Special Education: Additional Assistance and Better Coordination Needed among Education Offices to Help States Meet the NCLBA Teacher Requirements
Released: 2004-07-15T00:00:00

Letter

Background

The No Child Left Behind Act of 2001, which reauthorized the Elementary and Secondary Education Act (ESEA), is designed to improve the education of all students and the quality of teachers. NCLBA requires that all teachers of “core academic subjects”—defined to mean English, reading or language arts, mathematics, science, foreign languages, civics and government, economics, arts, history, and geography—be “highly qualified.” To be highly qualified, teachers (1) must have at least a bachelor’s degree, (2) be certified to teach by their state, and (3) demonstrate subject matter competency in each core academic subject that they teach. A teacher’s options for demonstrating subject matter competency vary according to whether the teacher is new and the grade level being taught. New elementary school teachers must demonstrate subject matter competency by passing a rigorous state exam in the basic elementary school curriculum; new middle or high school teachers may establish that they are highly qualified by either taking a rigorous state exam or successfully completing a degree (or equivalent credentialing) in each core academic subject taught. In addition, NCLBA allows current teachers to demonstrate subject matter competency based on a “high objective uniform state standard of evaluation.” For example, under these uniform state standards, a combination of experience, expertise, and professional training could be used to meet the NCLBA subject matter competency requirements.

Education has issued guidance to states on how to apply NCLBA requirements to all teachers, including special education teachers. According to Education’s January 2004 guidance, special education teachers who provide instruction in core academic subjects, such as teachers in self-contained classrooms, are required to comply with the NCLBA subject matter competency requirements. In contrast, those special educators who do not provide instruction in core academic subjects, such as those who provide consultative services to highly qualified general educators, do not have to comply with the NCLBA teacher requirements. In addition, Education’s March 2004 guidance provided additional flexibility on the implementation deadline and competency requirements for some special education teachers. Specifically, the guidance stated that educators in eligible rural areas who are highly qualified in at least one core academic subject they teach would have 3 additional years to demonstrate subject matter competency in other academic areas. The guidance also states that teachers who provide instruction in multiple core academic subjects will be able to demonstrate their subject matter competency through one process under their states’ uniform standards, such as taking a single test that covers multiple core academic subjects.

IDEA is the primary federal law that addresses the unique needs of children with disabilities, including, among others, children with specific learning disabilities, speech and language impairments, mental retardation, and serious emotional disturbance. The law mandates that a free appropriate public education be made available for all eligible children with disabilities, ensures due process rights, requires an individualized education program (IEP) for each student, requires the inclusion of students with disabilities in state and district wide assessment programs, and requires the placement of students in the least restrictive environment. Under IDEA, states are required to establish special education teacher requirements that are based on the highest requirements in the state for personnel serving children and youth with disabilities.

Congress is considering including new special education teacher qualifications in the reauthorized IDEA. Under H.R. 1350, a new definition of “highly qualified,” as it refers to teachers, would be added with the same meaning as in NCLBA. In contrast, S. 1248 would add an extensive definition of “highly qualified” with respect to the qualification of educational personnel, while taking into account differences between special education and general education teachers. For example, under S. 1248, special education teachers who consult with secondary school core academic subject teachers for children with disabilities would need to be fully certified in special education and demonstrate the knowledge and skills necessary to teach students with disabilities, to be highly qualified. In addition, S. 1248 proposes to extend the deadline for meeting the highly qualified teacher requirements by 1 year—to school year 2006- 2007.

Two offices within the Department of Education are responsible for addressing special education teacher qualifications: the Office of Elementary and Secondary Education and the Office of Special Education Programs. The enactment of NCLBA significantly changed the expectations for all teachers, including those instructing students with disabilities. For example, states are now required to report on the qualifications of their teachers and the progress of their students.

OESE has assumed responsibility for developing policies for improving the achievement of all students and the qualifications of teachers. In addition, the office provides technical and financial assistance to states and localities, in part so they can help teachers meet the new qualification requirements. For example, in fiscal year 2003, OESE provided funding to state and local education agencies through its Improving Teacher Quality state grant program.

OSEP is responsible for providing leadership and financial resources to help states and localities implement IDEA for students with disabilities and their teachers. These responsibilities include awarding discretionary grants and contracts for projects designed to improve service provision to children with disabilities. In 2003, OSEP provided funding to 30 states through the State Improvement Grants program. OSEP also supports research on special education through centers such as the Center on Personnel Studies in Special Education.

