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entitled 'No Child Left Behind Act: More Information Would Help States 
Determine Which Teachers Are Highly Qualified' which was released on 
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Report to Congressional Requesters:

United States General Accounting Office:

GAO:

July 2003:

No Child Left Behind Act:

More Information Would Help States Determine Which Teachers Are Highly 
Qualified:

GAO-03-631:

GAO Highlights:

Highlights of GAO-03-631, a report to Congressional Requesters 

Why GAO Did This Study:

In December 2001, Congress passed the No Child Left Behind Act (NCLBA). The act required that all teachers of core subjects be highly qualified by the end of the 2005-06 school year and provided funding to help states and districts meet the requirement. In general, the act requires that teachers have a bachelor’s degree, meet full state certification, and demonstrate subject area knowledge for every core subject they teach.  This report focuses on the (1) number of teachers who met the highly qualified criteria during the 2002-03 school year, (2) conditions that hinder states’ and districts’ ability to meet the requirement, and (3) activities on which states and districts were planning to spend their Title II funds. GAO surveyed 50 states and the District of Columbia and a nationally representative sample of districts about their plans to implement the requirement. GAO also visited and interviewed officials in 8 states and 16 districts to discuss their efforts to implement the law.

What GAO Found:


GAO could not develop reliable data on the number of highly qualified 
teachers because states did not have the information needed to 
determine whether all teachers met the criteria. Officials from 8 
states visited said they did not have the information they needed to 
develop methods to evaluate current teachers’ subject area knowledge 
and the criteria for some teachers were not issued until December 
2002. Officials from 7 of 8 states visited said they did not have data 
systems that could track teacher qualifications for each core subject 
they teach. 

Both state and district officials cited many conditions in the GAO 
survey that hinder their ability to have all highly qualified 
teachers. State and district officials reported teacher pay issues, 
such as low salaries and lack of incentive pay, teacher shortages, and 
other issues as hindrances. GAO’s survey estimates show that 
significantly more high-poverty than low-poverty districts reported 
hindrances, such as little support for new teachers. Rural district 
officials cited hindrances related to their size and isolated 
locations. State officials reported they needed assistance or 
information from Education, such as in developing incentives to teach 
in high-poverty schools, and Education’s strategic plan addresses some 
of these needs.

To help meet the requirement for highly qualified teachers, state 
survey respondents reported they planned to spend about 65 percent of 
their Title II funds on professional development activities authorized 
under Title II, and districts planned to spend an estimated 66 percent 
on recruitment and retention. Both state and district officials 
planned to spend much larger amounts of funds from sources other than 
Title II funds on such activities. High-poverty districts planned to 
spend more Title II funds on recruitment and retention than low-
poverty districts. State and district officials visited said that most 
activities were a continuation of those begun previously.

What GAO Recommends: 

To help states determine which teachers are highly qualified and the 
actions they need to take to meet the requirement, GAO recommends that 
the Secretary of Education provide more information to states, 
especially on ways to evaluate the subject area knowledge of current 
teachers. The Department of Education provided written comments on a 
draft of this report and generally agreed with GAO’s recommendation.

www.gao.gov/cgi-bin/getrpt?GAO-03-631.

To view the full product, including the scope and methodology, click 
on the link above. For more information, contact Marnie S. Shaul, 512-
7215, shaulm@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Many States Were Uncertain about Numbers of Highly Qualified Teachers:

State and District Officials Reported Many Conditions as Hindrances to 
Meeting the Law:

To Help Teachers Meet the Requirement States Planned to Spend Most 
Title II Funds on Professional Development Activities, and Districts 
Will Spend Most on Recruitment and Retention Activities:

Conclusions:

Recommendation for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: Activities on Which States Can Spend Title II, Part A 
Funds:

Appendix III: Activities on Which Districts Can Spend Title II, Part A 
Funds:

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

Appendix V: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Tables:

Table 1: Federal Criteria for a Highly Qualified Teacher:

Table 2: Estimated Percentages of Districts That Will Have Difficulty 
Meeting the Requirement for Highly Qualified Teachers by Grade Level 
and Poverty:

