Appendix B

United States Government Accountability Office

GAO

Report to Congressional Requesters

February 2008

NO CHILD LEFT
BEHIND ACT
Education Actions
Could Improve the
Targeting of School
Improvement Funds
to Schools Most in
Need of Assistance
This report was reissued on May 14, 2008, to reflect the

following modification: On page 21, the map in figure 4 has been
replaced with the map that was previously in figure 6, and on
page 28, the map in figure 6 has been replaced with the map
that was previously in figure 4.

GAO-08-380

Contents

Letter

1
Results in Brief
Background
A Statutory Requirement Limits Some States’ Ability to Target Title
I School Improvement Funds to Lowest-Performing Schools, but
Many States Have Used Other Resources for School
Improvement Efforts
States Generally Target Funds to the Most Persistently
Underperforming Schools, However, Some States Did Not Fulfill
NCLBA Requirements for Allocating or Tracking Funds
Schools and States Are Engaged in a Variety of Improvement
Activities and Mainly Assess Them Using Student Achievement
Data and Feedback
Education Provides a Range of Support for School Improvement,
Including Some New Efforts Aimed at Areas in Which States
Want More Help
Conclusions
Recommendations for Executive Action
Agency Comments and Our Evaluation

3
6

15

23

33

38
43
44
45

Appendix I

Scope and Methodology

46

Appendix II

Comments from the Department of Education

51

Appendix III

GAO Contacts and Acknowledgments

53

Related GAO Products

54

Tables
Table 1: Timeline for Implementing Interventions for Schools That
Do Not Make Adequate Yearly Progress
Table 2: NCLBA Technical Assistance Districts Are Required to
Ensure for Schools Identified for Improvement
Table 3: Federal Programs Related to School Improvement

Page i

10
11
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GAO-08-380 No Child Left Behind Act

Table 4: Characteristics of the 12 States Unable to Set Aside the
Full 4 Percent of Title I Funds for School Improvement,
Fiscal Year 2006
Table 5: Changes in Title I School Improvement Set-aside, Fiscal
Years 2005-2007
Table 6: State Funds for School Improvement under NCLBA, Fiscal
Year 2006
Table 7: Selected Characteristics of Schools That Received Title I
School Improvement Funds, Other Schools Identified for
Improvement, and All Other Title I Schools, Fiscal Year
2006
Table 8: School Districts Selected for Site Visits

18
19
23

26
49

Figures
Figure 1: Title I Grants to Local Education Agencies, 2001-2007
Figure 2: Distribution of Title I Set-aside Funds for School
Improvement
Figure 3: States’ Title I School Improvement Set-aside Portions
since 2002
Figure 4: States’ Average Title I Set-aside Amounts Available per
School Identified for Improvement, Fiscal Year 2006
Figure 5: Median Title I School Improvement Allocations by
Improvement Status, Fiscal Year 2005
Figure 6: States’ Methods for Allocating School Improvement
Funds, Fiscal Year 2006
Figure 7: Number of States That Reserved Less than 5 Percent, 5
Percent, or More than 5 Percent of School Improvement
Funds for Their Statewide System of Support
Figure 8: Differences in Types of Assistance States Provided to
Schools in Different Stages of Improvement
Figure 9: Example of a Middle School’s Data Room to Track
Students’ Progress
Figure 10: Education’s Technical Assistance and Research-Related
Resources That Support School Improvement Efforts
Figure 11: Extent to Which States Found Assistance from
Education Helpful

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8
13
17
21
24
28

30
35
37
39
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GAO-08-380 No Child Left Behind Act

Abbreviations
AYP
CCD
CSR
CSPR
ESEA
IASA
NCES
NCLBA
SES

adequate yearly progress
Common Core of Data
Comprehensive School Reform
Consolidated State Performance Reports
Elementary and Secondary Education Act of 1965
Improving America’s Schools Act of 1994
National Center for Education Statistics
No Child Left Behind Act of 2001
supplemental educational services

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GAO-08-380 No Child Left Behind Act

United States Government Accountability Office
Washington, DC 20548

February 29, 2008
The Honorable Tom Harkin
Chairman
The Honorable Arlen Specter
Ranking Member
Subcommittee on Labor, Health and Human
Services, Education, and Related Agencies
Committee on Appropriations
United States Senate
Over the past 40 years, the federal government has invested billions of
dollars annually in grants to states and school districts to improve
educational opportunities for economically disadvantaged students. The
most recent reauthorization of the Elementary and Secondary Education
Act of 1965 (ESEA), known as the No Child Left Behind Act of 2001
(NCLBA), sought to hold schools, districts, and states accountable for
student progress.1 Specifically, states are required to develop academic
standards and tests, measure student proficiency in certain grades and
subjects, and determine whether schools are meeting proficiency goals.
Schools that fail to meet state academic goals for 2 or more years are to be
identified for improvement and are required to take a series of actions
intended to improve student performance. The number of schools
identified for improvement under NCLBA increased from about 8,400 in
school year 2004-2005 to over 10,700 in 2006-2007, and if this trend
continues, more schools will be identified for improvement in the future.
To assist these schools, NCLBA requires states to set aside 4 percent of
their Title I funds to help pay for school improvement efforts, which in
fiscal year 2005-2006 totaled close to $500 million nationally. States are
required to target funds to districts that serve the lowestachieving schools,
have the greatest need for assistance, and are committed to using funds to
help their lowest performing schools meet annual goals.2 However, the
availability of these funds may be limited because of a hold-harmless
provision that prevents states from giving any district less Title I funds

1

Pub. L. No. 107-110.

2

20 U.S.C. § 6303(c).

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than it did in the previous year as a result of setting aside improvement
funds.3
While states have spent over a billion federal dollars on school
improvement since NCLBA was enacted in 2002, questions remain about
how Title I school improvement dollars are allocated and expended, or the
types of improvement activities schools use and find effective. Further, in
a report accompanying the fiscal year 2006 appropriations bill for the
Department of Education (Education) and other departments, the Senate
Appropriations Committee expressed concern about the hold-harmless
provision and its effect on high-poverty districts as well as states’ ability to
set aside the full 4 percent.4 To shed light on these issues and to assist
Congress in the reauthorization and funding of NCLBA, you asked GAO to
determine (1) the extent to which states have been able to set aside Title I
school improvement funds and dedicated other federal and state funds to
school improvement since NCLBA was enacted, (2) the schools to which
states targeted school improvement funds and the extent to which these
funds are tracked, (3) the types of activities that states and schools have
undertaken to improve schools and how the these strategies are being
assessed, and (4) how Education provides support to help states make the
best use of school improvement funds.
To do this work, we administered a survey to state education agency
officials in all 50 states and the District of Columbia between July and
October 2007 and received a 100 percent response rate. Because national
information is not available on states’ expenditures of school improvement
funds, we collected this information through our survey. In addition, we
requested information from each state on the schools receiving
improvement funds and linked data on these schools to Education’s
Common Core of Data (CCD) to identify school characteristics. Three
states were unable to provide this information, and 1 state provided partial
information, so our data on school characteristics are presented for only

3

20 U.S.C. § 6303(e). Title I allocations are made by formula to districts based in large part
on the number of children from families below the poverty line in a district and thus may
vary from year to year. The hold-harmless provision protects school districts from resulting
declines when states calculate Title I set-asides for school improvement. As a result, after
district allocations are determined, only district funding increases are available for the 4
percent set -aside. Thus, the effect of the set-aside and the hold-harmless provision is to
reduce Title I funds for some districts but not others.

4

S.Rep. 109-103, at 229 (2005).

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those states that provided this information.5 We reviewed both the survey
data and the lists of schools receiving improvement funds for obvious
inconsistencies, errors, and completeness. When we found discrepancies,
we brought them to the attention of state officials and worked with them
to correct the discrepancies before conducting our analyses. On the basis
of these efforts, we determined that the survey data and lists of schools
were sufficiently reliable for the purposes of this report. We also
conducted site visits to 5 states—California, Georgia, Michigan, New
Mexico, and Ohio—which were selected based on having high percentages
of schools identified for improvement, variation in Title I set-aside funding
allocation methods and administrative structures, and geographic
diversity. We met with state officials in each state and, to understand the
local perspective, we met with officials in 12 districts and 22 schools.
Districts and schools were selected to provide variety in student
demographics, locale, and stage of improvement.6 We interviewed
Education officials and reviewed relevant federal laws, guidance, and
monitoring tools to learn about federal requirements for school
improvement funds and efforts to monitor these funds and activities. We
also interviewed officials from national interest groups and researchers
and reviewed published research and reports about school improvement
funding and activities. See appendix I for more information about our
survey and other data collection methods. We conducted our work from
January 2007 through February 2008 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.

Results in Brief

A statutory requirement has limited some states’ ability to target the full 4
percent of Title I funds for school improvement to low-performing
schools. However, many states have used other federal and state funds for

5
Arkansas, Florida, and North Carolina provided information on districts that received
funds, but could not provide information on which schools received funds, and California
provided a partial list of schools that received funds.
6

In each state, we met with officials in at least two districts and at least four schools. In
one state we met with officials from four districts, and in several states, we met with
officials from additional schools to gain perspective from a broad range of schools
identified for improvement.

