Education of Homeless Students: Improved Program Oversight Needed
Released: 2014-08-22T00:00:00

Letter

Background

The Education for Homeless Children and Youth Program

The EHCY program is the key federal education program targeted to homeless children and youth, and, in school year 2011-12, more than 1.1 million were enrolled in our nation’s public schools, according to Education data. For purposes of the program, a homeless child or youth is one who lacks a fixed, regular, and adequate nighttime residence. This includes children who: are sharing the housing of others due to loss of housing, economic hardship, or a similar reason (commonly referred to as “doubled-up”); are living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations; are living in emergency or transitional shelters; are abandoned in hospitals; or are awaiting foster care placement; have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings; are living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings; and are migratory children who qualify as homeless due to their living circumstances, as described above.

Education’s Office of Student Achievement and School Accountability (SASA)—within the Office of Elementary and Secondary Education— provides EHCY formula grants to states, which must comply with certain requirements. For example, the McKinney-Vento Act requires each state that receives funds to establish an Office of Coordinator for Education of Homeless Children and Youths, with responsibilities that The state plan describes, among include carrying out the state plan.other things, procedures that will be used to identify homeless children and youth, strategies to address challenges, such as enrollment delays, and a demonstration of the state’s efforts to review and revise policies to remove barriers to the enrollment and retention of homeless children and youth. Among other responsibilities, state educational agencies report data to Education on the educational needs of their homeless students; provide technical assistance to school districts and monitor their compliance with the program; and facilitate collaboration between the state and other service providers that serve homeless children and youth and their families.

States are generally required to award no less than 75 percent of their grant to school districts on a competitive basis. Grants to school districts, awarded for a period of up to 3 years, are to be used for activities that facilitate the enrollment, attendance, and success of homeless children and youth in school. Grants to districts are to be awarded based on the need of the school district for assistance and the quality of the application submitted. In determining which districts to fund, states are required to consider certain factors, such as the needs of homeless children and youth enrolled in the school district, the types of services to be provided under the program, and the extent to which the services will be coordinated with other services available to homeless children and youth. Districts are authorized to use these funds to support a range of activities for homeless students, such as tutoring, transportation, and referrals to health care services, as well as to provide professional development for educators and support coordination between schools and other agencies. According to Education data, in school year 2011-12, fewer than a quarter of school districts nationwide (3,531 out of 16,064) received EHCY program funds; these districts enrolled 68 percent of the homeless students identified that year.

Education also allows states to use a regional approach to award their competitive grants. Through such an approach, according to the National Center for Homeless Education (NCHE), a state may provide funds to established regional educational entities, geographic clusters of school districts defined by the state, clusters self-selected by neighboring school districts, or some combination of these approaches. According to Education’s survey of states in school year 2010-11, the most recent survey data available, 16 states reported that they provided funds through an intermediate educational agency or consortia.

The “school of origin” is the school that the child or youth attended when permanently housed or the school in which the child or youth was last enrolled. 42 U.S.C. § 11432(g)(3)(G). In determining the best interest of a child or youth, a district must, to the extent feasible, keep a homeless child or youth in the school of origin unless doing so is contrary to the wishes of the child or youth’s parent or guardian. 42 U.S.C. § 11432(g)(3)(A)-(B). immediately enroll in the selected school, even without the records, such as proof of residency, typically required; and receive services comparable to those offered to other students for which they are eligible, such as transportation, educational services, and free school meals.

Other Federal Programs that May Also Support Homeless Children and Youth

Other programs administered by Education and other federal agencies, many of which receive more federal funding than the EHCY program, may also support the needs of homeless children and youth (see table 1 for selected examples). For example, under Title I, Part A of the Elementary and Secondary Education Act of 1965, as amended (ESEA), school districts are required to set aside funds as necessary to provide comparable services for homeless students who do not attend Title I schools. In addition, grantee school districts are required to coordinate with other organizations serving homeless children and youth, including those operating programs funded under the Runaway and Homeless Youth Act. The populations served by these programs vary, and for some programs, eligibility for services does not depend on being homeless. Among the programs that do target homeless populations, some use definitions of homelessness that are different from the one used by the EHCY program.

The McKinney-Vento Act also created the U.S. Interagency Council on Homelessness (USICH), which currently consists of 19 federal cabinet secretaries and agency heads. The Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009 established as the mission of USICH to coordinate the federal response to homelessness and create a national partnership at every level of government and with the private sector to reduce and end homelessness.

Selected School Districts Leveraged Existing Resources to Identify and Serve Homeless Students, but Faced Resource Limitations and Other Challenges

Selected School Districts Largely Relied on Enrollment Forms and Referrals to Identify Homeless Students, but Faced Challenges and Noted Problems with Under-Identification

To identify homeless students, officials in a majority of school districts (13 of 20) said their districts systematically requested some information on the housing status of new students using a form during the enrollment Two of these districts also requested housing information from process.every student every year to help identify eligible students whose housing circumstances may have changed following enrollment. According to the National Center for Homeless Education (NCHE), using a questionnaire at enrollment can help school districts increase their identification of homeless students (see fig. 1).

To identify students who were not identified at enrollment or whose housing status changed during the year, homeless liaisons in the 20 school districts we interviewed also relied on referrals from school staff or other service providers (see fig. 2). students who provide home addresses of shelters or other students; students who request transportation changes; students with attendance problems or who are tardy; students who fall asleep in class; and students with dropping grades, hunger, or hygiene issues.

Officials we interviewed also discussed the importance of training staff to identify homeless students, as identifying currently enrolled students is less systematic than identifying new students at enrollment.

Despite ongoing efforts to identify homeless students through housing surveys and referrals, officials in 8 out of the 20 districts we interviewed noted a problem with the under-identification of homeless students. All four state EHCY program coordinators we interviewed acknowledged that school districts face financial disincentives to identifying homeless children and youth due to the cost of services districts must provide.

Officials from both grantee and non-grantee districts reported facing significant challenges in identifying all eligible students.

Student Mobility

Officials in 11 of the 20 districts we interviewed said they identified increasing numbers of homeless children and youth in recent years, and many noted the frequent mobility of some students, making it challenging for school staff to keep track of their homeless students.