All States Implemented at Least Two of Three NCLBA Teacher Requirements for Special Education Teachers

In the 2002-2003 school year, all states required that special education teachers have a bachelor’s degree and be certified to teach—two of the three NCLBA teacher qualification requirements—and half required special education teachers to demonstrate competency in core academic subjects, which is the third requirement. In the 26 states that did not require teachers to demonstrate subject matter competency, state-certified special education teachers who were assigned to instruct core academic subjects might not be positioned to meet the NCLBA requirements. In 31 states that offered alternative routes to teacher certification, certification requirements for alternative route and traditional teacher preparation program graduates followed a similar pattern, with half meeting two of three NCLBA teacher requirements.

Half of States Have Similar Teacher Requirements to NCLBA, but 26 States Did Not Require Special Education Teachers to Demonstrate Competency in Core Academic Subjects

Every state required special education teachers to hold at least a bachelor’s degree and to be certified by their states before teaching, according to our survey results and reviews of Education documents and state Web sites. States varied in whether they offered one or more types of teaching certificates for special educators. Specifically, 30 states established a single certification for special education teachers that covered kindergarten through 12th grade, according to survey respondents. The remaining 22 states offered two or more certifications. For example, some states offered different certifications for teachers of elementary, middle school, and high school students. In addition, some states certified special education teachers to serve students with specific disability categories such as hearing impaired and emotionally disturbed, and/or with broader disability categories, such as mild, moderate, and severe special needs. Finally, several states certified their special education teachers for specific instructional roles such as general special education teacher, resource room teacher, or collaborative teacher.

During the 2002-2003 school year, 24 states, the District of Columbia, and Puerto Rico required special education teachers to demonstrate some level of competency in the core academic subjects that they wished to teach at the time of their initial certification by having a degree or passing tests in the academic subjects that they wished to teach. Teachers in these states are better positioned to meet NCLBA’s teacher requirements. However, the level of competency required varied by state and in some cases may not meet NCLBA competency level requirements. The rest of the states did not have any such requirements. (See fig. 1.)

In states that did not have these requirements, the certified special education teachers who were assigned to instruct core academic subjects might not be positioned to meet the NCLBA requirements. To meet NCLBA teacher requirements, these teachers would need to demonstrate subject matter competency by the end of the 2005-2006 school year.

The extent to which special education teachers were required to meet NCLBA subject matter competency requirements depended upon their instructional roles, which could sometimes be difficult for prospective teachers to determine. Special education teachers often attained their certification prior to being hired by local school districts for specific grade levels, subjects, or instructional roles. Therefore, these individuals might not be positioned to meet NCLBA teacher requirements for their future instructional roles. Furthermore, any special education teacher who was assigned to teach a different subject from one year to the next might meet subject matter competency requirements one year but not the next. According to Education officials, these challenges are not specific to special education teachers and will require school districts to be more mindful of teacher qualifications, including subject matter mastery, when assigning teachers to various teaching roles.

Special Education Teachers from Programs Offering Alternative Routes to Certification Were Generally Required to Meet the Same Certification Requirements as Other Special Education Teachers

According to survey respondents, 31 states provided alternative routes to certification for prospective special education teachers. States have developed such routes to meet specific teacher shortages as well as to allow professionals in related fields to become teachers. The alternative routes to certification programs that we reviewed were generally administered by the state education agencies, often through institutions of higher education. However, this was not always the case: In Maryland, for example, one county contracted with Sylvan Learning Center and the New Teacher Project to provide its alternative route to certification program.

Most of the states that provided alternative routes to certification required that the graduates from such alternative route to certification programs fulfill the same certification requirements as graduates from traditional special education teacher preparation programs, such as having a bachelor’s degree and passing teacher licensing examinations. The primary difference between alternative route programs and traditional teacher preparation programs was the extent to which teaching candidates received practical teaching experience prior to attaining full state certification.

In general, prospective teachers in alternative route to certification programs were required to receive more practical teaching experience before being certified than were teachers in traditional programs. For example, candidates in an alternative route to certification program in Illinois were required to complete a 1-year mentored teaching internship, while most traditional certification programs for special education teachers required teaching candidates to complete a 9- to 18-week supervised student teaching assignment. This additional teaching experience has been required because individuals in some alternative programs have not received courses in pedagogy and instructional techniques. (See app. I for state special education alternative route to certification program contact information.)