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this purpose. While the 4 percent set aside does not affect the total amount
of Title I funds a state receives, the statutory requirement known as the
hold-harmless provision can affect how those funds are allocated within a
state. Specifically, when states set-aside funds for school improvement,
the hold-harmless provision prevents the state from reducing the Title I
funding for any school district from the previous year. Sometimes, after
taking into consideration the hold-harmless provision, there are not
enough funds available from those districts with increasing Title I
allocations to cover the full 4 percent set-aside. Specifically, we found that
22 states have been unable to set aside the full 4 percent of Title I funds for
1 or more years since NCLBA was enacted because of the hold-harmless
provision. Six of these—Florida, Kansas, Kentucky, Maine, Massachusetts,
and Michigan—have been unable to set aside the full amount for 3 or more
years. The change in available funds from year to year can make it difficult
for affected states to provide steady assistance to schools in need of
improvement, and some states have held back funds in some years to
ensure that funds would be available in the future. Education, recognizing
challenges associated with the hold-harmless provision, has proposed
repealing the provision in the past and has raised this issue again as part of
its proposed revisions to NCLBA, which is currently being considered for
reauthorization. In addition to the Title I funds for school improvement, 38
states have dedicated other federal funds, and 17 have contributed state
funds to school improvement efforts. Since 2002, state funds supporting
school improvement activities have totaled almost $2.6 billion, compared
to nearly $1.3 billion in Title I improvement funds nationwide for this
period.
Though states generally target improvement funds to the most persistently
underperforming schools, some states did not fulfill all NCLBA
requirements for allocating or tracking funds. Overall, we found that in
2006 states provided schools in restructuring nationwide a median grant of
about $40,000 more than for schools in corrective action. In addition,
schools that received Title I school improvement funds had higher
percentages of low-income and minority students than all other Title I
schools. To allocate school improvement funds, 37 states used stateestablished criteria, which included factors such as the number of years
schools have been identified as needing improvement; 2 states used a
competitive grant process; and 8 used some other method. However, we
found that 4 states reported that they required funds be allocated equally
to schools and may not have taken into consideration factors required by
NCLBA, such as focusing on the lowest-achieving schools. In addition,
during our site visits, we found that 1 state allocated Title I improvement
funds to districts in improvement with no schools in improvement without

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GAO-08-380 No Child Left Behind Act

determining first that it had excess improvement funds, as required by
NCLBA. We referred this issue to Education for follow-up. Although
Education monitors how states allocate improvement funds, it did not
identify these issues during its state monitoring efforts. Also, 4 states
could not provide the required list of all schools in their state that received
improvement funds. Education has not provided guidance on how states
should make lists of schools receiving funds publicly available and does
not monitor states’ compliance with this requirement.
Schools and states that received funds have undertaken a variety of
improvement activities, and most states assess these activities through
reviewing changes in student achievement and feedback from district and
school officials. For school year 2006-2007, 45 states reported that schools
that received improvement funds were engaged in professional
development, reorganizing curriculum or instructional time, or data
analysis using student assessment information. Schools in all 5 states we
visited cited the importance of professional development, and several
noted that school improvement funds helped them participate in training
that would not have been available otherwise. Nearly all states reported
that they help schools identified for improvement with school
improvement plans and professional development, and officials in 42
states consider this assistance key to helping schools improve. For some
activities, such as support from school support teams, more states
provided this assistance to schools in corrective action or restructuring
than to those required to offer public school choice and supplemental
educational services. To assess school improvement activities, 42 states
reported that they analyze student achievement data or track school
performance trends, and 36 of those states also use feedback from school
and district officials.
Education provides various forms of support related to school
improvement, including some new efforts aimed at areas in which states
want more help. Education staff provide direct assistance with school
improvement to states through written guidance, policy letters, and
national meetings or conferences. Education also offers support through
its comprehensive centers, which provide technical assistance and
research results to states on developing approaches for improving schools.
In addition, Education provides information on school improvement
strategies through its Web-based What Works Clearinghouse. State
officials reported that Education’s written guidance, nationwide
comprehensive centers, and national conferences were the most helpful
forms of assistance and the What Works Clearinghouse was relatively less
helpful. Some state and district officials we visited said that it is difficult to

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GAO-08-380 No Child Left Behind Act

figure out how to translate the research on the clearinghouse into practical
application in the classroom. At the same time, 48 states also reported that
they could benefit from more assistance such as additional national or
regional meetings to share lessons learned and promising practices.
Education has begun some new efforts that are aimed at addressing these
areas, including the development of a Web site to provide additional
resources intended to help educators adapt and use the research-based
practices on the What Works Clearinghouse. In addition, Education is
planning to collect information on how states assess school improvement
activities as part of a new school improvement grants program that was
authorized under NCLBA but was funded for the first time in 2007.
To enhance state efforts to target school improvement funds to schools
most in need of assistance, we recommend that Education review the Title
I monitoring process to ensure that steps are in place to ensure that states
comply with requirements in the statute for allocating funds to districts for
district-level activities and prioritizing funds to the lowest-achieving
schools. We also recommend that Education provide guidance to clarify
when and how states are to make information about which schools receive
Title I improvement funds available and track state compliance with this
requirement. Finally, to provide further support for its proposal to
eliminate the hold-harmless provision, we recommend that Education
develop an analysis comparing the characteristics of districts that
contribute to the set-aside with those protected by the hold-harmless
provision. Education agreed with our recommendations and stated it
would explore options for analyzing additional data related to eliminating
the hold-harmless provision, improving its monitoring process, and
providing additional guidance to states regarding disclosure of schools
receiving Title I improvement funds. Education also identified some of the
steps it has taken to collect additional information on the allocation and
use of school improvement funds and to identify successful school
improvement strategies.

Background

Under NCLBA, states are required to hold their Title I schools accountable
for students’ performance by developing academic standards and tests,
measuring student proficiency in certain grades and subjects, and
determining whether schools are meeting proficiency goals. Schools that
have not met state established goals for 2 or more consecutive years are
identified as in need of improvement and must implement certain activities
meant to improve student academic achievement. NCLBA also requires
states to set aside Title I funds to assist schools in implementing
improvement activities.

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Title I

Title I of the Elementary and Secondary Education Act (ESEA), as
amended and reauthorized by NCLBA, authorizes federal funds to help
elementary and secondary schools establish and maintain programs that
will improve the educational opportunities of economically disadvantaged
children.7 Title I is the largest federal program supporting education in
kindergarten through 12th grade, supplying an estimated $12.8 billion in
federal funds in fiscal year 2007. Appropriations for Title I grew rapidly in
the years following the enactment of NCLBA, from about $8.8 billion in
fiscal year 2001 to $12.3 billion in 2004. However, Title I funding growth
slowed between 2004 and 2007. (See fig. 1.) Title I funds are allocated
through state educational agencies to districts using statutory formulas
based primarily on Census Bureau estimates of the number of students
from families below the poverty line in each district. States retain a share
for administration and school improvement activities before passing most
of the funds on to school districts. In turn, districts are required to allocate
Title I funds first to schools with poverty rates over 75 percent in rank
order, with any remaining funds distributed at their discretion to schools
in rank order of poverty either districtwide or within grade spans. A
school’s Title I status can change from year to year because school
enrollment numbers and demographics vary over time, and annual
allocations to districts under Title I formulas can vary considerably.

7

In this report, we refer to Title I, Part A of the ESEA, as amended, as “Title I.” Other parts
of Title I (Parts B through I) are targeted at specific populations or purposes and are
commonly referred to by their program names, such as Even Start or Comprehensive
School Reform.

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Figure 1: Title I Grants to Local Education Agencies, 2001-2007
Dollars in billions

14

12

10

8

6

4

2

0
2001

2002

2003

2004

2005

2006

2007

Fiscal year
Source: Education.

School Improvement
under NCLBA

In 2002, NCLBA added several new provisions to the ESEA, as amended,
to strengthen accountability of all schools identified for improvement,
which included requiring states to develop academic achievement
standards and establish proficiency goals for making adequate yearly
progress (AYP) that will lead to 100 percent of their students being
proficient in reading, mathematics, and science by 2014.8 To measure their
progress, states administer an annual assessment to students in most
grade levels.9 In addition, each school’s assessment data must be
disaggregated in order to compare the achievement levels of students

8

States set their own academic standards for what constitutes proficiency. NCLBA does,
however, require states to set two standards for high achievement—”advanced” and
“proficient,” to reflect a degree of mastery—and to set another standard for “basic”
achievement to indicate the progress of the lower-achieving children toward mastering
their state standards.
9

Students in grades 3 to 8 must be annually assessed in mathematics and reading or
language arts, while high school students are only required to be assessed once in these
subjects. Assessments in science, which were first required under NCLBA in school year
2007-2008, are required at least once in grades 3 to 5, grades 6 to 9, and grades 10 to 12. In
addition to annual assessments, high schools must include students’ graduation rate, and
elementary and middle schools must include one other academic indicator determined by
the state to assess whether they made AYP.

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within certain designated groups with the state’s performance goals. These
student groups include the economically disadvantaged, major racial and
ethnic groups, students with disabilities, and those with limited English
proficiency, and each of these groups generally must make AYP in order
for the school to make AYP.
The last reauthorization of ESEA prior to NCLBA—the Improving
America’s Schools Act of 1994 (IASA)—required that schools be identified
for improvement if they did not make AYP for 2 consecutive years and that
they take certain actions to improve student performance. NCLBA also
includes a timeline for implementing specific interventions based on the
number of years a school fails to make AYP and adds some interventions
that were not required under IASA. (See table 1.) Under NCLBA, schools
that fail to make AYP for 2 consecutive years are identified for
improvement and must develop an improvement plan in consultation with
the district, school staff, parents, and outside experts. This plan, which is
subject to district approval, must incorporate strategies to address the
specific academic issues that caused the school to be identified for
improvement. At this stage districts also must offer students in the school
the opportunity to transfer to a higher-performing public school in the
district—an option that is called offering public school choice. After the
third year, districts must also offer supplemental educational services
(SES), such as tutoring. Under NCLBA, if a school fails to make AYP for 4
consecutive years, it is required to implement one of the corrective actions
identified in the law, such as implementing a new curriculum or extending
the school year or day. Finally, if a school fails to make AYP for 5 or more
years it must make plans to restructure its governance and implement
those plans. Schools exit improvement status if they make AYP for 2
consecutive years. In addition, all schools identified for improvement are
required to spend at least 10 percent of their Title I funds on professional
development for the school’s teachers and principal as appropriate.

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Table 1: Timeline for Implementing Interventions for Schools That Do Not Make Adequate Yearly Progress
Adequate yearly
progress

School status in the next year

NCLBA interventions for Title I schools

First year missed

Not applicable

None

Second year missed Public school choice (first year of
improvement)

Required to offer public school choicea

Third year missed

SES (second year of improvement)

Required to offer public school choice and SES

Fourth year missed

Corrective action (third year of
improvement)

Implement certain corrective actions and offer public school choice
and SES

Fifth year missed

Planning for restructuring (fourth year of
improvement)

Plan for a change in governance and offer public school choice and
SESb

Sixth year missed

Implementation of restructuring (fifth
year of improvement)

Implement a change in governance and offer public school choice
and SES

Source: GAO analysis of NCLBA and Education’s regulations.
a

At this stage, the school must also develop the school improvement plan.

b

While NCLBA does not require that corrective actions must be continued after a school enters
restructuring, Education officials noted that in practice, many schools continue corrective actions after
entering restructuring status.

Both Districts and States
Provide Technical
Assistance to Schools in
Improvement

School districts bear the primary responsibility for ensuring that their
schools in improvement receive technical assistance. Specifically, districts
must ensure that each school identified for improvement receives
assistance based on scientifically based research in three areas: analysis of
student assessment data, identifying and implementing instructional
strategies, and analysis of the school budget, as shown in table 2.