Confusion Regarding Applying Eligibility Requirements

Officials in 4 of the 20 districts said it was challenging to identify children and youth living doubled-up with others, particularly where living with extended family may be a cultural norm. In such cases, families may not consider themselves to be homeless or may be unaware of their rights to receive services under the program. For example, officials in one district told us that many of the district’s immigrant families who work for a local meat processor live with relatives in doubled-up conditions but do not consider themselves homeless. To help clarify program eligibility, one district we reviewed used its enrollment form to ask parents or guardians to check a box when they are “living ‘doubled-up’ due to economic emergency, not to save money or for cultural preference.”

Limited Information from Housing Surveys

In one school district we reviewed, the enrollment form asks parents or guardians to check a box “if the student is homeless or living in temporary/transitional housing,” and asks whether the student is an “unaccompanied youth,” but does not describe eligible housing situations. As a result, a student who is living doubled-up due to economic circumstances may not be identified, even though this situation represents a majority of homeless students nationwide (see fig. 3).

Nationally, according to Education’s survey of grantee school districts in school year 2010-11, homeless liaisons spent a median amount of nearly 2 hours per week on their responsibilities for the EHCY program. Many liaisons said that they juggled multiple responsibilities, including duties outside of the EHCY program. Officials in 7 of the 20 districts cited their limited availability to provide training and outreach or the lack of sufficiently trained school personnel as a challenge to identifying eligible students. In one state we visited the state EHCY program coordinator who surveyed homeless liaisons on the amount of time they spent on the EHCY program said she has found a link between the amount of time liaisons spend on the EHCY program and the number of homeless students they have identified.

Confusion Regarding Terminology

One liaison said there is confusion around “awaiting foster care placement,” a term used to describe some children and youth eligible for the EHCY program. Specifically, the liaison told us that she would receive requests for services for children in foster care, rather than for children awaiting foster care placement.among the district’s many military families, the term “transition,” sometimes used to describe eligible families, has a meaning unrelated to homelessness.

Stigma

Officials in 7 of the 20 districts said that stigma around being identified as homeless makes it challenging to identify eligible children and youth. One formerly homeless student we interviewed described her initial identification as very traumatic because she did not want anyone at school to know about her housing status and did not want to be called homeless. She said she would rather have received bad grades in high school than have her teachers know of her situation. Another said that she did not want anyone to know she was homeless but found it difficult to hide when she had to resort to “couch-surfing” in the homes of many different people.

Identification of Homeless LGBTQ Youth

Some officials we spoke with suggested the districts under-identify unaccompanied homeless youth, including lesbian, gay, bisexual, transgender, or questioning (LGBTQ) youth who tend to be overrepresented in the homeless youth population. Officials in five districts told us they are involved in efforts targeted to LGBTQ youth. For example, an official in one of these districts said the district has been involved in focus groups and worked with service providers on how to better identify and serve these youth who may have separated from their families due to their LGBTQ identification.

Fear of Government

Officials in 5 of 20 districts told us that some families fear being known to government entities, such as child protective services, police, and immigration services. For example, officials in one district said parents may be afraid that the child protective services agency will remove their children from their custody if they are discovered to be homeless.

Natural Disasters

Natural disasters, including floods and a hurricane that forced many families from their homes, also presented challenges for some districts we reviewed. To identify the large numbers of students displaced simultaneously in these districts, officials working in four of five districts we interviewed about their experiences with natural disasters relied heavily on staff and outside resources (e.g., shelters and community meetings). However, officials said that factors such as families’ unwillingness to self-identify and frequent mobility following the disaster created challenges to identifying and serving students. For example, officials in a district affected by heavy flooding said that immediately following the flooding, families moved in with relatives or other families and did not necessarily consider themselves to be homeless. However, as time passed, the district had to identify families in another wave as families again were displaced from where they initially had moved.

Under-identification can negatively affect homeless students’ ability to access needed services and to succeed in school. For example, according to a formerly homeless youth we interviewed, prior to being identified as homeless during his final year of school, he had been receiving Fs on his report card. After being identified, he received a bus pass, school supplies, and a laptop—necessary supplies to help him graduate. Although he faced significant pressures outside of school, according to a school official, and challenges completing his schoolwork, he graduated and was able to obtain employment. Another unaccompanied homeless youth said that after he was identified as homeless he received assistance with school work and clothing for an internship, and was very happy to be able to stay at the same high school. Some officials we interviewed noted that children and youth not connected to school or other services can be particularly challenging to identify, leaving them most at risk of failing to receive necessary services.

Selected School Districts Leveraged Resources to Serve Homeless Students, but Faced Resource and Coordination Challenges

Students experiencing homelessness have diverse needs, ranging from school-related to more basic needs. Nationally, grantee school districts in school year 2010-11 most frequently reported transportation to and from school, family or student preoccupation with survival needs, and frequent mobility from school to school as among homeless students’ greatest barriers to school enrollment, attendance, and success, respectively, Some officials according to Education’s survey of these school districts.we interviewed cited similar barriers. For example, a high school principal said that the most pressing need for homeless students in his school is for a safe place to sleep, and students who are worried about where they will sleep at night will not be focused on their studies. Some of the homeless youth we spoke with also indicated that stable housing or food were among their significant needs. Specifically, one unaccompanied homeless youth we interviewed—who has lived with a series of family members since leaving her mother’s home—said that while she currently sleeps on the couch in her uncle’s house, she worries every day about her next move as she does not know how long she will be allowed to stay.

To help address the needs of homeless students, grantee school districts in school year 2010-11 reported providing a variety of services, according to Education’s survey (see fig. 4).

Transportation

Officials we interviewed said their districts provided eligible students with transportation to and from school, as required by the McKinney-Vento Act, through means such as public transit, district buses, taxi cabs, gas assistance and mileage reimbursements. Officials in 9 of the 20 districts also said they collaborated with neighboring districts to transport homeless students across district boundaries, such as by splitting transportation costs or dividing responsibility for routes to and from school.