State Officials Cited Several Factors That Affected the Implementation of NCLBA Subject Matter Competency Requirements for Special Education Teachers

State officials indicated that implementing the core academic subject competency requirements of NCLBA would be difficult and cited factors that have facilitated or impeded application of this requirement to special education teachers. State officials identified several key facilitators, including having funds available to dedicate to special educators’ professional development and having preexisting or ongoing efforts to develop subject matter competency standards for special educators. State officials and national education organizations’ representatives also cited several factors that impeded meeting the subject competency requirements, including uncertainty about how to apply the law to special education teachers in some circumstances, and the need for additional assistance from Education in identifying implementation strategies.

Availability of Professional Development Funds Was among the Factors Cited as Facilitating the Implementation of NCLBA Requirements

Survey respondents, as well as state officials and national education organizations’ representatives we interviewed, reported that the availability of professional development funding and the flexibility to use funds were essential in helping teachers meet the NCLBA subject matter competency requirement. For example, officials in 19 states reported helping special education teachers by allocating some of the states’ professional development money to financial aid for those seeking to enhance their knowledge in a core academic subject, such as by pursuing a degree. In addition, states can use their professional development funds to create alternative routes to certification. This could result in developing a cadre of special educators who would already have expertise in a core academic subject area.

Survey respondents described several state assistance initiatives that were designed to help special education teachers meet the subject matter competency requirements. For example, 17 survey respondents reported holding workshops for special education teachers on specific academic subjects, and a few states held review sessions to prepare teachers for states’ academic content exams. In addition, respondents from 7 states reported providing sample test questions to help teachers prepare for subject matter competency tests. Nineteen survey respondents reported that their states had established partnerships with institutions of higher education to develop and implement strategies to assist special education teachers. For example, Arkansas collaborated with state colleges and universities to develop dual-certification programs for special educators.

Officials we interviewed from 2 of 6 states said that they expected their uniform state standards of evaluation would make it easier for their experienced teachers to meet NCLBA subject matter requirements. Specifically, they asserted that these competency standards would allow states and territories to design alternative methods for evaluating teachers’ knowledge of the subject matter they teach, other than having a degree or passing subject matter tests in a core academic subject. According to officials in 2 of the 6 states we interviewed, their alternative methods of evaluating teachers’ subject matter competency would take into account both a teacher’s years of experience and factors such as participation in professional development courses. A few state officials and national education organizations’ representatives we spoke to commented that the flexibility to design alternative methods for evaluating teachers’ subject matter knowledge provided more options for making subject matter competency assessments of experienced special education teachers.

Uncertainty about How to Apply the Subject Matter Competency Requirement to Special Education Teachers in Different Instructional Roles Was One of Several Barriers Cited to Meeting the NCLBA Requirements

State officials we interviewed and surveyed reported being concerned about how difficult meeting the subject matter competency requirements might be for special educators providing instruction, given that their roles may require them to teach at multiple grade levels or multiple subjects. State officials told us that because of special educator shortages, special education teachers’ instructional roles might vary. For example, some special educators might not have to meet subject matter competency requirements when they were hired, but subsequently might have to meet subject matter competency requirements for one or more core academic subjects, depending upon their instructional roles. Education has issued guidance that says that teachers instructing core academic subjects must demonstrate subject matter competency. This guidance applies to all teachers, including special education teachers. However, Education officials told us that the assessment level of the student being taught was a consideration in determining the application of the NCLBA subject matter competency requirement. The inclusion of the assessment levels in determining how to apply the NCLBA requirements may explain some of state officials’ uncertainty regarding the application of the requirement to special education teachers.

About half of the state officials and national education organizations’ representatives we interviewed reported that states needed more assistance on how to implement NCLBA teacher requirements for their special education teachers. For example, some state officials from Oklahoma and South Dakota reported being uncertain how to apply the requirements to the unique situations in which special education teachers provide instruction. Officials in these states reported that they were unclear whether a teacher providing instruction in core academic subjects to high school age students who are performing at the elementary level would need to meet elementary or high school level subject competency requirements (See table 1 for examples of the application of NCLBA requirements to special educators’ instructional roles).