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Table 2: NCLBA Technical Assistance Districts Are Required to Ensure for Schools
Identified for Improvement
Data analysis
The district must ensure that school staff receive assistance in analyzing student
assessment data to identify and develop solutions in areas such as
• instructional deficiencies
• parental involvement and professional development requirements, and
• implementing the school improvement plan.
Identification and implementation of strategies
The district must ensure that the school receives help to identify and implement
• instructional strategies and methods that are grounded in scientifically based research
and address specific issues that caused the school to be identified for improvement,
• professional development relevant to implementation of such strategies and methods.
Budget analysis
The district must ensure that the school is provided with
• assistance in analyzing and revising its budget to fund activities most likely to increase
student academic achievement.
Source: GAO analysis of NCLBA and Education’s regulations.

States provide technical assistance to districts and schools through their
statewide systems of support, with a priority given to those in
improvement status. In developing their statewide system of support, the
state educational agency must (1) establish school support teams that
include individuals who are knowledgeable about scientifically based
research and practice to assist schools throughout the state that are
identified for improvement in areas such as strengthening instructional
programs; (2) designate and use distinguished teachers and principals who
are chosen from Title I schools and have been especially successful in
improving academic achievement; and (3) devise additional approaches to
improve student performance, for example, by drawing on the expertise of
other entities such as institutions of higher education, educational service
agencies, or private providers of scientifically based technical assistance.

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States Are Required to Set
Aside a Percentage of
Their Title I Funds to
Support School
Improvement Activities

NCLBA requires states to set aside a portion of Title I funds to allocate to
districts for use by and for schools for school improvement activities and
to carry out the state’s responsibilities for school improvement. In fiscal
years 2002 and 2003, states were required to reserve 2 percent of the Title I
funds for school improvement, and in fiscal years 2004 to 2007, states were
required to reserve 4 percent.10 However, states may not always be able to
reserve the full amount for school improvement because of a holdharmless provision that prevents states from reducing the amount of Title
I funds any district receives from what it received the prior year. The holdharmless provision is intended to protect school districts from declines in
Title I funding from year to year, by preventing the state from giving them
less funds than the year before. If the total increase in Title I funds from
districts with increasing allocations is less than 4 percent of a state’s total
Title I allocation, then that state would not be able to set aside the full 4
percent of Title I funds for school improvement.
States are generally required to allocate 95 percent of the 4 percent set-aside
to districts for schools identified for improvement. States may use the
remaining 5 percent of the 4 percent set-aside to carry out their
responsibilities related to school improvement, including creating and
maintaining their statewide system of support.11 (See fig. 2.) NCLBA
establishes priorities and requirements for the distribution of school
improvement funds to districts. Specifically, under NCLBA states must give
funding preference to districts that serve the lowest-achieving schools,
demonstrate the greatest need for assistance, and demonstrate the strongest
commitment to using the funds to assist their lowest-performing schools with
meeting progress goals.12 States may either allocate these funds directly to
districts for schools identified for improvement to be used for activities
required under the school improvement section of the law or, with the
permission of districts, retain funds to provide for these activities for schools
identified for improvement. 13

10

20 U.S.C. § 6303(e).

11

20 U.S.C. § 6303(b)(1).

12

20 U.S.C. § 6303(c).

13

20 U.S.C. § 6303(b)(2).

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GAO-08-380 No Child Left Behind Act

Figure 2: Distribution of Title I Set-aside Funds for School Improvement
Other Title I funds

5%

School Improvement
Fund for the statewide
system of support

96%

Set-aside for the School
Improvement Fund

4%

95%

School Improvement
Fund for schools
identified for
improvement

School Improvement Fund was a 2 percent set-aside in years 2002 and 2003 and increased to a
4 percent set-aside for each subsequent year.
Source: GAO analysis of the No Child left Behind Act.

While NCLBA directs 95 percent of improvement funds to schools through
districts, some flexibility exists for funds to be used at the state or district
level for improvement-related activities. For example, NCLBA gives states
authority to use some of the 95 percent funds at the district level if the
state determines that it has more funding than needed to provide
assistance to schools in improvement. In addition, states may use some of
their 5 percent funds generally retained at the state level for districts to
support district-level activities.
Among other requirements regarding the allocation of funds, states are
required to make publicly available a list of the schools that have received
funds or services from the school improvement set-aside and the
percentage of students in each of these schools from families with
incomes below the poverty line.14

14

20 U.S.C. § 6303(f).

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Other Funds States May
Use for School
Improvement Activities

In addition to the Title I set-aside, Education officials told us that states
may use state funds for school improvement or incorporate other federal
funds to support school improvement efforts, including the School
Improvement Grant Program under NCLBA,15 Comprehensive School
Reform, Reading First, and Title II teacher and principal quality programs
(see table 3). These programs either establish funding priorities for
schools identified for improvement or allow for state flexibility to
establish such priorities.

Table 3: Federal Programs Related to School Improvement
Program

Purpose and connection to school improvement

Statutory priorities

School Improvement
Grant Program

Authorizes states to make grants to school districts for improvement
activities. Grants can be $50,000-$500,000 for each school. This
program received appropriations for the first time in 2007.

Districts to address schools
identified as being in
improvement, corrective action,
and restructuring.

Comprehensive School
Reform

Provide financial incentives for schools to develop comprehensive
school reforms based on scientifically based research and effective
practices that include an emphasis on basic academics and parental
involvement so that all children can meet challenging state academic
content and academic achievement standards.

Districts that plan to use the
funds in schools identified as
being in need of improvement or
corrective action

Reading First

To provide assistance to states and districts to establish reading
programs in grades kindergarten through third grade; prepare teachers;
administer assessments; develop and select materials; programs and
strategies; and strengthen coordination among schools, early literacy
programs, and family literacy programs to improve reading achievement.

Districts in which at least 15
percent of the children or 6,500
children are from families with
incomes below the poverty line

Title II teacher and
principal training
programs

To increase student academic achievement through strategies such as
improving teacher and principal quality and increasing the number of
highly qualified teachers in the classroom and highly qualified principals
and assistant principals in schools, and to hold districts and schools
accountable for improvements in student academic achievement.

Schools that have the lowest
proportion of highly qualified
teachers, the largest average
class size, or are identified for
school improvement

Source: GAO analysis of NCLBA and Education’s regulations.

15

In 2007, Congress appropriated $125 million for awards under 20 U.S.C. § 6303(g). States
must apply for these grants, and the amount allocated to each state will be in proportion to
elements in their fiscal year 2007 Title I funding allocation.

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GAO-08-380 No Child Left Behind Act

Education Oversees
School Improvement
Funds through Compliance
Monitoring

Education oversees how states allocate school improvement funds as part
of its overall monitoring of state compliance with Title I and NCLBA.
Education monitors states in two ways: (1) by routinely gathering and
analyzing data collected from Web-based searches and documents, such as
the Consolidated State Performance Reports,16 and (2) by conducting onsite visits to state educational agencies and selected districts and schools
within each state to interview officials and review relevant documents.
Education has a 3-year monitoring cycle for visiting each state. During
these visits, Education reviews whether states provide guidance to
districts related to the use of school improvement funds and activities and
how the state monitors school improvement plans. Education’s monitoring
guide includes specific questions about how the state allocated school
improvement funds, whether all the funds have been spent, and what
guidance the state provided to districts—and was recently updated to
include some additional questions on whether states are monitoring
expenditures of school improvement funds at the school level and
assisting schools in effectively using their resources to make AYP and exit
improvement status.

A Statutory
Requirement Limits
Some States’ Ability
to Target Title I
School Improvement
Funds to LowestPerforming Schools,
but Many States Have
Used Other Resources
for School
Improvement Efforts

The hold-harmless provision, which is designed to protect school districts
from reductions in their Title I funding, prevented some states from being
able to target school improvement funds to low-performing schools.
However, many states have used other federal and state funds for school
improvement efforts. The hold-harmless provision prioritizes maintaining
the Title I funding of all eligible districts over ensuring that states can set
aside the full 4 percent for schools identified for improvement—the lowest
performing schools. Twenty-two states have been unable to set aside the
full 4 percent of Title I funds for school improvement for 1 or more years
since NCLBA was enacted because they did not have enough funds to do
so after satisfying the hold-harmless provision. Schools identified for
improvement are, by definition, performing worse than other schools—
and may be among the neediest. When states cannot set aside the full 4
percent for school improvement, it is difficult for them to plan and provide
consistent assistance to these schools. In addition to Title I funds for
school improvement, many states have dedicated other federal funds and
state funds to school improvement efforts. In the period since NCLBA was

16
States may apply and report annually on multiple ESEA programs through a single
consolidated application and report. These annual reports include information on
numerous ESEA programs.

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GAO-08-380 No Child Left Behind Act

enacted, state funds used for this purpose totaled almost $2.6 billion,
compared to $1.3 billion in federal Title I funds.

A Statutory Requirement
Limits Some States’ Ability
to Target School
Improvement Funds to the
Lowest-Performing
Schools

While the hold-harmless provision is designed to protect school districts from
reductions in their Title I funding, it has prevented some states from being able
to set aside the full amount of funds for school improvement, which are
intended for the lowest-performing schools. While the total amount of Title I
funds a state receives does not decrease in any one year as a result of
calculating the 4 percent set-aside, the hold-harmless provision can affect how
those funds are allocated within a state.17 Specifically, when states set aside
funds for school improvement, the hold-harmless provision prevents the state
from reducing the Title I funding for any school district from the previous year.
Sometimes, after taking into consideration the hold-harmless provision, there
are not enough funds available from those districts with increasing Title I
allocations to cover the full 4 percent set-aside. Specifically, 22 states have been
unable to set aside the full portion of Title I funds for school improvement for 1
or more years since NCLBA was enacted because they did not have enough left
over after satisfying the hold-harmless provision. 18 Six of these—Florida,
Kansas, Kentucky, Maine, Massachusetts, and Michigan—have been unable to
set aside the full amount for 3 or more years. (See fig. 3). Title I allocations are
distributed through states to school districts based on poverty levels, and the
hold-harmless provision protects districts from receiving less than they
received the previous year. In other words, if a district’s population of lowincome students decreases, the hold-harmless provision ensures that a district
does not receive less Title I funds than the previous year as a result of the
school improvement set-aside.19 Consequently, states can only set aside funds
for school improvement that would otherwise have been allocated to school
districts slated for Title I increases. In addition to the 22 states affected by the
hold-harmless provision, 4 states did not set aside the full portion of Title I
school improvement funds for other reasons. For example, 1 state reported that
it did not set aside the entire set-aside amount because it had few schools

17

Funds not used for the set-aside for school improvement would still be distributed to
Title I schools in that state.

