The principal source of federal funding for CTE, Perkins IV authorizes federal grant funds for the enhancement of CTE for secondary and postsecondary students. In fiscal year 2008, Congress appropriated $1.2 billion for the improvement of local CTE programs. Education’s Office of Vocational and Adult Education allocates the funds to states, which retain up to 15 percent of the funds for administration and state leadership of CTE programs, before passing at least 85 percent of the funds on to local recipients of funds, such as local school districts and community colleges. States determine the percentage of funds that will be allocated to the secondary and postsecondary levels. The majority of funds allocated to the secondary level are passed on to local recipients based on the school district’s share of students from families below the poverty level for the preceding fiscal year. Postsecondary funds are primarily allocated based on the institution’s share of Pell Grant recipients. Perkins IV established six student performance measures at the secondary level and five performance measures at the postsecondary level. These measures represent a range of student outcomes, such as attainment of technical skills and placement in employment or further education following the completion of CTE programs. In addition, the measures include the nontraditional participation and completion of students from an underrepresented gender in programs with significant gender disparities (such as women participating in auto repair), among others (see tables 1 and 2 for a description of the Perkins IV performance measures). To ease states’ transition to the new provisions in Perkins IV, Education permitted states to submit a 1-year transition plan that covered only the first program year of Perkins IV implementation, 2007-2008. Accordingly, states were required only to implement and report performance on two secondary performance measures for the 2007-2008 program year: academic attainment and student graduation rates. These two measures are based on the same academic attainment and student graduation rate measures required by Title I of the Elementary and Secondary Education Act. Beginning in the 2008-2009 program year, states are required to report on student outcomes for all of the performance measures. States will report these outcomes to Education in December 2009. Perkins IV requires states to negotiate specific performance targets with Education and to annually report their performance to Education. It also requires local recipients to negotiate performance targets with the states and to annually report to the state their progress toward meeting these targets. Perkins IV established additional accountability requirements for states and local recipients, including actions to address states that do not meet all of their performance targets. Under Perkins IV, if a state does not meet at least 90 percent of its targets for one or more of the performance measures, it is required to develop and implement a program improvement plan that describes how it will address its failing performance targets. Prior to Perkins IV, states were only required to develop and implement a program improvement plan if they failed to meet their targets in all of their performance measures, not just one measure. States can also face financial sanctions. For example, Education can withhold all or a portion of funds if a state does not implement a program improvement plan, show improvement in meeting its failing performance measure, or meet the target for the same performance measure for 3 consecutive years. Local recipients that do not meet at least 90 percent of their performance targets have the same program improvement requirements as the state and face similar sanctions from the state. In the event of financial sanctions, Education is required to use the withheld funds to provide technical assistance to the state for improving its performance on the measures and the state is to use funds withheld from local recipients to provide CTE services and activities to students. In order to implement the performance measurement requirements of Perkins IV, states must define which students will be included in the measures and collect data for each of the performance measures at the secondary and postsecondary levels. For example, states define the minimum requirements, such as a certain number of CTE credits that a student would need to obtain in order to be identified as a student concentrating in CTE. Education has taken a range of actions to help states with these activities. For example, in January 2007, Education began issuing nonregulatory guidance to states to help them develop their student definitions and data collection approaches for the performance measures. Education also issued guidance to states on the information states must include in their state Perkins plans and in the annual reports that they submit to Education. In the state plans, states must detail how they intend to implement the performance measures, and in the annual reports states must describe their progress in meeting the negotiated performance targets. In addition to implementing performance measures, states are required to evaluate programs, services, and activities supported with Perkins funds and to report to Education in their state plans how they intend to conduct these evaluations. To meet this requirement, states describe the approaches, such as the use of state-developed standards, they will use to evaluate local CTE programs. In addition, Education requires states to include a description of how they used Perkins funds to evaluate their local CTE programs in their annual reports. A