certification is a means to determine a child’s eligibility for free school meals based on whether the child receives benefits through the Supplemental Nutrition Assistance Program, among other criteria. For example, students from families who receive nutrition assistance through this program are eligible for free school meals without completing the school meals application. In addition, in January 2012, USDA issued a final rule implementing revisions to nutrition standards required by the Healthy, Hunger-Free Kids Act of 2010 that contained changes from the proposed rule. Among the provisions that may assist school districts in implementing the new requirements, the final rule gives school districts more time to make changes to school breakfast menus. In addition, in accordance with legislation passed in 2012, USDA removed a proposed limit on the amount of starchy vegetables that could be served. As a result of these and other changes and lower estimates for the cost of food, USDA estimates the cost of complying with the new rule will be about $3.2 billion over the next 5 years, instead of the $6.8 billion cited in the proposed rule.

77 Fed. Reg. 11,778 (Feb. 28, 2012).

Education, to reduce the burden of time distribution reports that school personnel must complete. According to Education, states, districts, and other stakeholders have repeatedly identified time distribution reports, required by OMB, as a source of administrative burden. Education officials told us they solicited feedback from stakeholders as they were designing this initiative. While the OMB notice did not include a timeline for this pilot, Education officials told us they expect to issue a notice to invite states and school districts to participate in the pilot later in 2012.

Education Has Taken Some Action to Remove Duplicative Reporting Requirements, but Generally Disagrees with Stakeholders About the Extent to Which Duplication Exists

Education has taken some action to address duplicative reporting requirements. For example, department officials removed items from the 2009-2010 CRDC that were already collected by the department under IDEA. According to Education officials, data on how students complete high school is no longer required in the CRDC, because Education already collects that information through its EDFacts data collection. Education officials also told us of an effort to consolidate district-level ESEA and IDEA reports and implement single file reporting in the 2011- 2012 school year. In an effort to reduce duplicative reporting by school districts, Education officials said they proposed that states report data required by the CRDC on behalf of their districts. However, according to department officials, only Florida has done so.

Despite these efforts, department officials generally disagree with stakeholders and state and districts officials about the extent to which duplicative reporting requirements exist and the burden they impose. In its July 2011 letter to Education regarding the department’s preliminary retrospective analysis plan, the Council of Chief State School Officers wrote of its on-going concerns about such requirements in the CSPR, CRDC, and other data collections. The National Title I Association and the National Association of State Directors of Special Education expressed similar concerns to the department. When we discussed the issues raised in these letters with Education officials, they told us there are few duplicative reporting requirements and that the burden they impose is minimal. For example, states are to report the graduation rate for students with disabilities in the ESEA CSPR and the IDEA Annual Performance Report and possibly other reports. However, Education officials said states’ reporting these data twice, in their view, is not burdensome, because both reports use the same data. They also said that similar reporting requirements may be viewed as duplicative by state and district officials. For example, states are required to report not only a graduation rate for students with disabilities, but also a program completion rate, which includes students with disabilities who finish high school but do not graduate.completion data through another departmental data collection, the Common Core of Data. However, Education officials said these data are not duplicative, because they measure different ways students finish high school. We asked Education officials why, in response to comments they received on their draft retrospective analysis plan, they did not include a broader effort to identify duplicative reporting requirements in their final plan. In response, they said Executive Order 13563 (which required the department to develop the plan) focused on regulations and, as such, any reporting requirements based in statute would have been outside the scope of the order.

Education’s Ability to Address the Burden Associated with Some Requirements May Be Limited without Statutory Changes

Education may be unable to address certain burdensome requirements in the absence of legislative changes. These include, for example, certain requirements related to IDEA Indicators and transitioning preschool children with disabilities into IDEA Part B programs as well as requirements not addressed through ESEA waivers.

IDEA indicators. IDEA requires Education to monitor states and states to monitor school districts using indicators in each of three specified priority areas. In accordance with this requirement, Education has established 20 indicators under IDEA Part B. In October 2011, Education published a Federal Register notice seeking public comments on proposed changes to the IDEA Part B data collection. Education said it planned to eliminate two Part B indicators, since states report data on those indicators in other data collections. In response to the notice, several commenters recommended that the department eliminate many other indicators, but the department did not do so; among other reasons, the department said many of the indicators are required by the IDEA. In addition, Education withdrew other modifications it had proposed to the data collection in response to input that those changes would actually increase the burden on states and districts. Education may continue to make modifications to the IDEA data collection in future years. However, Education lacks authority to eliminate certain indicators on priority areas that are required by statute.