18

NCLBA generally requires states to set aside 2 percent of their Title I allocation in fiscal
years 2002 and 2003 and 4 percent in fiscal years 2004 through 2007.
19

However, changes in a district’s population of students living in poverty do not indicate
the extent of poverty in the district: A district with a small population of students living in
poverty may experience an increase in that population in a given year, while a district with
a high percentage of students living in poverty may lose some of that population. The
opposite could also occur.

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GAO-08-380 No Child Left Behind Act

identified for improvement. In 2006, 12 states were unable to set aside the full 4
percent of Title I funds for school improvement due to the hold-harmless
provision, with set-asides ranging from as little as 0.2 percent in Kansas to 3.75
percent in Florida.
Figure 3: States’ Title I School Improvement Set-aside Portions since 2002

Wash.
Mont.

Maine

N.D.

Ore.

Vt.

Minn.
Idaho

Wis.

S.D.

N.Y.

R.I.

Mich.

Wyo.

Nev.
Utah

Ill.

Ohio

Ind.

Colo.

Calif.

★
W.Va.

Kan.

Mo.

Va.

Ky.
N.C.

Tenn.
Ariz.

Conn.
N.J.

Pa.

Iowa

Neb.

N.H.
Mass.

Del.
Md.

★ D.C.

Okla.

N.M.

S.C.

Ark.

Hawaii

Miss.
Tex.

Ga.

Ala.

La.

Fla.

Alaska

States able to set aside full portion each year
States unable to set aside funds for 1 year due to hold-harmless provision
States unable to set aside funds for 2 years due to hold-harmless provision
States unable to set aside funds for 3 plus years due to hold-harmless provision
States that did not set aside full portion for other reasons for 1 or more years
Data not available

Source: GAO survey of states; Copyright © Corel Corp. All rights reserved (map).

Note: Virginia did not provide information on the Title I school improvement set-aside.

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GAO-08-380 No Child Left Behind Act

The lowest-performing schools—schools identified for improvement—are
affected when states cannot set aside the full 4 percent for school
improvement. These schools—which are the targets of the school
improvement funding—have failed to meet state performance goals and
are, by definition, performing worse than other schools. Effectively, the
hold-harmless provision prioritizes preserving the Title I funding of all
eligible Title I districts over ensuring that the lowest-performing schools
receive funds for school improvement. Furthermore, schools identified for
improvement may be among the neediest. In fiscal year 2006, schools
identified for improvement in the 12 states that were unable to set aside
the full 4 percent had higher average percentages of students in poverty
and minority students compared to other Title I schools that were in need
of improvement in those states. (See table 4.)
Table 4: Characteristics of the 12 States Unable to Set Aside the Full 4 Percent of Title I Funds for School Improvement, Fiscal
Year 2006
Schools identified for
improvement that received Title I
school improvement funds

All other schools identified for
improvement that did not receive
Title I school improvement funds

All other Title I schools not
identified for improvement

Mean percentage of students

Mean percentage of students

Mean percentage of students

Poverty
status

72

62

53

Minority
status

64

54

30

Percentage of schools

Percentage of schools

Percentage of schools

Urban

57

64

22

Suburban

19

28

28

Town/rural

24

8

50

100

100

100

Selected
student
characteristicsa

Selected
school
characteristics
Locale

Total

Source: GAO analysis of Education data.
a

The table shows the mean percentages of students who are members of racial or ethnic minority
groups (minority status) or who qualified for free or reduced price meals (poverty status).

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GAO-08-380 No Child Left Behind Act

When states cannot set aside the full portion of Title I funds for school
improvement, it is difficult for states to provide consistent assistance to
schools identified for improvement. States that were unable to set aside
the full 4 percent for school improvement experienced large decreases in
their school improvement funds from year to year compared to all other
states. (See table 5.) For example, Ohio officials told us that they
experienced a decline of $14 million in Title I allocations to districts
between fiscal years 2004 and 2005 due to a decrease in census estimates
of the number of low-income students. Since the state still had to provide
all districts with no less Title I funds than the year before, it set aside 58
percent, or $9.3 million, less in school improvement funds than it had in
the previous year. An Ohio official said this variability made it difficult to
commit school improvement assistance to districts. To address this issue,
Ohio now retains a portion of its total Title I school improvement set-aside
each year to help ensure that school improvement funds will be available
if there are future decreases in school improvement funds as a result of
the hold-harmless provision.20
Table 5: Changes in Title I School Improvement Set-aside, Fiscal Years 2005-2007
States unable to set aside the full 4 percent
for school improvement
Fiscal
year

Number of states

Median dollar
change

Median percent
change

2005

12

Decrease
$332,000

2006

12

2007

11

All other states
Number of states

Median dollar
change

Median percent
change

Decrease 10%

38a Increase $304,000

Increase 6%

Decrease
$805,000

Decrease 31%

38

Increase $73,000

Increase 1%

Decrease $2.2
million

Decrease 74%

37b Increase $154,000

Increase 3%

Source: Analysis of GAO survey of states.
a

One state did not provide information for fiscal years 2005 and 2006.

b

Three states did not provide information for fiscal year 2007.

20

Title I funds are appropriated on a forward-funded basis, and states and districts have a
total of 27 months to obligate and expend these funds. For example, for fiscal year 2005,
Title I appropriations were made available to schools on July 1, 2005, for obligation and
expenditure through September 30, 2007.

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GAO-08-380 No Child Left Behind Act

There is also wide variation among states in the average amount of school
improvement money available per school in improvement. (See fig. 4).21
The average amount per school in improvement varies due to differences
in overall Title I allocations as well as the number of schools identified for
improvement in each state.22 For example, Massachusetts received over
$200 million in Title I funds in fiscal year 2006 and set aside less than
$780,000 for its 455 schools identified for improvement, for an average of
approximately $1,700 available per school identified for improvement. In
contrast, Texas received over $1 billion in Title I funds in fiscal year 2006
and set aside $47 million for its 291 schools identified for improvement,
averaging approximately $163,000 per school identified for improvement.

21
These amounts represent the average amounts of school improvement funds available for
schools identified for improvement based on the Title I set-aside amount and the number of
schools identified for improvement in each state. These amounts do not represent the
actual amount of funds schools received.
22
The number of schools identified for improvement in a state can be affected by state
policies. Under NCLBA, states are required to develop academic standards and tests,
measure student proficiency, and determine whether schools are meeting proficiency
goals. Because these definitions can vary from state to state, the number of schools in
improvement can also vary.

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GAO-08-380 No Child Left Behind Act

Figure 4: States’ Average Title I Set-aside Amounts Available per School Identified for Improvement, Fiscal Year 2006

Note: Missouri did not submit to Education its final list of schools identified for improvement in the
2006-2007 school year. In response to our survey, Virginia did not report the amount of Title I funds
set aside for school improvement in fiscal year 2006.

Education, recognizing challenges associated with the hold-harmless
provision, has proposed eliminating the provision as part of its 2007
budget justification and again as part of its proposals for reauthorization
of NCLBA. In its 2007 budget justification, Education estimated states’

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GAO-08-380 No Child Left Behind Act

ability to set aside the full 4 percent of Title I funds for school
improvement for fiscal year 2005 and contended that the hold-harmless
provision, in conjunction with Title I funding fluctuations, limited many
states’ ability to reserve these funds. Additionally, the department pointed
out that districts slated for Title I increases disproportionately contribute
to the Title I school improvement set-aside. Congress has not repealed the
hold-harmless provision and is currently deliberating the reauthorization
of NCLBA.

Many States Have
Dedicated Other Federal
Funds and State Funds to
School Improvement
Efforts

In addition to Title I funds for school improvement, many states have
dedicated other federal funds to school improvement efforts. To further
support school improvement efforts, 38 states targeted funds from other
federal programs intended to improve student achievement, including the
Comprehensive School Reform Demonstration Program (CSR), Reading
First, and teacher and principal quality programs under Title II of NCLBA.
Several states we visited reported incorporating CSR funds and Reading
First funds into their school improvement strategies. For example, in Ohio,
CSR funds were prioritized toward school improvement purposes under
NCLBA. Ohio’s school improvement funding scheme provided Title I setaside funds to schools for up to 3 years, after which schools could obtain
funds from the CSR program.
Additionally, 17 states have contributed almost $2.6 billion in state funds
for school improvement activities since NCLBA was enacted, nearly
double the $1.3 billion in federal Title I school improvement funds
provided over the same period. In 2006, 14 states contributed state funds
for school improvement under NCLBA. (See table 6.) For example, in 2006,
Georgia spent $9.5 million of its funds on its statewide system of support,
nearly as much as it expended in Title I school improvement funds. The 5
percent of the Title I school improvement set-aside the state of Georgia
reserves under NCLBA for its own use supports 8 employees in its school
improvement division, which implements its statewide system of support.
The remaining 107 employees in the division are supported by Georgia’s
own state funds. We found no relationship between the usage of state
funds for school improvement and whether a state reserved the full Title I
set-aside amount required under NCLBA.

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GAO-08-380 No Child Left Behind Act

Table 6: State Funds for School Improvement under NCLBA, Fiscal Year 2006
Funds expended for school improvement
State

Title I funds

State funds

Alabama

$4.9 million

$38 million

Arizona

4.6 million

13.7 million

Arkansas

680,000

300,000

California

24 million

174 million

Delaware

68,000

1.5 million

Georgia

10 million

9.5 million

Illinois

20 million

2.8 million

31,000

5 million

Massachusetts
New Hampshire

59,000

62,000

New Jersey

8.3 million

500,000

Ohio

1.1 million

13 million

Oregon

1.3 million

140,000

540,000

335 million

Pennsylvania
Washington
Total

620,000

4 million

76.2 million

597 million

Source: GAO survey of states.

States Generally
Target Funds to the
Most Persistently
Underperforming
Schools, However,
Some States Did Not
Fulfill NCLBA
Requirements for
Allocating or Tracking
Funds

States generally target improvement funds to the most persistently
underperforming schools, but some states did not fulfill some NCLBA
requirements for allocating or tracking funds. On our survey, states
generally reported that they provided more funds to the most persistently
underperforming schools, and those schools had higher percentages of
low-income and minority students than all other Title I schools. To
allocate school improvement funds, 37 states use state-established criteria
that include factors such as the number of years the school had been
identified for improvement, 2 states used a competitive grant process, and
8 used some other method. However, 4 states reported that they allocated
funds equally among schools in improvement, and may not have taken into
consideration factors required by NCLBA, such as focusing on the lowest
achieving schools. In addition, 1 state allocated Title I improvement funds
to districts without schools in improvement and did not take the required
steps to do this. Education did not identify these potential compliance
issues as part of its monitoring efforts. We referred these issues to
Education, and the department is following up with relevant states. Also, 4
states were unable to provide complete information on which schools in

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GAO-08-380 No Child Left Behind Act

their state received improvement funds, as required under NCLBA.
Education has not provided guidance on how states should provide this
information and does not monitor states’ compliance with this
requirement.