key feature of Perkins IV—to enhance state and local flexibility in developing, implementing, and improving career and technical education—allows for considerable variation in how states implement some performance measures. While Perkins IV was designed to strengthen accountability for results at the state and local levels, it also allows states to establish their own accountability systems, including their own data collection methods for the performance measures. Of the 11 performance measures, the secondary and postsecondary levels have 3 measures in common: technical skill attainment, student placement, and participation in and completion of nontraditional programs (see fig. 1). States may also include additional, state-developed performance measures in their accountability systems. For example, Washington state added three performance measures—earnings, employer satisfaction, and CTE student satisfaction—to its accountability system. Consistent with Perkins IV, Education’s guidance to states also allows for flexibility. Education issued nonregulatory guidance that proposed specific definitions that could be adopted by states to develop each of the secondary and postsecondary performance measures. It also identified preferred approaches for collecting data for certain measures such as student technical skill attainment. However, Education noted that in accordance with Perkins IV, states could propose other definitions and approaches to collect data for the required performance measures if they meet the requirements of the law. We found through our surveys of state CTE directors that states vary considerably in the extent to which they plan to follow Education’s guidance—specifically with regard to the technical skill attainment and secondary school completion measures. As a result, Education will collect student outcome data that vary across states for the same measures. This can create challenges for Education to aggregate student outcomes at the national level. For example, a majority of states reported that they will use technical assessments—the approach recommended in Education’s guidance—to measure student attainment of skills at the secondary and postsecondary levels. These include assessments leading to industry-ba certificates or state licenses. However, a number of states will rely on other approaches to collect data for the performance measure, including grade poi nt average (GPA), program completion, or other methods (see table 3). Officials in the states we visited provided a variety of reasons for their use of alternate methods to measure students’ attainment of technical skills. For example, postsecondary state officials in California said that a CTE instructor’s overall evaluation of a student’s technical skill proficiency, in the form of a final grade, is a better measure of technical skill attainmentthan third-party technical assessments, and can more effectivel program improvement. They questioned the value of technical assessments, in part because assessments often cannot keep pace with technology and changing CTE program curricula, such as curricula for digital animation. A Washington state official told us that the state plans to use program completion to measure technical skills at the postsecondary level, noting that each postsecondary CTE program incorporates industry- recognized standards into the curriculum. He noted that a national system se it of third-party assessments may not be adequate or appropriate, becau would not necessarily incorporate the same standards. Local school officials in Minnesota said that they will report on CTE course complet view by for this measure. Because CTE courses undergo curriculum re teachers as well as industry advisors, and align with relevant postsecondary programs in the area, school officials told us cours completion i attainment. s sufficient to satisfy the definition of technical skill Education’s guidance also allows for considerable variation in the types of technical assessments states can use and when they can administer them. Most states at the secondary level reported in our survey that they plan to use industry-developed certificates or credentials most often administere at the end of a program, such as a certificate awarded for an automotive at the end of a program, such as a certificate awarded for an automotive technician. At the postsecondary level, states plan to most often rely upon technician. At the postsecondary level, states plan to most often rely upon the results of assessments for state lice the results of assessments for state licenses, such as state nursing licenses, to measure technical skills (see fig. 2). nses, such as state nursing licenses, to measure technical skills (see fig. 2). However, we found that while a majority of states plan to use assessment to report to Education, the assessments are not currently in widespread use. For example, more than half of states at the secondary and postsecondary levels reported that they plan to use these assessments to report on few to none of their state-approved CTE programs in the 2008- s 2009 program year. Some states at the secondary level reported will use a combination of methods—including GPA o r program completion—to report on technical skill attainment. We also found that states differ in whether they plan to report student dat on GED credentials, part of the secondary school completion measure. Thirty states reported through our survey that they do not plan to report GED data to Education for the 2008-2009 program year, while 18 reported that they would. About one-third of all states cited their ability to access accurate GED data as a great or very great challenge.