Officials from half the states we surveyed indicated that they did not believe the law provided enough flexibility for teachers to meet the subject competency requirements. A few state officials we interviewed, particularly those with a large percentage of rural districts, such as those in South Dakota and Arkansas, mentioned this perceived lack of flexibility as a key concern. In particular, these officials indicated that because their special education teachers often teach multiple subjects, they would have to attain multiple degrees or pass several subject matter tests to meet the subject matter competency requirement. Recent Education guidance issued after this survey was concluded gives states more time to help all teachers, including special education teachers who teach core academic subjects, in small, rural school districts, meet the requirements. Under this new guidance, teachers in eligible rural school districts, who are highly qualified in at least one subject, will have 3 years to become highly qualified in the additional subjects they teach.

State officials reported concerns about their states’ ability to meet the federal timelines for implementing the NCLBA teacher requirements for special education teachers. Officials from 32 states reported that the time frames were not feasible for implementing the requirements. This included 15 states that had established subject matter competency requirements for their special education certification. However, depending on the specific state certification requirements, teachers in these states may still be required to do additional work to meet the subject matter competency requirements of NCLBA. In addition, some state officials reported that their states were not positioned to meet federal deadlines because some institutions of higher education had not aligned their programs with NCLBA requirements. For example, officials in 31 states reported that that current special education teacher preparation programs hindered implementation of NCLBA requirements, primarily because these programs did not emphasize majors or concentrations in core academic subjects. Given these conditions, state officials, in 3 of the 6 states we visited, reported the need for additional assistance in identifying strategies to meet the timelines for meeting requirements. Education also noted that the challenge facing states is developing new mechanisms to make sure that all teachers of core academic subjects are able to demonstrate appropriate subject matter mastery.

Some state officials and national education organizations’ leaders also cited concerns that special education teachers currently teaching might leave the field rather than take exams or return to school to take the courses needed to demonstrate subject matter competency. Thirty-two survey respondents expressed concern that the potential flight of special education teachers would hinder efforts to implement the requirements.

Finally, state education officials reported uncertainty over how to reconcile requirements of the two laws that appear to be inconsistent and thus could impede implementation of NCLBA. These officials reported that they were unsure as to which act—IDEA or NCLBA—should take precedence in establishing personnel requirements for special education teachers. For example, under IDEA, a student’s IEP could require that he be taught mathematics at a functional level 3 years below his chronological age, and under IDEA a certified special education teacher would be qualified to provide this instruction. However, under NCLBA, a teacher might not be qualified to instruct this student without first demonstrating subject matter competency in mathematics. According to Education officials, the requirements would depend in part on the assessment level of the students being taught. At the same time, Education officials noted that NCLBA teacher requirements apply to all teachers, including special education teachers. As a result of this uncertainty, some of the state special education officials we interviewed and surveyed said that they had decided to wait for further guidance or assistance before beginning to implement any NCLBA requirements for special education teachers. Education officials reported that they were aware that some states had expressed uncertainty about how to implement NCLBA’s teacher requirements. Moreover, Education officials noted that states that wait for further guidance could hinder their special education teachers’ ability to meet the subject matter competency requirements by the end of the 2005-2006 school year.

Coordination among Education’s Offices Responsible for Educating Students with Disabilities Was Limited

Education has provided a range of assistance, such as site visits, Web- based guidance, and financial assistance, to help states implement the highly qualified teacher requirements. However, department coordination related to the implementation of NCLBA’s teacher requirements for special education teachers has been limited. OESE has taken the lead in providing this guidance, with support from offices such as the Office of General Counsel and the Office of the Secretary. OSEP played a limited role in these efforts. Further, departmental coordination among Education’s offices was limited with respect to OSEP’s involvement in other key teacher quality initiatives. Because of this, Education may not have been in a position to be fully apprised of how special education concerns could affect implementation of the NCLBA teacher requirements. However, Education officials told us that they included OSEP by contacting OSEP staff to clarify IDEA substantive issues. Further, Education officials told us they have recently added OSEP to the department’s teacher quality policy team. However, Education currently does not have plans to develop written policies and procedures for coordination among its offices.