The Consolidated Appropriations Act, 2014 authorized school districts to use ESEA Title I funds to provide transportation for homeless students to their schools of origin. Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, div. H, tit. III, 128 Stat. 5, 388 (2013). school that the family had requested. While district officials did not think this was in the best interest of the child, officials said they did not think they could refuse to provide transportation due to the distance. Some district officials we spoke with also said coordinating transportation across districts can be difficult. For example, billing and being billed by other districts can be inefficient and problematic. A district transportation official we interviewed noted the significant amount of administrative work it takes to arrange a student’s transportation. For example, she said she could spend an entire day trying to figure out how to free up a bus driver to transport one homeless student to and from school when she also needs to worry about the transportation of another 500 students.

Coordinating Educational Services

Officials in the districts we interviewed coordinated with other education programs and districts to help address homeless students’ needs. For example, some districts used ESEA Title I, Part A funds to provide students with tutoring, uniforms, and funds for class fees, as well as hygiene kits, clothing and laundry vouchers, among other things. Officials in 7 of the 20 districts said these funds also supported salaries for positions that support homeless students, such as EHCY program staff, social workers and homeless student advocates. In addition, officials in some districts said they have coordinated with staff from special education programs to help facilitate services for homeless students; migrant education programs to help identify homeless migrant children; and in some instances, preschool programs to serve homeless preschool-aged children. Officials in 5 of the 20 districts said their preschool programs reserved spaces for homeless preschool-aged children or prioritized these students for services, and in four of these districts, officials said the district transported homeless preschoolers to and from school. Some officials also described coordinating with other districts. For example, officials in three districts said they coordinated with other districts to help homeless students obtain partial credit for work completed elsewhere but said that such efforts could be challenging. In one extraordinary case, we spoke with an official who said he worked for months to obtain a student’s transcript from an African refugee camp to be able to eventually verify the student had received 33 credits, exceeding the 22 necessary to graduate. According to a formerly homeless youth we interviewed, receiving credit for work completed was very important to help her meet graduation requirements as she moved across the country twice during high school and attended a total of four high schools.

Officials in 11 of the 20 districts we interviewed cited challenges due to limited staff availability or resources with which to serve homeless students and adequately address their needs. For example, a school principal in a K-8 school we visited without full-time counselors or support staff said homeless students there have access to about 30 percent of the support services the school would like to offer them. In another high school we visited, officials said there is a severe lack of resources at the school to support homeless students. Specifically, according to officials, teachers currently fund a “food closet” on nearly every floor of the high school to meet the needs of hungry students.

Partnering with Community Organizations

To expand their ability to serve homeless students’ needs, district and school officials also leveraged community resources to provide students with access to additional services and supports. For example, some officials we interviewed said that they referred homeless students or their families to organizations and agencies that provide health and mental health services, as well as to other community organizations, such as food pantries and shelters for students’ pressing needs. Officials in 6 of the 20 districts reported they assisted homeless youth in accessing public benefits, such as for health care or food. Officials in some districts also said they referred students to other federal programs, such as Head Start and Runaway and Homeless Youth (RHY) programs, and housing programs for services. In one district we visited officials said they improved referrals for services by developing trainings for an interagency committee comprised of various community stakeholders on resources and services available to homeless students. However, officials said that a lack of community resources affected their ability to meet student needs. For example, officials in a number of school districts we interviewed (9 of 20) said the lack of available or affordable housing options made it challenging to address the needs of homeless children and their families.

School districts also played an important role in addressing the needs of students displaced by natural disasters and maintaining their school stability. For example, in the immediate aftermath, officials we interviewed in one of five districts about their experiences with natural disasters said three schools were used as emergency shelters for families. Officials in four districts said they received a great deal of community support through donations—such as mattresses, heaters, food, clothing and supplies—to help address the significant needs of displaced students and families. However, officials also reported challenges in serving large numbers of newly identified homeless students, sometimes without additional funds for services. For example, one district without EHCY grant funds spent $750,000 to transport displaced students to and from school and to pay tuition to other districts where some students began attending school, according to officials. Maintaining contact with families through their moves was also a challenge for some officials we interviewed. In one district, officials said they were unaware of the number of students who have not returned to their school of origin or who plan to relocate permanently to where they went after the storm. In addition, officials in another district discussed the need for counseling following the trauma that students faced in fleeing and coping with a natural disaster.

Homelessness Following a Natural Disaster Three families we interviewed who were displaced from their homes following a hurricane—two of whom moved at least twice in the months following—told us of the important role their children’s school played in helping to address their many needs. In addition to transportation and school supplies, the school provided homeless families with free before- and after-school care for students, food, gift cards, and clothing—some of which were donated by other organizations, businesses, and school districts, within and outside the state. According to school officials, families were also offered counseling services, though meeting students’ needs for counseling has been a challenge. Officials described how children faced significant trauma following the storm. For example, one student carried a sibling on her back to escape rising floodwaters.

Federal and State Agencies Use Numerous Strategies to Collaborate to Improve Services to Homeless Students despite Barriers

The Federal EHCY Program Manager Collaborates with Officials from Other Education Programs, Federal Agencies, and States to Increase Awareness about Homeless Education

The federal EHCY program manager collaborates with officials from other Education programs, federal agencies, and states (see table 2). These collaborative efforts are designed to share information with other programs likely to serve homeless students and increase awareness about the EHCY program and the rights of, and services available to, homeless students, among other things. In addition, the EHCY program manager provides training and technical assistance to state program coordinators. GAO has previously found that collaboration is essential for increasing the efficiency and effectiveness of federal programs and activities in areas where multiple agencies or programs have similar goals, engage in similar activities, or target similar beneficiaries.

State Educational Agencies Collaborate with Other State Agencies, Service Providers, and School Districts

State EHCY program coordinators collaborate with other state agencies, service providers and school districts to improve services to homeless children and youth. The McKinney-Vento Act requires state EHCY coordinators to facilitate coordination between the state educational agency and other state agencies and to collaborate with school district homeless liaisons, service providers, and community organizations, among others. According to Education data from its survey of state EHCY program coordinators covering school year 2010-11, 30 state coordinators ranked coordinating with other organizations and agencies to provide and improve services to homeless children and youth among Thirty-six state the three activities on which they spend the most time.coordinators reported that building programmatic linkages among various programs, agencies, or organizations was among the top three collaboration efforts that improved program administration and/or services to homeless children and youth (see fig. 5).