Generally, we found that states targeted school improvement funds to the
most persistently underperforming schools—those that had failed to make
AYP for several years—and states tended to provide more funds to these
schools. For example, the median grant amount for schools in
restructuring nationwide was about $40,000 more than for schools in
corrective action in 2006. (See fig. 5.)
Figure 5: Median Title I School Improvement Allocations by Improvement Status,
Fiscal Year 2005
Median grant amount (dollars)

100,000

96,442

90,000
80,000
70,000
60,000

55,000
50,000

50,000
43,192
38,201

40,000
30,000
20,000
10,000

ing
uc
tur
Re
str

ed
u

ca Su
tio pp
na lem
ls e
erv nta
ice l
s
Co
rre
cti
ve
ac
tio
n
Pla
nf
or
res
tru
ctu
rin
g

ol

ch
oic
e

0

Sc
ho

States Generally Target
Improvement Funds to the
Most Persistently
Underperforming Schools

Source: GAO survey of states.

Note:. Three states were unable to provide information on which schools received Title I school
improvement funds, and one state provided only a partial list of schools that received funds.

Overall, schools receiving improvement funds differed from Title I schools
not in improvement and schools in improvement that did not receive

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GAO-08-380 No Child Left Behind Act

funds. For example, schools receiving improvement funds had higher
percentages of students in poverty and higher percentages of minority
students compared to Title I schools not identified for improvement.23 (See
table 7.) In addition, 54 percent of schools that received improvement
funds were located in urban areas compared to 24 percent of all other Title
I schools not identified for improvement. Nearly half of the schools that
received funds were primary schools and nearly one-third were middle
schools. While schools identified for improvement that received funds had
similar poverty and minority percentages as all other schools identified for
improvement, there were some differences between these two groups. For
example, 26 percent of schools that received improvement funds were
located in rural areas, compared to 12 percent of all other schools
identified for improvement. In the 2005-2006 school year, approximately 71
percent of schools identified for improvement received school
improvement funds.24

23

Our prior work has documented that schools in corrective action and restructuring
served a higher percentage of minority, economically disadvantaged, and middle school
students compared to all other Title I schools. See GAO, No Child Left Behind Act:
Education Should Clarify Guidance and Address Potential Compliance Issues for
Schools in Corrective Action and Restructuring, GAO-07-1035 (Washington, D.C.: Sept. 5,
2007).
24

This figure is based on our data analysis, which excluded schools for which information
was not available. In addition, this figure does not include data from three states that were
unable to provide a list of schools that received Title I school improvement funds and
includes information from one state that provided only partial data.

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GAO-08-380 No Child Left Behind Act

Table 7: Selected Characteristics of Schools That Received Title I School
Improvement Funds, Other Schools Identified for Improvement, and All Other Title I
Schools, Fiscal Year 2006
Schools identified
for improvement
that received Title I
school improvement
funds

All other schools
identified for
improvement

All other Title I
schools not
identified for
improvement

Mean percentage of
students

Mean percentage of
students

Mean percentage of
students

Poverty
status

74

73

52

Minority
status

76

79

43

Percentage of
schools

Percentage of
schools

Percentage of
schools

54

54

24

Selected
student
characteristicsa

Selected school
characteristics
Locale
Urban
Suburban

20

35

27

Town/Rural

26

12

45

100

100b

96b

Primary

48

61

71

Middle

29

25

15

Total
School level

High

16

11

10

Total

93b

97b

96b

Source: GAO analysis of Education data.
a

The table shows the mean percentages of students who are members of racial or ethnic minority
groups (minority status) or who qualified for free or reduced price meals (poverty status).

b

Some percentages do not total 100 due to rounding and the exclusion of schools for which
demographic information was unavailable.

States Use Varying Criteria
to Prioritize Schools for
School Improvement
Funds, but Some States
Did Not Fulfill NCLBA
Requirements for
Allocating Funds

Thirty-seven states established criteria on a state level to determine which
schools should receive Title I school improvement funds or services, and
the remaining states used other allocation methods. (See fig. 6.) Of the 37
states, 27 used criteria that included the number of years the school failed
to make AYP, and 21 states used criteria that included the number of
students in each school. For example, Michigan officials told us that their
allocation formula includes the year of school improvement as well as
overall student enrollment. The state also differentiates between schools
that failed to make AYP for academic reasons and those that missed AYP

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GAO-08-380 No Child Left Behind Act

targets for other reasons, such as graduation rate or attendance. Of the 14
states that used methods other than state-established criteria to allocate
funds, 2 states—Colorado and Idaho—distributed funds through a
competitive grant process. Eight states used other allocation methods
such as distributing funds to districts by ranking the schools identified for
improvement based on school performance and the number of low-income
students. However, we found that Delaware, New Hampshire, Virginia, and
the District of Columbia reported they required districts to provide each
school receiving school improvement funds an equal amount of funding,
and, thus, may not have prioritized the allocation of funds as required
under NCLBA.25 In addition to their various allocation methods, 9 states
gave districts flexibility in determining which schools received funds. For
example, New York allocates funds to districts based on state-established
criteria regarding schools in need of improvement. However, districts can
choose which schools receive funds and the amount of funds those
schools receive.

25
NCLBA requires that states, in allocating school improvement funds, give priority to
districts that (1) serve the lowest-achieving students, (2) demonstrate the greatest need for
such funds, and (3) demonstrate the strongest commitment to ensuring that such funds are
used to enable the lowest-achieving schools to meet the progress goals in the school
improvement plans. 20 U.S.C. § 6303(c).

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GAO-08-380 No Child Left Behind Act

Figure 6: States’ Methods for Allocating School Improvement Funds, Fiscal Year 2006

In addition to criteria used to allocate funds, states also varied in the
proportion of school improvement funds allocated to schools and retained
by the state. In 2006, 38 states allocated 95 percent of the school

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GAO-08-380 No Child Left Behind Act

improvement set-aside funds directly to local school districts for schools
identified for improvement, as NCLBA requires, with the remaining 5
percent retained by states to carry out their responsibilities.26 In 2006, 1
state that we visited retained less than 5 percent for its statewide system
of support and distributed more than 95 percent to districts for schools
identified for improvement. In contrast, some states retained more than 5
percent of their school improvement set-aside, as permitted under NCLBA
under certain circumstances.27 With the approval of districts, a state may
retain more than 5 percent to directly provide school improvement
services for schools or arrange for other entities to provide these services.
In 2006, 10 states retained more than 5 percent. (See fig. 7.) For example,
New Mexico officials told us that eligible districts agreed that the state
could retain the entire set-aside amount to support a systematic reform
model for school years 2006-2007 and 2007-2008. For participating schools,
state officials paid a contractor to provide leadership and instructional
training, reading and math interventions, and materials needed to support
the interventions for schools identified for improvement.

26

Under NCLBA, states are generally required to allocate at least 95 percent of the school
improvement set-aside to districts for schools identified for improvement to carry out
activities described in the statute. The state may retain up to 5 percent to carry out its
responsibilities, including implementing its statewide system of support.
27

States may either allocate these funds directly to districts for schools identified for
improvement to be used for activities required under the school improvement section of
the law or, with the approval of districts, retain funds to provide for these activities for
schools identified for improvement 20 U.S.C. § 6303(b).

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GAO-08-380 No Child Left Behind Act

Figure 7: Number of States That Reserved Less than 5 Percent, 5 Percent, or More
than 5 Percent of School Improvement Funds for Their Statewide System of
Support
Number of states
50

40

38

38
35

35
33
30

20

10

10

10

10

9

9

6
4
2

2

1

0
2002

2003

2004

2005

2006

Fiscal year
Less than 5 percent
5 percent
More than 5 percent
Source: GAO survey of states.

While most states retained the allowed 5 percent of the Title I school
improvement funds to carry out their state responsibilities,28 23 states
reported that they have fully implemented their statewide system of
support. Of the remaining 28 states, 18 reported that their system was
mostly implemented and 10 reported they have partially implemented their
system. Education officials offered several reasons why states may not
have fully implemented these systems. For example, some states may not
have had enough funds to fully implement their statewide system of
support. In other states, statewide strategies may only reach a portion of
the schools identified for improvement because services are prioritized for
the lowest-achieving schools and districts. In addition, officials said some

28
NCLBA requires states to create and maintain a statewide system of support designed to
increase the opportunity for all students and schools to meet the state’s academic content
and achievement standards.

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GAO-08-380 No Child Left Behind Act

states have experienced large increases in the number of schools
identified for improvement, necessitating significant changes to their
statewide system of support.
Additionally, 21 states allocated some of their Title I school improvement
funds to districts for district-level activities, including at least 1 state that
may not have met NCLBA requirements for doing this. Districts have a
major responsibility for providing technical assistance to schools
identified for improvement. According to Education officials, while
NCLBA does not explicitly set aside funds for district-level activities, it
does allow for districts to use improvement funds to provide services to
these schools. In addition, Education officials said that funds can be used
for building district capacity if the funds are focused on providing services
for schools identified for improvement. In Massachusetts, for example,
some funds supported district-level specialists who provided direct
assistance to schools identified for improvement in areas such as data
analysis and implementing the school improvement plan. In addition,
according to Education officials, states have authority to use some of the
95 percent funds for districts identified for improvement but without
schools in improvement if the state determines that the amount of 95
percent funds exceeds the amount needed to provide assistance to schools
identified for improvement. In this situation, a state may take excess funds
from one district and give those funds to other districts based on statedetermined need. Education officials told us that states must consult with
districts before claiming unused funds and have evidence that these
discussions took place.29 However, we found that 1 state may have
allocated Title I improvement funds to districts identified for improvement
without schools identified for improvement without first determining it
had excess funds. We identified this issue through our site visits and are
uncertain if other states may have also done this. Education officials said
they did not identify this issue during their recent monitoring visit. We
referred this matter to Education, which is following up on it.

29

Districts may also be designated for improvement if the district fails to make AYP for 2
consecutive years for all students or for any subgroup that misses its proficiency goals or
participation rates. AYP for districts is based on aggregating the results of each school’s
academic achievement and other measures. In some cases, districts without any schools
identified for improvement may themselves be identified for improvement when the
minimum group size at individual schools was too small to identify the schools for
improvement but was large enough on an aggregate level for the district to be identified for
improvement.