Table 3: Number of States Reporting on Conditions That Hinder Their 
Ability to Meet the Requirement for Highly Qualified Teachers (Ranked 
from Highest to Lowest):

Table 4: Estimated Percentages of Districts Reporting on Conditions 
That Hinder Their Ability to Meet the Requirement for Highly Qualified 
Teachers (Ranked from Highest to Lowest):

Table 5: Estimated Percentages of High-and Low-Poverty Districts with 
Significant Differences in the Hindrances to Meeting the Requirement:

Table 6: Estimated Percent of Spending Title II Funds by Activities for 
All Districts, High-Poverty Districts, and Low-Poverty Districts:

Table 7: Population and Sample by Stratum:

Table 8: Sample Estimates Compared to Population Values:

Table 9: Population and Sample by Region:

Table 10: Title II, Part A State Activities:

Table 11: Title II, Part A District Activities:

Figures:

Figure 1: Education's Assistance to States During Calendar Year 2002:

Figure 2: Planned Spending of Title II Funds by Reporting States:

Figure 3: Sources of Funds for Planned Spending by States on Title II 
Activities:

Figure 4: Estimated Spending of Title II Funds as a Percentage of Total 
Funds by Activities for All Districts, High-Poverty Districts, and Low-
Poverty Districts:

Figure 5: State Survey Respondents:

Abbreviations:

CCD: Core of Common Data:

CCSSO: Council of Chief State School Officers:

CMSA: Consolidated Metropolitan Statistical Area:

LEA: Local Education Agency:

MSA: Metropolitan Statistical Area:

NCLBA: No Child Left Behind Act:

United States General Accounting Office:

Washington, DC 20548:

July 17, 2003:

The Honorable Edward M. Kennedy 
The Honorable Jeff Bingaman 
United States Senate:

In December 2001, Congress passed the No Child Left Behind Act (NCLBA), 
which, among other things, focused attention on closing the achievement 
gaps among various groups of students. Recently, a body of research has 
shown that quality teachers play a significant role in improving 
student performance. However, research has also shown that many 
teachers, especially those in high-poverty and rural 
districts,[Footnote 1] were not certified and lacked knowledge of the 
subjects they taught. NCLBA established the requirement that all 
teachers be highly qualified for each core subject they teach by the 
end of the 2005-06 school year.[Footnote 2] The criteria for meeting 
this requirement vary somewhat by grade level and experience but 
generally require that teachers have (1) a bachelor's degree, (2) state 
certification, and (3) subject area knowledge for each core subject 
they teach. This represents the first time the federal government has 
established specific criteria for teachers. Title II, Part A, of NCLBA 
replaced the Eisenhower Professional Development and Class Size 
Reduction programs with the Teacher and Principal Training and 
Recruiting Fund and Congress appropriated $2.85 billion to help states 
and districts meet the requirement. In addition, Title II directed 
these funds to be spent on specific activities to help states and 
districts recruit, retain, and develop highly qualified teachers. The 
Department of Education (Education) administers Title II and is 
responsible for oversight of states' implementation of NCLBA.

Given the need for states and districts to meet the requirement for 
highly qualified teachers by the end of the 2005-06 school year, you 
asked us to determine what they were doing to have their teachers meet 
the requirement. Specifically, this report focuses on the (1) number of 
teachers who met the highly qualified teacher criteria during the 2002-
03 school year, (2) conditions that hinder states' and districts' 
ability to meet the requirement, and (3) activities on which states and 
districts were planning to spend their Title II funds.