The collaborative activities state EHCY program coordinators engage in may vary depending on whether they are collaborating with school districts, other programs, interagency councils, or non-governmental entities (see fig. 6).

State EHCY program collaboration activities with other state agencies, programs, service providers, and associations have included raising awareness of the program, developing joint products, such as strategic plans, and efforts to better connect students to services. For example, state EHCY program staff in one state told us they collaborate with the state’s health department and Children’s Health Insurance Program to make sure students have access to immunizations and help homeless families apply for health insurance for their children. Additionally, they collaborate with the state agriculture department to ensure homeless children have immediate access to free school meals. One state coordinator told us that she has partnered with the 21st Century Community Learning Centers (21st CCLC) program, which allowed the state to increase the number of high schools receiving 21st CCLC funding from 5 to 37 and increased the resources available to serve homeless students. In addition, three state coordinators we spoke with told us that they have worked with universities in their states to, for example, provide information about students experiencing homelessness and barriers they face to higher education. Officials in one state told us that this collaboration has led over 30 public institutions of higher learning to identify a single point of contact within the school to advocate for homeless students.

Federal and State Agencies Face Similar Barriers to Greater Collaboration

42 U.S.C. § 11432(f)(6). collaboration. For example, he only attends conferences for Title I and other Education programs every few years. Similarly, while state EHCY program coordinators we spoke with generally felt that there is significant collaboration with other entities, several also told us that staff capacity was a significant barrier to further collaboration. State coordinators are generally responsible for managing the EHCY grant process, monitoring and overseeing implementation of the EHCY program at the school district level, and providing technical assistance and training to school district personnel, including homeless liaisons; sometimes in several hundred school districts. Many state coordinators have responsibilities in addition to those for the EHCY program. According to Education’s survey data from school year 2010-11, 23 of the 50 state EHCY program coordinators reported working 30 hours or more per week on EHCY program responsibilities. The same survey found that more than half of the states (27) had one or fewer full-time employees working in the state EHCY program office (see fig. 7). For example, one state coordinator we spoke with was also the coordinator for another education program, which she said takes up about 40 percent of her time.

According to state EHCY program coordinators, resource constraints have prevented additional collaboration efforts. For example, three state coordinators told us they must choose which partners to collaborate with at the expense of others. In one of these states, this has meant limited collaboration with RHY programs. In GAO’s previous work, we have emphasized the importance of agencies identifying and leveraging sufficient funding to accomplish their objectives and to initiate or sustain their collaborative efforts and we suggested approaches to help them do so.

Federal and state officials also said that differing definitions of who is considered “homeless” under various federal programs was another barrier to collaboration. Because the population eligible for services under each program differs, the populations contained in data collected by one agency will be different than in data collected by other agencies, making data sharing more difficult. The federal EHCY program manager told us that the lack of a consistent definition across programs administered by Education and HUD has created a challenge to increasing data sharing at the local level between school districts and Because a relatively small number of Continuums of Care (CoC).students considered homeless under Education’s definition may be eligible for services funded by CoCs, these entities sometimes feel that the additional work necessary to share the data is not worthwhile, according to the EHCY program manager. Nationally, most homeless students are “doubled up.” Officials from one state told us that because this is the case in their state, though school districts want to provide wrap- around services that meet the wide variety of homeless youths’ needs, these students may be ineligible for services through HUD programs.However, one school district in one of the states we reviewed has entered into an agreement with the local CoC that allows school district personnel to access and enter data into the CoC’s Homeless Management Information System. This partnership allows the school district and CoC partners to track the services homeless students have received, evaluate the need for additional services, and make referrals for those services, among other functions. A state EHCY program coordinator we spoke with told us that a common definition would allow Education and HUD programs to pool data, increasing collaboration and efficiency. This official said that instead of redundant data collection, resources could be used to provide additional services.

Education Currently Lacks a Comprehensive Oversight Plan and Faces Limitations in Using its Performance Data to Assess Program Results

Education Has Protocols for Monitoring State EHCY Programs but Lacks a Plan to Ensure Oversight of All States

Education has protocols and procedures in place to monitor state EHCY programs. According to Education guidance, monitoring is the regular and systematic examination of a state’s administration and implementation of a federal education grant, contract, or cooperative agreement. To hold states accountable to provide a free appropriate public education to homeless students, Education evaluates the degree to which states meet certain standards, called monitoring indicatorsThese include data on: (see appendix II). monitoring of school districts; implementation of procedures to identify, enroll, and retain homeless students by coordinating and collaborating with other program offices and state agencies; provision of technical assistance to school districts; efforts to ensure that school district grant plans for services to eligible homeless students meet all requirements; compliance with statutory and other regulatory requirements governing the reservation of funds for state-level coordination activities; and prompt resolution of disputes.

Education’s monitoring involves a review of documents, followed by an on-site or videoconference review, and preparation of a final report that includes any compliance findings for which the state must take corrective action (see fig. 8). Between fiscal years 2007 and 2009, Education’s policy was to monitor 50 states and 3 other areas (i.e., 53 “states”)least once during that 3-year time period and it followed this policy.

Starting in fiscal year 2010, Education adopted a risk-based approach to select states for monitoring to more efficiently target and prioritize limited resources, resulting in longer gaps between monitoring visits in some states. Education conducts an annual risk assessment to evaluate which states have the highest risk of noncompliance, according to the EHCY program manager. The agency weighs the following four risk assessment criteria equally: the state’s academic proficiency levels for students experiencing homelessness, the tenure of the state EHCY program coordinator, whether there are multiple or recurring EHCY monitoring findings, and a financial review of the state’s EHCY grant expenditures.Education also considers the size of the state’s EHCY grant allocation and the length of time since a state was last monitored. Since Education adopted this approach in fiscal year 2010, it has monitored 31 of the 53 states for the EHCY program—28 from October 2009 to September 2012 and 3 from October 2012 to July 2014. Of the 22 remaining states, Education last monitored 7 states in fiscal year 2007, 6 in fiscal year 2008, and 9 in fiscal year 2009 (see fig. 9).