Education Provided Assistance to States in Implementing the NCLBA Teacher Requirements

According to Education officials, OESE took the lead in providing assistance to states concerning the NCLBA teacher requirements, with some support provided by offices including OSEP, the Office of the Secretary, the Office of the Undersecretary, the Assistant Secretary of Elementary and Secondary Education, and the Office of General Counsel. One of OESE’s key efforts to provide technical assistance to states was the Teacher Assistance Corps initiative, which sent teams of experts to states to provide clarification and guidance on implementing NCLBA teacher requirements. According to Education, these teams have been responsible for sharing promising strategies, providing advice on compliance issues, and assisting state officials in setting and meeting teacher quality goals. The teams have also gathered feedback from states on their concerns about implementing the teacher requirements. Team members have included lead officials from OESE and general counsel, individuals with expertise on issues of concern to particular states, higher education representatives, and education officials from that state. Education officials told us that OSEP staff did not participate in these visits, but two state officials with expertise in special education participated in some visits.

OESE also offered states other types of assistance. OESE created a teacher quality newsletter, and the Office of the Under Secretary created and then updated the No Child Left Behind Toolkit for Teachers booklet, to help teachers understand the law in general, the highly qualified teacher requirements, and to explain which teachers need to meet the NCLBA requirements. However, while the tool kit provided detailed information pertaining to general education teachers, it provided limited information for special education teachers. According to OESE officials, the office had also been developing a Web site on promising practices for implementing the NCLBA teacher quality requirements and had plans to feature special education on the site. However, at the time of our interviews, OESE did not have a timeline for when this Web site would be available. Finally, OESE also provided financial assistance to states through Improving Teacher Quality state grants; states could use this financial assistance to help special education teachers meet NCLBA teacher requirements.

Education’s Internal Coordination on Special Education Teacher Qualification Issues Was Limited

The enactment of NCLBA significantly changed the expectations for all students and their teachers in the nation’s schools and increased the need for OESE and OSEP to coordinate their efforts. NCLBA covers to a greater extent than did previous educational legislation the groups that have historically been the primary responsibility of OSEP—students with disabilities and their teachers. Moreover, NCLBA established qualifications for all teachers, including special education teachers, who provide instruction in core academic subjects such as English, language arts, mathematics, and science.

As state education officials began implementing NCLBA subject matter competency requirements, they sought guidance from OSEP, their primary source of information on special education issues. However, OSEP officials told us that they had generally referred these officials to OESE or to the NCLBA Web site. OSEP officials told us that they were waiting until IDEA is reauthorized to develop their own guidance on special education teacher quality requirements. However, during this time NCLBA requirements applied to special educators teaching core academic subjects, and several state officials told us they needed clarification of the guidance on these requirements.

Coordination between OSEP and OESE has generally been limited. For example, OSEP commented on the teacher quality policies and initiatives that OESE developed, but generally was not involved in the initial development of these policies. Education officials told us that OSEP was included in the implementation of the teacher requirements, noting that they contacted this office to clarify IDEA substantive issues and that OSEP officials reviewed NCLBA guidance. OSEP did not participate in OESE’s Teacher Assistance Corps visits to states and generally was not involved in the analysis of the information that was collected from these visits. OESE officials told us that they did not believe that states would benefit from OSEP’s participation in these visits, because the focus of the visits was on meeting the NCLBA requirements, not IDEA requirements. In addition, Education told us that there were no written policies or procedures to assist OESE and OSEP in coordinating the development and implementation of its teacher quality policies for special education teachers. Finally, these officials did not indicate that Education was planning to develop such policies.

In March 2003, Education formed a teacher quality policy team under the auspices of the Office of the Under Secretary and included other key offices in Education such as the Office of the Secretary, the Office of General Counsel, and OESE. This team, run by OESE, has focused on NCLBA implementation related to teacher qualifications, and special education teacher issues have been among the topics most frequently discussed. OSEP was not a member of this team until April 2004, when Education officials told us that OSEP had become a part of the team.

Conclusions

NCLBA is a complex law with new requirements that hold states, districts, and schools accountable for ensuring that their teachers meet specific qualifications. Further, the law applies to all teachers, including special education teachers, resulting in states and districts having to reassess how they certify and assign special education teachers, as well as provide professional development geared toward helping teachers meet requirements.