In conducting our work, we surveyed 50 states and the District of 
Columbia. We obtained responses for 37 of these 51 surveys and reported 
the results as representing only those that responded. The student 
enrollment for the responding states represented 85 percent of total 
student population in kindergarten through 12th grade. In addition, we 
surveyed a nationally representative sample of 830 school districts. We 
received a response from 511 or 62 percent. We compared relevant 
characteristics of these respondents to the universe of districts and 
found them to be similar, which along with the response rate allowed us 
to report national estimates.[Footnote 3] For our comparisons of high-
and low-poverty districts, we included responding districts that had 70 
percent or more of their students approved for free and reduced-price 
meals as high-poverty and those with 30 percent or less of their 
students approved for free and reduced-price meals as low-poverty. We 
visited and interviewed officials in 8 states selected with a range of 
characteristics that might affect their ability to meet the 
requirement--California, Connecticut, Illinois, Iowa, Maryland, North 
Carolina, Delaware, and Wyoming. We visited 2 districts in each of the 
states and 1 school in each district. We interviewed U.S. Department of 
Education officials, and officials from professional organizations and 
unions that represent teachers. Additionally, we analyzed the 
legislation, related reports, and relevant documents. See appendix I 
for detailed information on the methodology. We conducted our work from 
July 2002 through May 2003 in accordance with generally accepted 
government auditing standards.

Results in Brief:

We could not develop reliable data on the number of highly qualified 
teachers because states did not have the information needed to 
determine whether all teachers met the criteria. During our visits 
state officials did not know the criteria for some of their teachers. 
Education's draft guidance on the criteria for teachers in alternative 
certification programs changed between June and December of 2002, which 
meant that states had to reassess their teachers' qualifications. 
Guidance for special education teachers was not available until 
December 2002, and it was contained in an appendix to the Title I 
regulations, but not in the federal regulations. Also, states did not 
have the information they needed to develop methods to evaluate subject 
area knowledge of their current teachers. In our survey, 32 of 37 state 
respondents said that they needed clear and timely guidance from 
Education. Additionally, officials from 7 of the 8 states we visited 
said they did not have data systems that could track teacher 
qualifications by subject, which they needed to determine if a highly 
qualified teacher taught each core subject. One official added a 
comment to the survey that said the state data system on teachers "was 
designed years ago for state certification purposes…[and] has not yet 
been updated to include all NCLBA criteria for teachers." Some state 
officials we interviewed also expressed reservations about changing 
their data systems before complete guidance was issued. Furthermore, 6 
of the 8 state officials were reluctant to say that their certified 
teachers might not be highly qualified because they believed it would 
harm teacher morale. Thus, we concluded that the survey data related to 
the number of highly qualified teachers would not likely be reliable.

Both state and district officials cited many conditions that hinder 
their ability to have all highly qualified teachers. Many state 
officials reported issues related to teacher pay, such as low salaries, 
lack of incentive pay programs, and a lack of career ladders as 
hindrances. For example, 32 of the 37 state officials responding to our 
survey said that teacher salaries were low compared with other 
occupations. During our visits officials said that salary issues 
particularly hindered their efforts to recruit and retain math and 
science teachers. Twenty-three of the 37 state officials reported 
teacher shortages in high need subject areas--mostly math, science, and 
special education. During the late 1990s, there was an increase in 
demand for workers with math and science backgrounds, especially in 
information technology, and these occupations generally paid higher 
salaries than teaching. Other hindrances cited by state officials 
included few programs to support new teachers, a lack of leadership 
from principals, and union agreements. Our survey estimates show that 
salary issues were also hindrances for the majority of the districts, 
and about 20 percent of all districts cited teacher development 
conditions such as (1) weak technology training for teachers, (2) few 
alternative certification programs, and (3) professional development 
programs of too short a duration to improve teacher quality. In 
addition, significantly more high-poverty than low-poverty districts 
identified some conditions as hindrances, according to our survey 
responses. For example, an estimated 30 percent of high-poverty 
districts compared to 6 percent of low-poverty districts cited few 
programs to support new teachers. Officials in rural districts we 
visited and who commented on the survey said they faced unusual 
conditions because some of them were very small, isolated, or had only 
one or two teachers in total at some schools. While many of the 
hindrances that state and district officials reported could not be 
addressed by Education, at least half of the state survey respondents 
indicated that Education could be more helpful. Specifically, they said 
they needed more information on, or assistance with, professional 
development programs, best practices related to teacher quality, and 
incentives for teachers to teach in high-poverty schools. Education has 
identified several steps it will take in its 2002-07 strategic plan 
related to these issues.