In the fall of 2012 Education began monitoring states that had received waivers from certain ESEA requirements under an initiative Education calls “ESEA Flexibility” and since that time, has monitored three states for compliance with the EHCY program. Under Education’s ESEA flexibility initiative, 44 of the 53 states currently have waivers from specific requirements of the ESEA, as amended. In these states, Education has conducted regular monitoring, but the monitoring only covers compliance with the ESEA waiver requirements and does not include monitoring for compliance with the EHCY program. As a result, the states with ESEA waivers currently have little EHCY program oversight at the federal level. Education officials cited the shift to a risk-based approach to monitoring the EHCY program, the more recent need to focus on ESEA flexibility waiver monitoring, and a lack of staff capacity as the primary reasons why they have not been able to monitor the states as frequently in recent years as in the past. Education officials said they intend to continue to monitor the EHCY program in the future, but the agency has not determined when or how it will do so. Standards for internal control emphasize the need for federal agencies to establish plans to help ensure goals and objectives can be met, including compliance with applicable laws and regulations. Absent a plan for future monitoring of grantees, Education cannot be sure that problems will be identified and resolved promptly.

As a result of reducing the number of monitoring visits, Education has been unaware of the compliance status of some states for an extended period of time. According to GAO’s Standards for Internal Control in the Federal Government, monitoring is a key management tool that helps agencies assess the quality of performance over time and ensure that the Additionally, one state EHCY program problems are promptly resolved.coordinator we interviewed said that federal monitoring ensures a higher level of compliance with the McKinney-Vento Act and that it is in a state’s best interest to be monitored regularly. According to this program coordinator, monitoring helps states improve how they address homeless students’ needs and provides important leverage within the state to ensure that program funds are used as intended. Of the 22 states that Education has not monitored since at least fiscal year 2009, 10 had been required to take corrective actions following their last review to address compliance concerns. While Education found these actions to be sufficient, according to officials, Education is currently unaware of whether these states have remained in compliance and it is possible that they (or other states) may have new or recurring compliance issues. For example, one of the states we visited had not monitored its grantees on- site since school year 2008-09, whereas NCHE recommends states monitor grantees on-site at least once every 3 years.

Under the McKinney-Vento Act, states are required to develop plans that describe how they will implement the program and submit the plans to Education. 42 U.S.C. § 11432(g). Education is responsible for reviewing state plans using a peer review process and evaluating whether state laws, policies, and practices described in the plan adequately address the problems of homeless children and youths relating to access to education and placement as described in the plan. 42 U.S.C. § 11434(a). updated their plans with new activities and goals. Some states have implemented programmatic changes since the plans were initially required in 2002. For example, one state we visited changed its service delivery model in recent years by adopting a regional approach to award grants to lead school districts that are responsible for providing services to other districts in their region. This state’s EHCY coordinator confirmed that the state has not submitted any state plan updates to Education since 2002. However, because Education is no longer consistently monitoring all states for compliance, the agency is also unable to determine whether states’ current practices are consistent with their existing state plan. GAO’s Standards for Internal Control in the Federal Government suggest that management continually assess and evaluate whether internal control activities—such as reviewing and monitoring compliance with state plans—are effective and up-to-date.

Education Survey Data and GAO’s Review Showed that States Generally Focused Their Monitoring on Grantee Districts and Not Non- Grantee Districts

The McKinney-Vento Act requires each state to describe in its plan how it will ensure that all school districts comply with EHCY program requirements, but does not specify how states must monitor compliance or where they should focus their efforts. NCHE’s guidance to states on monitoring districts acknowledges the challenge of monitoring all districts on site annually—given resource constraints—and recommends that states utilize a combination of strategies, such as on-site monitoring for grantee districts and desk monitoring, i.e., phone calls or written correspondence, for non-grantee districts. According to Education’s survey of states in school year 2010-11, states use a variety of approaches in monitoring districts. Most states (43 out of 50) monitored grantees on-site and about half (26 out of 50) did so for non-grantees. States also commonly use desk monitoring, with about two-thirds (34 out of 50) using this approach for grantees and about half (26 out of 50) doing so for non-grantees (see table 3).

The majority of states in Education’s survey also reported including the EHCY program in the state’s monitoring of other federal programs for both grantee districts (33 out of 50) and non-grantee districts (29 out of 50). States that monitor compliance for the EHCY program in this way are able to reach additional districts without adding to the state EHCY program coordinator’s responsibilities, one of a few strategies that NCHE recommends to cover a large number of districts. For example, in one state we visited, a review team monitors about 100 school districts per year with a lengthy checklist for federal programs that includes the EHCY program.

States focused their monitoring on districts that had received an EHCY grant from the state, resulting in limited oversight of many non-grantee districts. NCHE’s guidance indicates that states should monitor grantees at least once during the grant cycle—which can be up to 3 years—and non-grantees at least once every 3-to-5 years. According to Education’s survey, most states (39 out of the 46 that responded to this question) said that they monitor grantees at least once every 2 years. Half (23 out of 46) of the states that responded to this question reported monitoring non- grantees at least once every 2 years and the other half reported monitoring them less frequently (see fig. 10). Additionally, 2 of 50 states reported that they did not monitor non-grantees at all (see table 3).

Similarly, state EHCY program coordinators in three of the four states we reviewed focused on monitoring grantees and employed a variety of approaches, according to our interviews with the coordinators. One state coordinator reported monitoring all grantee school districts on-site annually. Two state coordinators reported monitoring grantees annually using a combination of on-site visits and desk reviews, in which grantees are monitored via phone and email and must send data to the state for review. The fourth state coordinator we interviewed reported conducting quarterly fiscal and program reviews in lieu of formal on-site or desk monitoring for all of the grantees since school year 2008-09.