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While States Collect Some
Information to Track
Funds, Many States Are
Not Able to Provide
Information on Which
Schools Receive Funds

Most states collect and track information on the use of school
improvement funds. Forty-eight states reported on our survey that they
collect information on the expenditure of Title I school improvement
funds at least annually from schools, districts, or other sources. Twentyfour states reported collecting expenditure information on each school
receiving improvement funds. Other states reported collecting expenditure
information from districts that provide aggregate information for all
schools that received improvement funds in the district, rather than for
each school receiving improvement funds. Seventeen states reported that
district officials monitor school improvement funds by comparing
activities that were funded to those identified in school improvement
plans. For example, some district officials we visited said they compare
school improvement expenditures to the school improvement plan before
approving disbursements. Forty-five states reported that state or district
officials conduct visits or monitor through other means how school
improvement funds were expended and what school improvement
activities were funded. State officials from 14 states reported that
monitoring was conducted in multiyear cycles rather than annually or that
a portion of schools were monitored annually. For example, as part of
Ohio’s monitoring and review process, officials said that district cohorts
are reviewed every 3 years with on-site reviews conducted at a minimum
of 10 percent of the cohort.
While most states monitor funds, 4 states were unable to make publicly
available the complete list of schools receiving improvement funds, as
required under NCLBA, because these states do not collect information on
each school receiving improvement funds, and Education has not provided
guidance on this requirement.30 Almost all states were able to provide a list
of schools receiving funds to us, but 3 states—Arkansas, Florida, and
North Carolina—provided information on districts that received funds, but
could not provide information on which schools received funds, and
California provided a partial list of schools that received funds. In a few
cases, we found that non-Title I schools had inappropriately received Title
I school improvement funds. State officials said that they would take steps
to address this issue, and we referred this matter to Education, which is
following up on it. Though Education monitors the allocation of school
improvement funds through its 3-year Title I monitoring cycle, Education
officials told us they had not uncovered these issues. In addition,
Education does not regularly check when and whether states have made

30

20 U.S.C. § 6303(f).

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the lists of schools receiving improvement funds publicly available, as
required, and has not provided guidance on how states make lists of
schools receiving improvement funds publicly available.

Schools and States
Are Engaged in a
Variety of
Improvement
Activities and Mainly
Assess Them Using
Student Achievement
Data and Feedback

Schools that received funds and states have employed a range of
improvement activities, and most states assess these activities by
reviewing trends in student achievement data and obtaining feedback from
district and school officials. At least 45 states reported that schools that
received school improvement funds were involved in professional
development, reorganizing curriculum or instructional time, or data
analysis. Nearly all states reported that they assisted schools identified for
improvement with school improvement plans and professional
development, and officials in 42 states consider this assistance key to
helping schools improve. To assess school improvement activities, 42
states reported that they track student achievement data or school
performance trends, and 36 of those states also use feedback from school
and district officials.

Schools That Received
Funds Have Undertaken a
Variety of Improvement
Activities, and States Have
Provided Support for Many
of These Activities

Nearly all states reported on our survey that schools that received
improvement funds in school year 2006-2007 were engaged in activities
such as professional development and data analysis, and districts and
schools we visited also cited these and other activities. Forty-seven states
reported that schools receiving improvement funds were taking part in
professional development, 46 states said schools were reorganizing
curriculum or instructional time, and 45 states reported that schools were
using data analysis from the state’s assessment system or other
assessments. School officials in each state we visited also cited using
school improvement funds for professional development activities. For
example, at one school in California, staff received intensive training in
instructional strategies and data analysis software, which was designed to
help teachers analyze instructional practices and provided teachers with
specific steps to increase student achievement. In addition, schools and
districts in every state we visited mentioned using coaches who are
generally former principals, teachers, or other subject area specialists who
work with school administrators or teachers. School officials in Michigan
noted that coaches had served as a key resource in the development of
school improvement plans. In some of the schools and districts we visited,
officials pointed to the importance of examining test scores and student
data in helping schools improve. For example, a school district in Ohio
provided school leaders and teachers immediate access to test scores and

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other information such as curriculum, professional development
resources, and student records online to help track student achievement.
While over 40 states reported that they assisted schools identified for
improvement with the school improvement plan, professional
development, and data analysis, or provided help from school support
teams, states generally reported providing more assistance to schools in
later stages of improvement (See fig. 8). In New Mexico, for example, all
schools identified for improvement are required to conduct certain
activities such as short cycle assessments several times a year, while
schools in restructuring are also required to send staff to training in areas
such as principal leadership. As another example, 44 states reported that
they provided assistance from school support teams to schools in
corrective action and restructuring, compared to 34 states that reported
providing this assistance to schools in earlier stages of improvement. The
only area in which states said they provided slightly more assistance to
schools in earlier stages of improvement was helping with the school
improvement plan.

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Figure 8: Differences in Types of Assistance States Provided to Schools in Different
Stages of Improvement
Type of assistance
50

School improvement plans
47
41

Professional development

46
44

Data analysis

44
34

School support teams

44
34

Instructional experts

40
32

Curriculum and instructional
alignment with state standards

36
35

Curriculum and
assessment materials

35

0

5

10

15

20

25

30

35

40

45

50

Number of states
Schools offering public school choice and SES
Schools in corrective action and restructuring
Source: GAO survey of states.

Forty-two states considered helping schools identified for improvement
with the school improvement plan and professional development to be
somewhat to very effective forms of state support. For example, many
states provided schools and districts a template for improvement plans,
which can help ensure some consistency in plans across the state. In Ohio,
state officials showed us an electronic tool that they developed for both
district improvement plans and school improvement plans that they said
have been useful in aligning district and school improvement plans.

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States Primarily Use
Student Achievement Data
and Feedback from
Districts and Schools to
Assess Improvement
Activities

Forty-two states reported that they tracked changes in student
achievement data or school performance trends, and 36 of those states
also used feedback from district and school officials to assess
improvement activities. For example, Michigan officials said they require
schools to provide student achievement data annually and to describe
which improvement activities were working as well as what changes they
planned to make. We also found that some states we visited conduct more
extensive reviews of schools in corrective action and restructuring that
include site visits, assessments, and observation of staff and leadership.
Most districts and schools we visited also focus on student achievement
data to assess activities. One school in Georgia has students take interim
practice tests using questions similar to those of the state’s annual
assessment to track students’ progress. The school has a “data room” that
has test scores and other data by grade level and subgroups displayed in
lists, graphs, and charts to track progress and serve as a visual reminder of
its overall goals. (See fig. 9.) At the district and school levels, officials in
every state we visited emphasized the importance of using the school
improvement plans to identify specific actions and goals, and many use the
plan to monitor progress and make adjustments as needed.

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Figure 9: Example of a Middle School’s Data Room to Track Students’ Progress

Source: GAO.

Twenty-four states reported that they conduct evaluations, either on the
state, district, or school level to assess activities. Based on information
provided by some states, these assessments were not in line with
Education’s definition of high-quality reviews of educational effectiveness
but included approaches to assess activities and track school
improvement.31 In some cases, states we visited told us they are working

31
On its What Works Clearinghouse, Education defined high-quality reviews as those that
include randomized controlled trials and quasi-experimental designs, among others.
Randomized controlled trials are studies in which participants are randomly assigned to an
intervention group that receives or is eligible to receive the intervention and a control
group that does not receive the intervention. Quasi-experimental designs are primarily
designs in which participants are not randomly assigned to the intervention and
comparison groups, but the groups are compared to each other.

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with or plan to work with an independent evaluator or other entity to
conduct a more formal evaluation of school improvement activities.

Education Provides a
Range of Support for
School Improvement,
Including Some New
Efforts Aimed at
Areas in Which States
Want More Help

Education directly supports states with school improvement through
written guidance, staff assistance, policy letters, and information provided
at national conferences. In July 2006, Education published nonregulatory
guidance on district and school improvement that updated and expanded
its earlier guidance in this area.32 Education staff also provide direct
assistance by responding to states’ questions. In some cases, Education
officials said they send policy letters to individual states to address statespecific questions and post the letters on its Web site. For example, one
state requested clarification from Education on allocating Title I school
improvement funds to districts, and Education responded with a policy
letter. In addition, Education also provides guidance and disseminates
information through national conferences such as the annual Title I
National Conference.
In addition to direct support, Education provides a number of technical
assistance and research-related resources to assist states, districts, and
schools in their school improvement efforts. These include the
Comprehensive Centers Program, Regional Education Laboratories, the
Center for Comprehensive School Reform and Improvement, the What
Works Clearinghouse, and a new Doing What Works Web site.
(See fig. 10).

32

See Education’s LEA and School Improvement: Non-Regulatory Guidance (Washington,
D.C.: July 21, 2006).

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Figure 10: Education’s Technical Assistance and Research-Related Resources That Support School Improvement Efforts

National content centers

Regional comprehensive assistance centers

Assessment and
accountability

Alaska

New England

Appalachia

New York

High schools

California

North Central

Innovation and
improvement

Florida and islands

Northwest

Great Lakes East

Pacific

Instruction

Great Lakes West

Southeast

Teacher quality

Mid-Atlantic

West/Southwest

Mid-Continent

Texas

Region educational
laboratories
Appalachia

States

Central

Districts

Schools

Mid-Atlantic

Center for
Comprehensive
School Reform
and Improvement

Midwest
Northeast and islands
Northwest
Pacific
Southeast

What works
clearinghouse

Southwest

Doing
what works

West
Web-based

Web-based

Source: GAO analysis of Education information; images, Art Explosion.

Note: While Education has some additional efforts to support student achievement, the resources
shown above represent those most related to school improvement.

•

Education provides a number of services to states through its
Comprehensive Centers Program—consisting of 16 regional centers

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and 5 content centers.33 The regional centers are located across the
country and provide training and technical assistance to address state
needs and priority areas, which largely focus on school improvement.
Each of the 5 content centers focuses on one of the following areas:
accountability, instruction, teacher quality, innovation and
improvement, or high schools. The content centers provide expertise,
analysis, and research in the five content areas. According to an
Education official, a key focus of the comprehensive centers is helping
states build their statewide systems of support. Currently, the
comprehensive centers have 8 regional initiatives and 35 individual
state initiatives related to this topic. In addition, there are 2 regional
initiatives and 26 individual state initiatives to address district and
school improvement.
•

One content center, the Center on Innovation and Improvement,
provides a variety of services related to school improvement. The
center gathers data and information on districts and schools making
sustained gains to identify successful improvement strategies. It has
developed two guides on this topic, a Handbook on Restructuring and
Substantial School Improvement and a Handbook on Statewide
Systems of Support, which it has distributed to regional centers, state
educational agencies, and other organizations.34 The center also
facilitates information sharing on school improvement topics through
its annual 2-day training for representatives of the regional centers and
additional workshops throughout the year. In addition, the center
collaborates with the Council of Chief State School Officers to issue
monthly School Improvement e-newsletters, which focus on school
improvement efforts at the state and district levels.