Title II provided funds to help meet the requirement for highly 
qualified teachers, and state survey respondents said they planned to 
spend most of their Title II funds on professional development 
activities while districts planned to spend the majority of their funds 
on recruitment and retention activities authorized under Title II. 
Generally, state educational agencies could use up to 2.5 percent of 
the state's Title II funds for authorized state activities. State 
officials reported they planned to spend 65 percent on professional 
development activities. These activities could help teachers enhance 
their subject area knowledge and complete state licensing requirements 
to meet the criteria for highly qualified teachers. States planned to 
spend much larger amounts of other federal and state funds than Title 
II funds on authorized state activities. For example, states reported 
that 85 percent of the total funds they planned to spend on 
professional development activities would come from other federal and 
state funds. Districts received about 95 percent of their state's Title 
II funds for authorized district activities. From our survey we 
estimated that districts planned to spend about two-thirds of their 
Title II funds on activities to help recruit and retain highly 
qualified teachers, with the remaining funds on activities for 
professional development. High-poverty districts planned to spend a 
larger percentage of Title II funds on recruitment and retention 
activities than low-poverty districts. For example, high-poverty 
districts planned to spend 77 percent of their Title II funds for 
recruitment and retention while low-poverty districts planned to spend 
59 percent. Recruitment and retention activities, such as establishing 
incentive pay programs and reducing class sizes, could help attract 
more highly qualified teachers to schools. Survey results also show 
that districts planned to spend much larger percentages of other 
federal, state, and local funds than Title II funds on authorized Title 
II activities. For example, an estimated 80 percent of the total funds 
all districts planned to spend on professional development came from 
other federal, state, and local funds. During our visits, both state 
and district officials said that most activities were a continuation of 
those begun in previous years.

In order to help states meet the requirement for highly qualified 
teachers by the end of the 2005-06 school year, we recommend that the 
Secretary of Education provide more information on methods to evaluate 
subject area knowledge of current teachers.

Education provided written comments on a draft of this report including 
information on the guidance for special education teachers that we 
incorporated as appropriate. Additionally, Education indicated that it 
plans to take steps to address our recommendation. Our evaluation of 
their comments is in the report and Education's comments are in 
appendix IV.

Background:

Recently, a body of research has shown that quality teachers are 
significant to improving student performance. For example, a 1996 study 
by Sanders and Rivers[Footnote 4] examined the effect of teacher 
quality on academic achievement and found that children assigned to 
effective teachers scored significantly higher in math than children 
assigned to ineffective teachers. Research has also shown that many 
teachers, especially those in high-poverty and rural districts, were 
not certified and lacked knowledge of the subjects they taught. For 
example, a report from The Education Trust found that in every subject 
area, students in high-poverty schools were more likely than other 
students to be taught by teachers without even a minor in the subjects 
they teach.[Footnote 5]

States are responsible for developing and administering their education 
systems and most have delegated authority for operating schools to 
local governments. States and local governments provide most of the 
money for public elementary and secondary education. In 2002, Education 
reported[Footnote 6] that 49 percent of the revenue for education was 
from state sources, 44 percent from local sources, and 7 percent from 
federal sources. Therefore, it is mostly state and local funds that are 
used to cover most of the major expenses, such as teacher salaries, 
school buildings, and transportation. Although the autonomy of 
districts varies, states are responsible for monitoring and assisting 
their districts that, in turn, monitor and assist their schools.

The federal government plays a limited but important role in education. 
The Department of Education's mission is to ensure equal access to 
education and promote educational excellence throughout the nation by, 
among other things, supporting state and local educational improvement 
efforts, gathering statistics and conducting research, and helping to 
make education a national priority. Education provides assistance to 
help states understand the provisions or requirements of applicable 
laws, as well as overseeing and monitoring how states implement them. 
With the passage of the No Child Left Behind Act, on January 8, 2002, 
the federal government intensified its focus on teacher quality by 
establishing a requirement in the act for teachers across the nation to 
be "highly qualified" in every core subject they teach by the end of 
the 2005-06 school year.[Footnote 7]

While the act contains specific criteria for highly qualified teachers 
by grade and experience levels, in general, the act requires that 
teachers: (1) have a bachelor's degree, (2) have state certification, 
and (3) demonstrate subject area knowledge for each core subject they 
teach. Table 1 lists the specific criteria by grade and experience 
levels as defined in the act.