The four states we reviewed also varied with regard to how often they monitor non-grantees. State coordinators in two of the four states we reviewed regularly monitor all non-grantee districts within the 3 to 5 year timeframe NCHE suggests. One state coordinator reported monitoring non-grantees on a 3-year rotational basis. Another state coordinator uses desk monitoring for all non-grantees annually and also uses a risk-based approach to select non-grantees for on-site monitoring. state coordinators we interviewed do not regularly monitor non-grantees within the suggested timeframe; however, one of these states annually ensures that all districts have identified a homeless liaison.

States may not focus monitoring efforts on non-grantee districts because they lack tools to enforce compliance. One state coordinator explained that the state can record a finding of noncompliance, but because there is no direct fiscal action or penalty attached to it, the district may disregard it. Another state coordinator said she has to accept a district’s report of zero homeless students, even if she suspects that the district may be under-identifying them. In contrast, state coordinators we spoke with said that states can hold districts with EHCY grant funding more accountable because they have more direct leverage over them, in the form of the grant. According to Education’s survey of states, 3 of 39 states that responded to this question reported that they withheld funds from grantees that were out of compliance.

This state’s EHCY program coordinator reported annually reviewing each district’s data on homeless students and visiting those non-grantees with the highest risk of noncompliance based on several risk factors, such as fewer than expected homeless students identified given a district’s poverty rates; trends in under-identification; a high number of disputes with neighboring districts and/or complaints from parents; and the size of the district, with larger districts assumed to have a higher risk of noncompliance. districts were aware of the availability of services through the regional structure adopted by the state. This state uses a regional approach for its grantee districts, whereby the grants are distributed to lead entities that are in turn responsible for ensuring that all homeless students within the region receive appropriate services. To do this, the grantee district may provide funds and/or services, such as training, to other districts in its region. While we met with two lead grantee school districts that provided services to other districts in the region, we also met with two other non- grantee districts whose officials were unaware that the district was eligible for funds or services from their respective lead grantee districts, indicating that the state’s regional model was not being implemented effectively. Such problems suggest inadequate state-level monitoring of school districts, reinforcing the importance of effective federal monitoring of states.

Education Collects Performance Data but Faces Limitations in Using Them to Assess Program Results

Education relies on annual state performance data collected from school districts to determine the extent to which states are meeting the program’s intended goal of ensuring that homeless students have access to a free appropriate public education (see table 4).

Education has increased the number of data elements it requires school districts, particularly non-grantee districts, to report in the Consolidated State Performance Report. For example, in school year 2010-11, Education began requiring states to report information on the academic achievement of homeless students in reading and mathematics from non- grantee school districts, data that had been required from grantee districts since at least the 2004-05 school year. In school year 2011-12, Education added corresponding data elements in science for all districts to the Consolidated State Performance Report. In school year 2012-13, Education began requiring states to report information on the number of homeless students enrolled in each district, by certain subcategories.Previously, Education had only required states to report this information by subcategory for grantee districts; for non-grantee districts, states were only required to report the total number of homeless students enrolled and their primary nighttime residence.

Education presents trends in data on homeless students over time in its Consolidated State Performance Report; however, there are limitations to the use of state-reported data to assess the program’s results. For example, the state data on the number of homeless students are likely incomplete or unreliable due in part to the under-identification of eligible students. In Education’s survey of states, 13 of the 25 states that responded to this question had found that at least one grantee was not in compliance with the statutory requirement to identify homeless children and youth. In one of the four states we reviewed, Education found the data on the number of homeless students to be unreliable, which the state EHCY program coordinator attributed to a 2009-10 transition to a new, state-wide database system that led to undercounting homeless students. Both Education and the state educational agency are taking steps to address the state’s data quality issues, according to officials from both agencies. Education officials told us that the under-representation of the number of homeless students in the data generally is an area of concern, which they are addressing in multiple ways. In addition to questioning states about this issue, an Education official said the agency has worked with a contractor who analyzed school district-level data in every state to help identify school districts that may have been under- identifying homeless students by comparing their rate of homeless student identification to the percentage of students receiving free or reduced-price lunch. The contractor has made presentations on the results of this analysis to state EHCY program coordinators, and Education plans to provide state EHCY program coordinators with additional technical assistance on outreach and identification.

Another limitation to the use of state-reported data is that, by design, the data are difficult to compare across states. As GAO has previously reported, states vary in how they measure student academic achievement, as permitted by ESEA, to allow states to address their unique circumstances. Education has acknowledged this inherent limitation, as well as challenges in comparing data within states over time, as many states have made changes to their state assessments that can impact comparability. According to the Common Core State Standards Initiative, a voluntary state-led initiative, 43 states and the District of Columbia have chosen to adopt the Common Core State Standards— designed to define the knowledge and skills students should gain throughout their K-12 education in order to graduate high school prepared to succeed in entry-level careers, introductory academic college courses, and workforce training programs. Most states have chosen to participate in one of two state-led consortia working to develop assessments based on these standards, expected to be available in school year 2014-15, which may lead to greater comparability across states. Similarly, according to agency officials, Education collects dropout and graduation rate data, including disaggregated data for homeless students, but these data are calculated differently in different states—making comparisons across states problematic. GAO has previously reported on the use of different state graduation rates, and recommended that Education provide information to all states on ways to account for different types of students in graduation rate calculations and assess the reliability of state data used to calculate interim rates, which it did.

Aside from its annual data collection efforts, Education’s latest study (forthcoming in 2014), which covers school year 2010-11, will provide some valuable information on program implementation, according to agency officials. The study collects information from surveys of state EHCY program coordinators and grantee school district homeless liaisons on topics such as their EHCY-related responsibilities; data collection and use; collaboration with other programs and service providers; barriers homeless students face to enrolling, attending, and succeeding in schools; and state monitoring of districts’ compliance with the McKinney- Vento Act, among other topics.