Transition of preschool students with disabilities from the IDEA Part C program to the IDEA Part B program. Every state that receives IDEA funds must have in effect policies and procedures to ensure that an IEP (or an individualized family service plan, if applicable) has been developed and is implemented by the third birthday for children participating in the IDEA Part C program who will transition into the IDEA Part B program. Two district officials told us that the transition requirements impose a burden on them, since there is no flexibility, even in the case of emergencies or other extenuating circumstances. Officials in one district told us that failure to comply with the requirement to have the IEP done by the child’s third birthday, by even one day, renders the school district out of compliance with this requirement. To comply with this requirement, officials in this district said that they begin the transition process with an assessment about 6 months in advance even though it would be better to assess the child as close to their third birthday as possible. (They explained that a child assessed when he or she is two and a half years old may need special education services, but, since children change more rapidly when they are young, it is possible they may not need services by the time they are three years old.) However, because the third birthday deadline is established by statute, Education lacks authority to provide exceptions to states and school districts.

Requirements not addressed through ESEA waivers. Several of the ESEA Title I requirements identified as burdensome by states and school districts are also required by statute. For example, the statute specifies certain information that must be included in state and district report cards and requires that school districts must spend 20 percent of their Title I allocation on SES and school choice-related transportation, unless a lesser amount is needed. Although Education does not have the authority to modify these statutory requirements, it has used its waiver authority to issue waivers exempting states and their districts from the SES and school choice requirements and from some of the state and district report card requirements. Other than offering these waivers, however, Education does not have the authority to change the underlying statute, so states and districts must still comply with the statutory requirements to the extent they are not covered by a waiver.

Conclusions

Recent government-wide initiatives have highlighted the need to reduce the burden faced by states and school districts in complying with federal grant requirements. While stakeholders and state and district officials generally agree that requirements are necessary to ensure program integrity, transparency, and fair and equal educational opportunities for all students, there is also acknowledgement that states and districts spend considerable time and resources complying with requirements. Education has taken some steps to alleviate burden on states and districts while, at the same time, ensuring these entities achieve program goals. Despite these efforts, additional in-depth analysis and greater collaboration among Education and key stakeholders is needed so that states and districts do not waste resources implementing overly complex processes or reporting data multiple times. Education can work with interested parties to identify requirements that can be modified or eliminated without affecting program integrity. Education cannot, however, change some requirements that states and districts find burdensome, because they are specified by statute. In these cases, statutory changes would be needed. Finding the appropriate balance between program goals and compliance can be difficult but maintaining requirements that are unnecessary and burdensome can hinder education reform efforts.

Recommendations for Executive Action

We recommend that the Secretary of Education take additional steps to address duplicative reporting and data collection efforts across major programs such as ESEA Title I and IDEA Part B as well as other efforts, such as the Civil Rights Data Collection. For example, Education could work with stakeholders to better understand and address their concerns and review reporting requirements to identify specific data elements that are duplicative. In addition, we recommend that the Secretary build on these efforts by identifying unnecessarily burdensome statutory requirements and developing legislative proposals to help reduce or eliminate the burden these requirements impose on states and districts.

Agency Comments and Our Evaluation

We provided a draft copy of this report to Education, USDA, and OMB for review and comment. Education’s comments are reproduced in appendix II. Education generally agreed with our recommendations. In particular, Education agreed that it should take additional steps to address duplicative reporting and data collection efforts that are not statutorily required and said it believes additional efficiencies can be achieved in its data collections. Education noted that some data elements are required under various program statutes and said it will work with Congress on reauthorization of key laws, such as the ESEA and IDEA, to address duplication or the appearance of duplication resulting from those requirements. Education also acknowledged the importance of collaborating with stakeholders whenever the department develops regulations, such as data reporting requirements.

Education and USDA provided technical comments on our report which we incorporated as appropriate. OMB did not have any comments on our report.

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If you or your staff have any questions about this report, please contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix III.

Appendix I: Description and Source of Requirements Identified as Burdensome by the State and School District Officials We Interviewed

Table 2 lists the 17 federal requirements identified as most burdensome by the officials we interviewed in 3 state educational agencies and 12 school districts. Requirements are grouped by program: Elementary and Secondary Education Act (ESEA) Title I, Part A; Individuals with Disabilities Education Act (IDEA) Part B; national school meals programs, including the National School Lunch Program and the School Breakfast Program; and other requirements related to the receipt of federal funds.

The summaries and cited provisions for each requirement represent the burdens described in our interviews; therefore they are not intended to be complete descriptions of each requirement. Additional provisions related to these requirements may apply. In some cases a requirement may have multiple sources, such as where statutory requirements are further interpreted in a regulation or guidance document.

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

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, the following staff members made important contributions to this report: Elizabeth Morrison, Assistant Director; Jason Palmer, Analyst-in-Charge; Sandra Baxter; Jamila Kennedy; and Amy Spiehler. In addition, Sarah Cornetto and Sheila McCoy provided extensive legal assistance. Jean McSween, Timothy Bober, Phyllis Anderson, and Kathleen Van Gelder provided guidance on the study.