Table 1: Federal Criteria for a Highly Qualified Teacher:

Grade level and experience: Any public elementary school or secondary 
school teacher; Federal criteria: Has obtained full state 
certification as a teacher (including alternative certification) or 
passed the state teacher licensing examination and holds a license to 
teach in the state; however, when teaching in a charter school,[A] the 
teacher may not be certified or licensed if the state does not require 
it. Further, the teacher has not had certification or licensure 
requirements waived on emergency, temporary, or provisional basis.

Grade level and experience: Elementary school teacher new to the 
profession; Federal criteria: Holds at least a bachelor's degree; and 
has passed a rigorous state test to demonstrate subject knowledge and 
teaching skills in reading, writing, math, and other areas of the basic 
elementary school curriculum (these tests may be included in state 
certification or licensing tests).

Grade level and experience: Middle or secondary school teacher new to 
the profession; Federal criteria: Holds at least a bachelor's degree 
and has passed a rigorous state academic subject test in each of the 
academic subjects in which the teacher teaches (this may be the state 
certification or licensure test) or for each academic subject taught, 
the teacher has successfully completed an academic major, a graduate 
degree, coursework equivalent to an undergraduate academic major, or 
advanced certification or credentialing.

Grade level and experience: Elementary, middle, or secondary teacher 
not new to the profession; Federal criteria: Has met the above 
standards for new elementary, middle, and secondary school teachers or 
demonstrates competence in all the academic subjects in which the 
teacher teaches based on a high objective, uniform state standard of 
evaluation that (1) is set by the state for both grade appropriate 
academic subject matter knowledge and teaching skills; (2) is aligned 
with challenging state academic content and student academic 
achievement standards and developed in consultation with core content 
specialists, teachers, principals, and school administrators; (3) 
provides objective, coherent information about the teacher's attainment 
of core content knowledge in the academic subjects a teacher teaches; 
(4) is applied uniformly to all teachers in the same academic subject 
and the same grade level throughout the state; (5) takes into 
consideration, but not be based primarily on, the time the teacher has 
been teaching in the academic subject; (6) is made available to the 
public upon request; and (7) may involve multiple, objective measures 
of teacher competency.

Source: NCLBA, Pub.L. No. 107-110, section 9101(2002).

[A] Charter schools are public schools that are exempt from a variety 
of local and state regulations.

[End of table]

For Title II, Part A of the act, Congress appropriated $2.85 billion to 
the Teacher and Principal Training and Recruiting Fund in fiscal year 
2002--about $740 million more than states received in fiscal year 2001 
under the previous two programs that it replaced--the Eisenhower 
Professional Development and Class Size Reduction programs. The purpose 
of the fund is to increase student academic achievement by providing 
support for states and districts to implement authorized activities 
cited in Title II to help them meet the requirement for highly 
qualified teachers. (See apps. II and III for state and district 
authorized activities.):

States had to complete an application in order to receive funds. All 
applications were due by June 2002, and states received the funds by 
August 2002. The funds were to be distributed according to the formula 
defined in the act. Specifically, states and districts received an 
amount equal to what they received for fiscal year 2001 under the two 
previous programs. The additional $740 million was distributed to 
states and districts based on the number of families with children ages 
5 to 17 who had incomes below the poverty threshold[Footnote 8] and the 
relative population of children ages 5 to 17. The act requires states 
to ensure that districts target funds to those schools that have the 
highest number of teachers who are not highly qualified, the largest 
class sizes, or have been identified as in need of improvement.

To help states understand and implement the new law, Education took a 
number of actions. The department established a Web site, developed an 
application package for the formula grant program, issued draft 
guidance, and held informational conferences for states and districts. 
Figure 1 summarizes Education's assistance to states.