Conclusions

The EHCY program, funded at about $65 million for fiscal year 2014, is intended to remove barriers to educational achievement for homeless students and provide them with access to critical services—such as transportation to school and referrals for health care. Such services are important to help mitigate the range of negative effects experienced by homeless children and youth across an array of measures, including academic achievement and school graduation rates. The program identified more than 1.1 million homeless students in school year 2011- 12—students who, had they not been identified, might have faced greater difficulties succeeding in school and preparing to graduate. To increase the program’s effectiveness, school districts, states, and the federal government leverage existing resources to ensure that homeless students are identified and their various academic and non-academic needs are met. The EHCY program promotes efforts to leverage resources, in part, by requiring coordination and collaboration among various programs and service providers that also serve homeless students. Collaboration can be particularly important for districts and communities addressing significant increases in homelessness following natural disasters.

Appropriately identifying eligible students, in collaboration with other providers, is key to ensuring that districts provide homeless students with the services they need. However, challenges districts face in identifying students coupled with potential financial disincentives to identify them due to the cost of providing them with services such as transportation, can lead to under-identification, which has several consequences. First, it can result in barriers to homeless students’ educational stability and achievement. Homeless children and youth who are not identified may have difficulty getting to and from their school as their nighttime residence changes and may therefore be derailed in their attempts to obtain an education without the assistance available through the EHCY program. Second, under-identification complicates Education’s ability to fully assess program results due to concerns about the accuracy and completeness of the data, which it has taken some steps to address. Similarly, under-identification complicates the ability of the U.S. Interagency Council on Homelessness to accurately assess progress toward its goal of ending homelessness for families, youth, and children by 2020.

While it may not be possible to accurately determine the extent to which districts may be under-identifying students—and the extent to which these children and youth may not succeed academically— monitoring states and school districts is imperative to ensure compliance with the requirements of the McKinney-Vento Act, particularly in light of the fact that some states are implementing the program differently than described in their state plans. Without monitoring states through regular reviews of state programs and implementation plans, Education will not have the information it needs to determine whether states are meeting requirements that help provide eligible students with the resources needed to pursue an education.

Recommendation for Agency Action

To help ensure state compliance with the McKinney-Vento Act, Education should develop a monitoring plan to ensure adequate oversight of the EHCY program. This plan could, for example, determine a schedule of states to be monitored and incorporate procedures to assess whether states need to update their state plans.

Agency Comments and Our Evaluation

We provided a draft of this report to the Departments of Education, HHS, and HUD and to USICH for review and comment. Education and USICH provided formal comments that are reproduced in appendices III and IV.

Education, HHS, HUD, and USICH also provided technical comments, which we incorporated as appropriate.

Education agreed that sufficient oversight of EHCY program requirements at the federal, state, and local levels is necessary and that both inter- agency and cross-program collaboration is essential to ensure that the needs of homeless children and youth are addressed. Education noted that although not all state EHCY programs have been monitored in recent years, the department has continued to conduct risk assessments for all states and to provide technical assistance to states and school districts through the EHCY program office and NCHE.

Education concurred with our recommendation that, in order to ensure compliance with the McKinney-Vento Act, the department should develop a monitoring plan to ensure adequate oversight of the EHCY program. Education said that it is currently developing a plan for monitoring for fiscal year 2015 and will increase monitoring for the EHCY program, ensuring that all states identified as “higher risk” in its next round of risk assessments are monitored through document reviews, on-site and remote interviews with state and local educational agency personnel. We encourage Education to continue to consider the length of time since a state was last monitored in its determination of risk and to consider developing a monitoring schedule to help ensure that it has the information it needs to determine whether all states are meeting EHCY program requirements. Education also said that it is making changes to its monitoring protocol, adding questions related to student academic achievement and potential under-identification of homeless students. We support Education’s decision to increase its EHCY program monitoring and believe focusing additional attention on the issue of under- identification is particularly important. Without a fuller sense of the extent of under-identification, it is difficult for Education to gauge program results. Lastly, Education indicated that it plans to include the development of a secure website through which states can update their state plans in its next technical assistance contract. Since states may have changed the way they implement the EHCY program since their state plans were originally developed, we encourage Education to take steps to ensure that states that need to update their plans do so.

USICH agreed that monitoring EHCY grantees is important to ensure homeless children and youth are identified. USICH also noted the important role that Education can play in fostering best practices, strategic partnerships, and innovation to address the needs of homeless students. USICH stated that it considers Education and the EHCY program to be critical partners in developing and advancing the work of USICH’s goal of ending homelessness among families, children, and youth by 2020.

As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days from its issue date. At that time, we will send copies of this report to the Secretaries of Education, HHS, and HUD, the Executive Director of USICH, relevant congressional committees, and other interested parties. In addition, the report will be made available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff members have any questions about this report, please contact me at (202) 512- 7215 or Brownke@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 V.

Appendix I: Scope and Methodology

We used several approaches to obtain information on how school districts, states, and the Department of Education (Education) implement and oversee the Education for Homeless Children and Youth (EHCY) program. To gather information on how the EHCY program is implemented at the local level, we visited three states—Colorado, New Jersey, and Washington State—and conducted interviews with a fourth state, Texas, by phone. We selected states that represent geographic diversity and were identified by experts, including the National Association for the Education of Homeless Children and Youth (NAEHCY) and other national organizations working on issues related to homelessness, for their experiences in providing education to homeless students. We identified these organizations during the course of our background research. We also considered the number of homeless students states identified in recent years, including any trends, the level of program funding states received, and the delivery structure of early childhood education programs in the state. In addition, we selected states that experienced surges in homelessness due to recent natural disasters—including wildfires, flooding, and a hurricane. Together, these states included about 13 percent of identified homeless students nationwide in school year 2011-12. In each state, we interviewed state officials to obtain information on how they collaborate with other agencies, service providers, and school districts, as well as their monitoring practices. We also met with school district officials. In all, we spoke with representatives from 20 school districts in the four states. We selected school districts, with assistance from state EHCY program coordinators, to represent a mix of urban, suburban, and rural districts, as well as districts that received EHCY program funds (grantees) and those that did not (non-grantees). In one state, we also met with representatives of two regional educational entities that are responsible for providing EHCY- related services to several school districts within their respective regions and receive EHCY program funds to do so. In the states we visited, we also met with school officials at the elementary, middle, and high school levels, and youth that have experienced homelessness, or their families, about their educational experiences (12 youth and three families). Information obtained from these states, school districts, youth, and families is non-generalizable. We also attended the 2012 NAEHCY Conference to obtain further insights into how school districts were implementing the EHCY program and met with five additional state coordinators at that conference to discuss how they collaborated with various stakeholders.