•

Education also compiles and disseminates relevant research on
effective educational interventions. Education operates 10 Regional
Education Laboratories to provide research on a variety of topics, such
as statewide systems of support and factors that have helped schools
make AYP. The laboratories are also available to provide assistance to

33

Education replaced its former Comprehensive Regional Assistance Centers, the Regional
Technology in Education Consortia, the Eisenhower National Clearinghouse for
Mathematics and Science Education, and the Regional Mathematics and Science Education
Consortia with its Comprehensive Centers Program.
34

See Herbert J. Walberg, editor. Handbook on Restructuring and Substantial School
Improvement (Center on Innovation and Improvement, Lincoln, Illinois: 2007), and Sam
Redding and Herbert J. Walberg, editors. Handbook on Statewide Systems of Support
(Center on Innovation and Improvement, Lincoln, Illinois: 2007).

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any entity, such as school districts or schools, if they request
assistance. Education also funds the Center for Comprehensive School
Reform and Improvement to assist schools and districts in
implementing comprehensive school reform and improvement by
providing information about research-based strategies and assistance
in using that information to make changes. In addition, Education
developed the What Works Clearinghouse to review studies of
educational interventions to determine which studies were conducted
with a sound methodology and to what extent the interventions are
effective. In November 2007, Education implemented a Doing What
Works Web site to help educators adapt and use the research-based
practices identified by the What Works Clearinghouse.
State officials reported that Education’s written guidance, national
meetings or conferences, and comprehensive centers were the most
helpful forms of assistance and the What Works Clearinghouse was
relatively less helpful (See fig. 11.) For example, in several states we
visited, state officials told us that comprehensive centers have been
helpful in areas such as building state school improvement capacity and
facilitating discussions with other states. Although 15 states reported that
the What Works Clearinghouse was moderately to very helpful, 20 states
reported that it provided some to no help. District officials said that it has
not been useful for reasons such as it is difficult to figure out how to
translate the research on the What Works Clearinghouse into practical
application at the classroom level.

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Figure 11: Extent to Which States Found Assistance from Education Helpful
Type of assistance
9

Written guidance on
school improvement

42
5

Center for Comprehensive School
Reform and Improvement

31
11

Regional and comprehensive
centers

33
13

National conferences

34
12

Technical assistance from
Department of Education staff

28
22

What Works Clearinghouse

19
0

5

10

15

20

25

30

35

40

45

50

Number of states
Some to no help
Moderately to very helpful
Source: GAO survey of states.

Almost all states also reported that they could benefit from additional
assistance from Education. Fifty states reported that they could benefit
from more tool kits and sample documents, and 48 states said they could
benefit from more national or regional conferences to share lessons
learned and promising practices. Education officials said that they have
also heard that states want more opportunities to share information and
are looking for ways to do this. Forty-three states also reported that they
could use additional assistance in evaluating the effectiveness of school
improvement activities, and 42 states said they could benefit from more
help with monitoring and assessing school improvement activities.
Education has taken steps to address concerns about the What Works
Clearinghouse and to provide additional resources aimed at addressing
areas in which states want more help. An Education official told us that
the recently implemented Doing What Works Web site is aimed at helping
educators adapt and use the research-based practices on the What Works
Clearinghouse. To do this, the Doing What Works Web site provides the
following: (1) information to help make the research on effective practices
more understandable for educators, (2) links to real-life examples such as

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interviews with teachers and pictures from classrooms to help show the
practices in action, and (3) tools and resources that educators can use in
their own planning and training efforts. As far as providing more help on
monitoring and evaluating school improvement activities, Education
officials told us that they plan to collect additional information about
successful school improvement practices as part of the new school
improvement grants—authorized under NCLBA and funded for the first
time in 2007. States receiving these grants will be required to track and
report outcomes such as increased student proficiency and how school
improvement activities helped schools improve. Education plans to
compile this information and discuss this topic at a meeting of state Title I
directors in early 2008. In addition, the Administration, as part of its
proposed revision to the school improvement section of NCLBA, is
recommending that Education be allowed to reserve up to 1 percent of
Title I funds to conduct research, evaluation, and dissemination activities
related to effective school and district school improvement activities.

Conclusions

While the hold-harmless provision is intended to shield districts from
receiving less in Title I funds than in the previous year as a result of the
school improvement set-aside, we found some evidence that it may be
preventing some of the neediest schools that face the most challenges to
improving the academic achievement of their students from obtaining
these funds. When states cannot set aside the full 4 percent of Title I for
school improvement, their ability to target funds at the lowest-performing
schools is diminished. Effectively, the hold-harmless provision prioritizes
preserving the Title I funding of all eligible Title I districts over ensuring
that the lowest-performing schools receive funds for school improvement.
Furthermore, the variability from year to year in state Title I funds can
affect some states’ ability to sustain a steady stream of support for lowperforming schools. Removing the hold-harmless provision, as Education
has proposed, would clearly increase states’ ability to target improvement
funds to the lowest-performing schools. However, while Education points
out that set-aside funds come from districts with increasing Title I
allocations, it is still not known how removing the hold-harmless provision
would affect those districts protected by it. It would be helpful for
Congress as it deliberates reauthorization of NCLBA to know the
characteristics of districts that contribute to the set-aside compared to
those that are protected by the hold-harmless provision, particularly in
terms of student characteristics and school performance.
Thousands of schools have received Title I school improvement funds
intended to help schools raise student achievement, and states have

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generally targeted these funds to schools with the most persistent
achievement problems. However, without additional monitoring steps by
Education to ensure that states are appropriately allocating funds for
district-level activities and prioritizing funds to the lowest-achieving
schools, some schools most in need of assistance may not receive funding.
While Education monitors every state’s improvement program every 3
years, it has not uncovered several compliance issues that we identified.
Further, because some states do not track which schools receive
improvement funds and could not make this information publicly
available, as required under NCLBA, Education and others have not been
in the best position to ensure that school improvement funds are used only
for Title I schools and targeted to the lowest-performing schools. Ensuring
that states track which schools receive improvement funds and can make
this information publicly available enhances transparency and
accountability, and better enables the public, Education, and states to
track compliance and progress.

Recommendations for
Executive Action

To enhance state efforts to target improvement funds to schools most in
need of assistance, we are making the following three recommendations to
the Secretary of Education:
•

To further support the department’s proposal to eliminate the holdharmless provision, develop an analysis comparing the characteristics
of districts that contribute to the set-aside with those protected by the
hold-harmless provision. Such an analysis could identify differences in
school performance or student characteristics.

•

Review the Title I monitoring process to ensure that steps are in place
to ensure that states comply with NCLBA requirements for allocating
school improvement funds to districts for district-level activities and
prioritizing funds to the lowest performing schools.

•

Ensure that states track which schools receive improvement funds and
can comply with the requirement to make a list publicly available of all
schools receiving Title I improvement funds by providing guidance to
clarify when and how this information is to be made available and by
monitoring state compliance.

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Agency Comments
and Our Evaluation

We provided a draft of this report to the Department of Education for
review and comment. In its written response, included as appendix II,
Education agreed with our three recommendations. Specifically,
Education agreed to explore options to determine the types of analyses
that would be helpful to inform the debate on eliminating the holdharmless provision. Education also agreed to review its monitoring
process and consider changes to gather additional evidence on whether
school improvement funds are being allocated and prioritized as required
by statute. In addition, Education agreed that it will explore options for
providing guidance to states on the NCLBA requirement that states make
publicly available a list of all schools receiving Title I school improvement
funds. Education also identified some of the steps it has taken to collect
additional information on the allocation and use of school improvement
funds and to identify successful school improvement strategies.
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 at (202) 512-7215 if you or your staff have any questions
about this report. Other contacts and major contributions are listed in
appendix IV.
Sincerely yours,

Cornelia M. Ashby
Director,
Education, Workforce, and
Income Security Issues

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Appendix I: Scope and Methodology

Appendix I: Scope and Methodology

To address the objectives of this study, we used a variety of methods. To
obtain nationally representative information on states’ school
improvement funding, types of activities being funded, and federal
assistance, we administered a survey to state education agency officials in
all 50 states and the District of Columbia. To get a national perspective of
schools in improvement, we conducted descriptive analyses of
characteristics of schools that received improvement funds and compared
them to all schools identified for improvement and all other Title I schools
nationwide. We also conducted site visits during which we interviewed
state, district, and school officials representing 5 states and 12 school
districts within these states. We spoke with officials at Education involved
in oversight and distribution of school improvement funds and reviewed
Education’s data on schools identified for improvement. We also
interviewed several experts in the field of school improvement. We
reviewed relevant federal laws, regulations, and agency guidance. We
conducted our work from January 2007 through February 2008 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.

Survey of States

To better understand states’ school improvement efforts, particularly how
states are allocating and tracking school improvement funds and activities,
we designed and administered a survey to state education agency officials
in all 50 states and the District of Columbia between July and October
2007 and had a 100 percent response rate.
The survey included questions on the amount of Title I improvement funds
states have reserved and expended, what other federal or state funds are
being used, what types of improvement activities are being funded, how
activities are being monitored and assessed, and assistance received from
Education.
Because this was not a sample survey, there are no sampling errors.
However, the practical difficulties of conducting any survey may introduce
nonsampling errors, such as variations in how respondents interpret
questions and their willingness to offer accurate responses. We took steps
to minimize nonsampling errors, including pretesting draft instruments
and following up with states to discuss questionable responses.
Specifically, during survey development, we pretested draft instruments

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Appendix I: Scope and Methodology

with officials in Rhode Island, Ohio, Illinois, Montana, and Florida
between May and June 2007. In the pretests, we were generally interested
in the clarity of the questions and the flow and layout of the survey. For
example, we wanted to ensure that definitions used in the surveys were
clear and known to the respondents, categories provided in closed-ended
questions were complete and exclusive, and the ordering of survey
sections and the questions within each section were appropriate. On the
basis of the pretests, the survey instrument underwent some slight
revision. A second step we took to minimize nonsampling errors was
contacting state officials via phone and e-mail to follow up on obvious
inconsistencies, errors, and incomplete answers. We also performed
computer analyses to identify inconsistencies in responses and other
indications of error. In addition, a second independent analyst verified
that the computer programs used to analyze the data were written
correctly.