Figure 1: Education's Assistance to States During Calendar Year 2002:

[See PDF for image]

[End of figure]

In June 2002, Education issued draft guidance entitled "Improving 
Teacher Quality State Grants" which has served as Education's principle 
form of assistance to states. In December of 2002, Education expanded 
and modified the draft guidance and issued final regulations on NCLBA 
that included some criteria related to the requirement for highly 
qualified teachers. Education does not plan to issue a final version of 
its draft guidance; instead, the draft includes the statement that it 
"should be viewed as a living document" that will be updated (1) as new 
questions arise, (2) if there is a change in the program statute that 
requires modification, or (3) when Education determines that more 
information would be helpful.

Many States Were Uncertain about Numbers of Highly Qualified Teachers:

In-depth discussions with officials in 8 states revealed that they 
could not determine the number of highly qualified teachers with 
accuracy because of one or more factors. All state officials said they 
did not know the criteria for some of their teachers because 
Education's draft guidance changed and was not complete. Officials also 
did not have all the information they needed to develop methods to 
evaluate subject area knowledge for their current teachers. 
Accordingly, officials in all of the states interviewed and nearly all 
surveyed said they needed complete and clear guidance before they could 
comply with the law. Most of the states we visited also did not have 
data systems that could track teacher qualifications by core subject 
taught, which they would have to do to ensure that teachers were 
teaching only those subjects for which they had demonstrated subject 
area knowledge. Finally, many state officials we visited were reluctant 
to say that their certified teachers might not be highly qualified.

States Did Not Have Complete or Consistent Criteria to Determine the 
Number of Highly Qualified Teachers:

During our review, Education changed its criteria for teachers who were 
in alternative certification programs and it reissued the draft 
guidance to qualify only teachers in certain programs.[Footnote 9] The 
revised draft guidance stated that only those teachers enrolled in 
alternative certification programs with specific elements, such as 
teacher mentors, would be considered highly qualified. As a result, 
state officials had to recount this group of teachers by determining 
which alternative certification programs met the standard and then 
which teachers participated in those programs. In one state we visited, 
there were about 9,000 teachers in alternative certification programs 
and all were considered highly qualified until the revised draft 
guidance was issued. As of May 2003, an official said she was still 
trying to determine the number of teachers who were highly qualified.

Also during our review, state officials were uncertain about the 
criteria for special education teachers. The draft guidance that was 
available during most of our visits did not address special education 
teachers. As a result, state officials could not know, for example, 
whether a special education teacher teaching math and reading would 
have to demonstrate subject area knowledge in both or neither of the 
subjects. For school year 1999-2000, special education teachers 
represented about 11 percent of the national teacher 
population,[Footnote 10] so that, on average, state officials were 
unable to determine whether at least a tenth of their teachers met the 
highly qualified criteria. In some districts, special education 
teachers represented a larger portion of the workforce. For example, in 
one high-poverty urban district that we visited, special education 
teachers were 21 percent of their teachers. Education issued final 
Title I regulations on December 2, 2002, with an appendix that 
discussed the highly qualified requirements for special education 
teachers, among other things. However, the requirements are not 
discussed in the federal regulations nor are they discussed in the 
Title II draft guidance that was issued December 19, 2002. In addition, 
as of March 2003 some officials still had questions about the 
requirements. Perhaps because the guidance was issued in an appendix, 
it was not given the prominence needed to ensure that all officials 
would be aware of the information.