State officials reported the need for assistance on how to meet NCLBA requirements, with Education also noting the need for states to have more information on strategies to meet requirements. Because half of the states do not have subject matter competency requirements as part of special education certification, these states in particular are challenged with developing strategies to help their teachers meet NCLBA requirements. Without additional assistance on such strategies, special education teachers may not be positioned to meet requirements by the end of 2005- 2006 school year. In addition, several state education officials cited the need for additional clarification on the application of the NCLBA subject matter competency requirement to special education teachers in special circumstances, for example those providing instruction to high school age students who are performing at the elementary level. Without additional assistance from Education to resolve state concerns related to special education teacher qualification issues, some states might not be able to determine how to focus their resources to ensure that their teachers meet the act’s requirements.

NCLBA covers to a greater extent than did previous elementary and secondary education acts the groups that have historically been the primary responsibility of OSEP—students with disabilities and their teachers. OESE has assumed primary responsibility for implementing NCLBA, including provisions applying to special education teachers. OESE has generally not relied on OSEP staff or information produced by OSEP to develop policy or guidance. Consequently, OESE may not have fully benefited from OSEP’s expertise to inform its NCLBA discussions on policies and guidance related to special education teacher issues and requirements. Although Education has recently added OSEP to its NCLBA teacher quality policy team, overall NCLBA coordination efforts among Education offices have not been formalized in writing to ensure appropriate and continuing involvement of these offices. As a result, the department may not fully address states’ needs for information and assistance on the implementation of NCLBA requirements for special education teachers.

Recommendations for Executive Action

To better address states’ concerns about their special education teachers being positioned to meet NCLBA teacher requirements, we recommend that the Secretary of Education provide additional assistance to states on strategies to meet the requirements and clarification of subject matter competency requirements for special education teachers.

To continue to improve policy development and technical assistance that Education’s offices provide to states on NCLBA requirements, we recommend that Education formalize in writing coordination efforts between OESE and OSEP. For example, such efforts could include defining how OSEP’s expertise and staff would be involved in developing NCLBA policies and guidance related to special education teachers and in providing technical assistance to states.

Agency Comments and Our Evaluation

We provided a draft of this report to Education for review and comment. In their comments, Education officials noted that they believed their guidance was clear but recognized that states were still struggling to identify strategies to meet requirements. Education officials provided new information in their comments on the draft that indicated improved coordination among those Education offices that are involved in NCLBA policy development and guidance. Consequently, we modified the report on both these topics to reflect Educations’ comments. Education officials also provided technical comments that we incorporated into the report where appropriate. Education’s comments are reproduced in appendix II.

Given the difficulties states are experiencing in implementing the law and the level of uncertainty reported by state officials, we believe that additional assistance needs to be provided by Education to help states implement the requirements. In Education’s comments, the department noted that states were having difficulty implementing NCLBA teacher requirements. Education officials highlighted assistance they provided and their willingness to provide additional technical assistance, depending on what states need. We believe Education could help states by identifying strategies to help states meet requirements, especially those states without subject matter competency requirements for their special education teachers. In addition, Education noted in its comments that guidance on how to apply the NCLBA subject matter competency requirement for special education teachers instructing high school age students functioning at elementary school levels was not different from guidance for all teachers. However, Education officials have also said that the assessment level of a student could be considered in determining how to apply the NCLBA teacher requirements. We encourage Education to provide assistance to explain the requirements, particularly as they relate to unusual circumstances involving varying student assessment levels. We have modified the report to reflect Education’s comments.

We continue to believe that improved coordination is needed. However, we modified the report to reflect Education’s recent addition of OSEP to its teacher quality policy team. We acknowledge Education’s effort in this regard and encourage the department to formalize its coordination policies by putting them in writing. We believe that formalizing coordination efforts will ensure that the different offices continue to be involved in developing NCLBA policies and guidance related to special education teachers.

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 on (202) 512-7215 if you or your staff have any questions about this report. Other contacts and major contributors are listed in appendix III.

Appendix I: Thirty-One States with Alternative Routes to Certification in Special Education during the 2002-2003 School Year

Appendix II: Comments from the Department of Education

Appendix III: GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

In addition to those named above, Emily Leventhal, Benjamin Howe, Ron La Due Lake, Luann Moy, Jean McSween, Bob DeRoy, Bryon Gordon, Behn Kelly, and Amy Buck made key contributions to the report.