Education and State Data

For our analysis, we used data from three sources—state-provided data on
schools that received Title I improvement funds in each state, Education’s
Common Core of Data (CCD), and Education’s Consolidated State
Performance Reports (CSPR). For comparison, we created three discrete
groups of schools: (1) schools identified for improvement that received
funds and services, (2) schools identified but not receiving funds and
services, and (3) all other Title I schools that were not identified for
improvement for school year 2005-2006.
To obtain information on the characteristics of schools receiving school
improvement funds, we requested information from each state on the
schools identified for school choice, supplemental educational services,
corrective action, or restructuring in their respective state that received
Title I set-aside school improvement funds or services pursuant to
§1003(a) of the No Child Left Behind Act (NCLBA) during the 2004-2005,
2005-2006, and 2006-2007 school years. We also asked states to indicate the
percentage of students from families with incomes below the poverty line
for each school that received improvement funds during the 3 school-year
time frame. In addition, we asked states to provide information on each
school that included (1) the school’s full name; (2) the school’s address,
city, and state; (3) the school’s district name; and (4) the school’s National
Center for Education Statistics (NCES) school identification; (5) the
school’s year of improvement under NCLBA: first year of improvement
(school choice), second year of improvement (school choice and
supplemental educational services), third year of improvement (school
choice, supplemental educational services, and corrective action), fourth

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Appendix I: Scope and Methodology

year of improvement (school choice, supplemental educational services,
and plan for restructuring), or fifth year of improvement (school choice,
supplemental educational services, and implementing a restructuring
plan); and (6) we asked states, if possible, to provide the amount of Title I
set-aside funds (and any other federal/state improvement funds, if
applicable) that each school received.
Three states were unable to provide this information, and 1 state provided
partial information, so our data on school characteristics are presented
only for those states that provided this information.1 We reviewed the lists
of schools receiving improvement funds for obvious inconsistencies,
errors, and completeness. When we found discrepancies, we brought them
to the attention of state officials and worked with them to correct the
discrepancies before conducting our analyses. On the basis of these
efforts, we determined that the data were sufficiently reliable for the
purposes of this report.
Our other two data sources were data from Education’s CCD and CSPR.
The CCD is a program of Education’s National Center for Education
Statistics that annually collects data from state education agencies about
all public schools, public school districts, and state education agencies in
the United States. At the time we began our analysis, the latest CCD data
available were from the 2005-2006 school year. Although we based our
analysis on schools in improvement in 2006-2007, the characteristics were
based on those of the prior year. To compare the characteristics of schools
that received improvement funds to those of all schools in improvement
and all Title I schools for 2005-2006, we used data from CSPR, which is the
required data tool for each state, the District of Columbia, and Puerto Rico
and contains lists of schools identified for improvement by state. The
CSPR also provides each school’s nationally unique identification number,
allowing us to link data on these schools with data provided in the CCD.
For our analysis, we excluded Puerto Rico, Arkansas, Florida, and North
Carolina because they could not provide information on which schools
received funds. In addition, we did not have complete information from
California because state officials provided a partial list of schools that
received funds. We compared schools in improvement from the CCD for
school year 2005-2006 with all other Title I eligible schools not identified

1
Arkansas, Florida, and North Carolina provided information on districts that received
funds, but could not provide information on which schools received funds, and California
provided a partial list of schools that received funds.

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Appendix I: Scope and Methodology

for improvement. We also compared states’ lists of schools in
improvement that received funds or services from the 2005-2006 CSPR
with lists of schools that were in improvement but did not receive funding
or services.
We performed a series of tests and took additional steps as needed to
assess the reliability of the data used. Specifically, we assessed the
reliability of the data by (1) examining the data for obvious
inconsistencies, (2) reviewing existing information about the data and the
system that produced them, and (3) interviewing agency officials
knowledgeable about the data. We determined that the data were
sufficiently reliable for the purposes of this report.

Site Visits

To understand school improvement funding and implementation at the
local level, we conducted site visits to 5 states and 12 districts and 22
schools within these states between April and October 2007. The states we
chose were California, Georgia, Michigan, New Mexico, and Ohio, which
were selected based on having high percentages of schools identified for
improvement, variation in Title I set-aside funding allocation methods and
administrative structures, and geographic diversity. We interviewed state
officials on states’ efforts to allocate federal and state school improvement
funds, provide assistance to schools identified for improvement, and
Education’s assistance to states.
Within each of the 5 states, we met officials from 2 school districts, and in
Michigan, we met with officials from 4 school districts for a total of 12
school districts, as shown in table 8. The 12 districts were selected to
provide variety in demographics, geographic location, and stages of
improvement.
Table 8: School Districts Selected for Site Visits
School district

City, state

Albuquerque Public Schools

Albuquerque, New Mexico

Columbus City Schools

Columbus, Ohio

DeKalb County School System

Decatur, Georgia

Detroit Public Schools

Detroit, Michigan

Grand Rapids Public Schools

Grand Rapids, Michigan

Hall County Schools

Gainesville, Georgia

Kent Intermediate School District

Grand Rapids, Michigan

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Appendix I: Scope and Methodology

School district

City, state

Lodi Unified School District

Lodi, California

Portsmouth City School District

Portsmouth, Ohio

Roswell Independent School District

Roswell, New Mexico

Wyoming Public Schools

Wyoming, Michigan

Yuba City Unified School District

Yuba City, California

Source: GAO.

During the site visits, we interviewed state and district officials as well as
officials representing 22 schools, including principals, teachers, and other
school staff involved with school improvement activities in order to
provide in-depth information and illustrative examples of our more general
findings. The selected schools represented varying stages of
improvement, grade levels served, and locales. While, in many cases,
district officials selected the schools we visited, we instructed state and
district officials to consider each school’s stage of improvement and
percentage of economically disadvantaged students, among other
characteristics. Through our interviews with state, district, and school
officials, we collected information on school improvement funding, school
improvement activities being undertaken, and state and district assistance
to schools identified for improvement.

Education and Expert
Interviews and Studies

To learn more about Education’s oversight of Title I school improvement
funds and efforts to assist states in implementation of school improvement
provisions, we conducted interviews with representatives of the offices of
Student Achievement and School Accountability Programs; Planning,
Evaluation, and Policy Development; Institute of Education Sciences;
Office of School Support and Technology Programs; and the Office of
General Counsel.
In addition, we interviewed experts on school improvement, including
those at the American Institutes for Research, Center on Education Policy,
Council of Chief State School Officers, and the National Governors
Association. We also reviewed several studies on school improvement
funding and activities.

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Appendix II: Comments from the Department
of Education

Appendix II: Comments from the Department
of Education

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GAO-08-380 No Child Left Behind Act

Appendix II: Comments from the Department
of Education

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GAO-08-380 No Child Left Behind Act

Appendix III: GAO Contacts and
Acknowledgments

Appendix III: GAO Contacts and
Acknowledgments
GAO Contact

Cornelia M. Ashby, (202) 512-7215, ashbyc@gao.gov

Acknowledgments

Bryon Gordon, Assistant Director, and Laura Heald, Analyst-in-Charge,
managed the assignment. Cheri Harrington, Cara Jackson, Charlene
Johnson, and Nathan Myers made significant contributions to this report
in all aspects of the work. Shannon Groff and Ayeke Messam provided
assistance in data collection; Cathy Hurley, Stuart Kaufman, and Jean
McSween provided analytical assistance; Charlie Willson provided
assistance on report preparation; Sheila McCoy provided legal support;
Tina Cheng and Mimi Nguyen developed the report’s graphics; and Lise
Levie verified our findings.

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GAO-08-380 No Child Left Behind Act

Related GAO Products

Related GAO Products

No Child Left Behind Act: Education Should Clarify Guidance and
Address Potential Compliance Issues for Schools in Corrective Action
and Restructuring Status. GAO-07-1035. Washington, D.C.: September 5,
2007.
Teacher Quality: Approaches, Implementation, and Evaluation of Key
Federal Efforts. GAO-07-861T. Washington, D.C.: May 17, 2007.
No Child Left Behind Act: Education Actions May Help Improve
Implementation and Evaluation of Supplemental Educational Services.
GAO-07-738T. Washington, D.C.: April 18, 2007.
No Child Left Behind Act: Education Assistance Could Help States Better
Measure Progress of Students with Limited English Proficiency.
GAO-07-646T. Washington, D.C.: March 23, 2007.
Reading First: States Report Improvements in Reading Instruction, but
Additional Procedures Would Clarify Education’s Role in Ensuring
Proper Implementation by States. GAO-07-161. Washington, D.C.:
February 28, 2007.
No Child Left Behind Act: Education Actions Needed to Improve
Implementation and Evaluation of Supplemental Educational Services.
GAO-06-1121T. Washington, D.C.: September 21, 2006.
No Child Left Behind Act: Education Actions Needed to Improve Local
Implementation and State Evaluation of Supplemental Educational
Services. GAO-06-758. Washington, D.C.: August 4, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic
Growth. GAO-06-948T. Washington, D.C.: July 27, 2006.
No Child Left Behind Act: Assistance from Education Could Help States
Better Measure Progress of Students with Limited English Proficiency.
GAO-06-815. Washington, D.C.: July 26, 2006.
No Child Left Behind Act: States Face Challenges Measuring Academic
Growth That Education’s Initiatives May Help Address. GAO-06-661.
Washington, D.C.: July 17, 2006.
No Child Left Behind Act: Improved Accessibility to Education’s
Information Could Help States Further Implement Teacher Qualification
Requirements. GAO-06-25. Washington, D.C.: Nov. 21, 2005.

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GAO-08-380 No Child Left Behind Act

Related GAO Products

No Child Left Behind Act: Education Could Do More to Help States Better
Define Graduation Rates and Improve Knowledge about Intervention
Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005.
No Child Left Behind Act: Most Students with Disabilities Participated
in Statewide Assessments, but Inclusion Options Could Be Improved.
GAO-05-618. Washington, D.C.: July 20, 2005.
No Child Left Behind Act: Education Needs to Provide Additional
Technical Assistance and Conduct Implementation Studies for School
Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004.
No Child Left Behind Act: Improvements Needed in Education’s Process
for Tracking States’ Implementation of Key Provisions. GAO-04-734.
Washington, D.C.: Sept. 30, 2004.
No Child Left Behind Act: Additional Assistance and Research on
Effective Strategies Would Help Small Rural Districts. GAO-04-909.
Washington, D.C.: Sept. 23, 2004.
No Child Left Behind Act: More Information Would Help States
Determine Which Teachers Are Highly Qualified. GAO-03-631.
Washington, D.C.: July 17, 2003.

(130638)

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GAO-08-380 No Child Left Behind Act

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