Furthermore, neither Education's draft guidance nor its regulations 
provided more information than the law to help state officials develop 
methods other than tests to evaluate their current teachers' subject 
area knowledge. The law allows states to use a "high, objective uniform 
state standard of evaluation" instead of a test. Education's draft 
guidance repeated the language of the law, but provided no further 
interpretation. In addition, Education officials said they would review 
states' implementation of this provision when they conduct compliance 
reviews and then determine if the state evaluation is in compliance 
with the law. State officials said they needed more information, such 
as examples, to be confident of what Education would consider adequate 
for compliance with the law. State officials prefer evaluations instead 
of tests, according to an official at the Council of Chief State School 
Officers (CCSSO), because they expect evaluations to be less expensive, 
more flexible, and more acceptable to teachers and unions. Such 
evaluations might be done through classroom observations, examination 
of portfolios, and peer reviews. In March 2003, CCSSO held a conference 
attended by about 25 state officials and several Education officials to 
discuss the implementation of state evaluations. At that conference, 
state officials said Education's lack of specificity was particularly a 
problem for evaluating middle and high school teachers who had not 
demonstrated subject area knowledge. According to our survey data, 23 
of 37 state officials said they would have difficulty fulfilling the 
highly qualified requirement for middle school teachers and 14 
anticipated difficulty for high school teachers. According to district 
survey results, 20 percent anticipated difficulties in meeting the 
federal criteria for middle school teachers and 24 percent for high 
school teachers. Furthermore, as table 2 shows, a significantly higher 
percentage of high-poverty districts reported they would have greater 
difficulty fulfilling the requirement for teachers, especially at the 
middle and high school levels, than would low-poverty districts.

Table 2: Estimated Percentages of Districts That Will Have Difficulty 
Meeting the Requirement for Highly Qualified Teachers by Grade Level 
and Poverty:

Type of school: Elementary; All districts: 7; High-poverty districts: 
18; Low-poverty districts: 4.

Type of school: Middle/junior high; All districts: 20; High-poverty 
districts: 35; Low-poverty districts: 13.

Type of school: High; All districts: 24; High-poverty districts: 46[A]; 
Low-poverty districts: 15.

Source: GAO survey.

[A] The percentage estimate for high schools in high-poverty districts 
has a 95 percent confidence interval of plus or minus 11 percentage 
points.

[End of table]

State officials from the 8 states we visited said they could not 
determine the number of highly qualified teachers because the draft 
guidance was changing, not clear, or incomplete. Most, 32 of 37, state 
officials responding to our survey said they needed clear and timely 
guidance to help them meet the law.

State Data Systems Did Not Track Federal Criteria:

Officials from 7 of the 8 states we visited told us they did not have 
data systems that would allow them to track teachers' qualifications 
according to the federal criteria by every subject taught. Officials in 
one state projected that it would take at least 2 years before the 
state could develop and implement a system to track teachers by the 
federal criteria. State officials we visited said since their state 
certifications had not required some teachers to demonstrate subject 
area knowledge as required in the federal criteria, their information 
systems did not track such information. In written comments to our 
survey, for example, one official said, "Questions [related to counting 
teachers] are impossible to answer at this point because we not have 
finished the identification of those who need to be tested or 
evaluated." Another respondent wrote that the data system "was designed 
years ago for state certification purposes…[and] has not yet been 
updated to include all NCLBA criteria for teachers." Other state 
officials also told us during our visits and through survey comments 
that their state certifications did not always require teachers to 
demonstrate subject area knowledge, so they did not have information on 
many teachers' qualifications for this criteria. Another state official 
wrote, "[We] do not have data on teachers who were grand fathered in 
before 1991 or from out of state… who do not have subject matter 
competency." Given the cost and time they thought it would take, some 
state officials expressed reservations about changing their data 
systems before Education provided complete guidance.

Some State Officials Reluctant to Report Teachers Not Highly Qualified:

Officials in 6 of the 8 states visited were reluctant to report their 
certified teachers might not be highly qualified. Three of these 
officials equated their state certification with the federal criteria 
for a highly qualified teacher even though they differed. They 
expressed a reluctance to say that their state certification 
requirements did not produce a highly qualified teacher even though the 
requirements did not match all the federal criteria, such as 
demonstration of subject area knowledge. Additionally, state officials 
expressed concern about the morale of teachers who are state certified 
but who would not meet the federal criteria. They were also concerned 
about how teachers and unions would react to testing already certified 
teachers. For example, in 5 states we visited officials told us that 
the unions in these states objected to the testing of certified 
teachers.