To obtain generalizable and national-level information from states and grantee school districts, we analyzed Education data from two surveys covering school year 2010-11. Education’s surveys collected information on services school districts provided to homeless children and youth; state and local collaboration efforts with other Education programs; and how states monitored school districts, including any differences in monitoring among grantee and non-grantee districts. A total of 448 school districts were included in the district-level survey sample, including the 50 largest school districts and a random sample of 401 other school districts (3 districts were removed from the sample after the survey was released because they had merged with other districts). The surveys were conducted electronically, however, in a small number of cases (7 or 8) districts that did not initially respond to the electronic survey were administered the survey over the phone or on paper. The school district- level survey had a weighted response rate of 86 percent (96 percent for the 50 largest districts and 85 percent for the remaining 398 districts). The state survey was sent to all 50 states, the District of Columbia, and the Bureau of Indian Affairs. The Bureau of Indian Affairs did not respond and was later removed from the scope of the survey. One additional state provided incomplete survey answers, leaving 49 states and the District of Columbia as the state survey population. We assessed the reliability of Education’s survey data by performing electronic testing of the data elements, reviewing relevant documentation, and interviewing agency officials knowledgeable about the data. We found that the data were sufficiently reliable for the purposes of this report. The responses of each eligible sample member who provided a useable questionnaire were weighted in the analyses to account statistically for all members of the population. We created weights for each survey respondent to account for unequal probabilities of selection and various unit response rates among the survey strata. All estimates obtained from the school district-level survey have margins of error of no greater than six percentage points.

To obtain information on how Education administers the EHCY program, we interviewed Education officials about how the agency monitors states for compliance and collaborates with other federal programs. We also interviewed officials from other federal agencies, including the Departments of Health and Human Services (HHS) and Housing and Urban Development (HUD), as well as the U.S. Interagency Council on Homelessness (USICH), to obtain their perspectives on collaborating with Education on programs that serve homeless children and youth. We also interviewed Education officials about the agency’s monitoring efforts. Additionally, we reviewed relevant documents—including federal laws and regulations, monitoring protocols, and policy memos—and examined Education’s findings on homeless education from state monitoring reports.

We conducted this performance audit from July 2012 through July 2014 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Education for Homeless Children and Youth Program Monitoring Indicators

Federal monitoring indicator 1.1: The state conducts monitoring and evaluation of school districts with and without subgrants, sufficient to ensure compliance with McKinney-Vento program requirements.

Selected examples of acceptable evidence that states provide Written procedure for monitoring school districts with and without subgrants to include:

Recent copy of monitoring policies and procedures, schedules for current and previous school years. Sample notification letters to school districts, preparation checklists, or other forms. A copy of the interview protocol for school district reviews.

Most recent copies of reports, recommendations and follow-up to corrective actions.

2.1: The state implements procedures to address the identification, enrollment and retention of homeless students through coordinating and collaborating with other program offices and state agencies.

Written communication to school districts updating state policies and procedures that address the problems homeless children and youth face in school enrollment and retention since the last Department of Education program review. Updates to the state plan, including the completion of planned activities and proposals for new state-level activities.

2.2: The state provides, or provides for, technical assistance to school districts to ensure appropriate implementation of the statute.

Copies of written guidance to school districts and/or information dissemination materials distributed electronically or by other means. The most recent liaison orientation, on-line trainings, conferences, and regional training agendas and technical assistant log.

3.1 The state ensures that school district subgrant plans for services to eligible homeless students meet all requirements.

Evidence that the state has an application and approval process to provide competitive subgrants to school districts.

3.2: The state complies with the statutory and other regulatory requirements governing the reservation of funds for state-level coordination activities.

State budget detail on reserved funds for state-level coordination activities for the current fiscal year and use of funds for the last fiscal year.

3.3: The state has a system for ensuring the prompt resolution of disputes.

Updated state dispute resolution policy and procedures including: procedures for tracking disputes documents indicating that dispute procedures have been implemented records indicating that disputes are addressed, investigated and resolved in a timely manner Evidence that the state tracks if school districts have a dispute resolution policy in place.

Appendix III: Comments from the Department of Education

Appendix IV: Comments from the U.S. Interagency Council on Homelessness

Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, Kathryn Larin (Assistant Director), Avani Locke (Analyst-in-Charge), David Barish, and Jennifer Cook made key contributions to this report. Also contributing to this report were Alicia Cackley, Sarah Cornetto, Keira Dembowski, Justin Fisher, Hedieh Fusfield, Jessica Gray, Thomas James, Jean McSween, Mimi Nguyen, Paul Schmidt, Almeta Spencer, Kathleen van Gelder, and Amber Yancey-Carroll.

Related GAO Products

Managing for Results: Implementation Approaches Used to Enhance Collaboration in Interagency Groups. GAO-14-220. Washington, D.C.: February 14, 2014.

Homelessness: Fragmentation and Overlap in Programs Highlight the Need to Identify, Assess, and Reduce Inefficiencies. GAO-12-491. Washington, D.C.: May 10, 2012.

Homelessness: To Improve Data and Programs, Agencies Have Taken Steps to Develop a Common Vocabulary. GAO-12-302T. Washington, D.C.: December 15, 2011.

K-12 Education: Many Challenges Arise in Educating Students Who Change Schools Frequently. GAO-11-40. Washington, D.C.: November 18, 2010.

Homelessness: A Common Vocabulary Could Help Agencies Collaborate and Collect More Consistent Data. GAO-10-702. Washington, D.C.: June 30, 2010.

Runaway and Homeless Youth Grants: Improvements Needed in the Grant Award Process. GAO-10-335. Washington, D.C.: May 10, 2010.

Disconnected Youth: Federal Action Could Address Some of the Challenges Faced by Local Programs That Reconnect Youth to Education and Employment.GAO-08-313. Washington, D.C.: February 28, 2008.