State and District Officials Reported Many Conditions as Hindrances to 
Meeting the Law:

Many state officials responding to our survey reported that teacher 
salary issues and teacher shortages were hindrances. State officials 
also identified other conditions such as few programs to support new 
teachers, lack of principal leadership, teacher training, and union 
agreements. District officials also cited teacher salary and teacher 
development issues as conditions that hindered them. Our district 
survey also shows that significantly more high-poverty districts 
reported some conditions as hindrances than low-poverty districts, and 
rural districts officials we visited cited hindrances specific to their 
small size and isolated locations. In our state survey, officials 
indicated that they needed more information from Education on 
professional development programs, best practices, and developing 
incentives for teachers to teach in high-poverty schools.

State Officials Cited Several Problems as Hindrances:

Many state officials responding to our survey reported that pay issues 
hindered their ability to meet the requirement to have all highly 
qualified teachers. These issues included low salaries, lack of 
incentive pay programs, and a lack of career ladders for teachers. For 
example, 32 of 37 state respondents said low teachers' salaries 
compared to other occupations was a hindrance. Officials we visited 
said that because of the low salaries it has been more difficult to 
recruit and retain some highly qualified teachers, especially math and 
science teachers. Several occupations are open to people with a 
bachelor's degree in math and science, such as computer scientists and 
geologists. During the late 1990s, there was an increase in demand for 
workers with math and science backgrounds, especially in information 
technology occupations. Between 1994 and 2001, the number of workers 
employed in the mathematical and computer sciences increased by about 
77 percent while the number of teachers increased by about 28 percent 
and total employment increased by about 14 percent. Furthermore, the 
math and science occupations have generally paid higher salaries than 
teaching positions. The U.S. Department of Labor's Bureau of Labor 
Statistics data indicate that in 2001 average weekly earnings was 
$1,074 for mathematical and computer scientist positions and $730 for 
teachers. Some research shows that teacher salary is only one of many 
factors that influence teacher recruitment and retention. For example, 
the American Association of School Administrators explained the 
relationship between pay and working conditions in a report on higher 
pay in hard-to-staff schools.[Footnote 11] The report stated "How money 
matters becomes much clearer if salary is viewed as just one of many 
factors that employees weigh when assessing the relative attractiveness 
of any particular job, such as opportunities for advancement, 
difficulty of the job, physical working conditions, length of commute, 
flexibility of working hours, and demands on personal time. Adjusting 
the salaries upward can compensate for less appealing aspects of a job; 
conversely, improving the relative attractiveness of jobs can 
compensate for lower salaries.":

Many state survey respondents also cited teacher shortages as a 
hindrance. Specifically, 23 of the 37 state officials reported teacher 
shortages in high-need subject areas--such as, math, science, and 
special education.[Footnote 12] Additionally, 12 state officials 
reported a shortage in the number of new highly qualified teachers in 
subject areas that are not high need, and 12 reported that having few 
alternative certification programs hindered their efforts. Education 
experts have debated the causes and effects of teacher shortages. Some 
experts argue that the problem is not in the number of teachers in the 
pool of applicants but in their distribution across the country. Others 
argue that poor retention is the real cause of teacher shortages. As 
for alternative certification programs, they were established to help 
overcome teacher shortages by offering other avenues for people to 
enter the teaching profession. However, in 1 state we visited officials 
said the success of these programs had been mixed because the content 
and length of the programs varied and some alternative certification 
teachers were better prepared than others.

Although states have been facing teacher shortages in some subject 
areas for years, the new requirement for highly qualified teachers 
could make it even more difficult to fulfill the demand for teachers. 
The new law requires states to ensure that teachers only teach subjects 
for which they have taken a rigorous state test or evaluation, 
completed an academic major or graduate degree, finished course work 
equivalent to such degrees, or obtained advanced certification or 
credentialing in the subjects. Previously, states allowed teachers to 
teach subjects without such course work or credentials. From its 
Schools and Staffing Survey,[Footnote 13] the National Center for 
Education Statistics, within the Department of Education, reported that 
in 1999-2000, 14 to 22 percent of students in middle grades and 5 to 10 
percent of high school students taking English, math, and science were 
in classes taught by teachers without a major, minor, or certification 
in the subjects they taught. Also, the report indicated that in the 
high school grades, 17 percent of students enrolled in physics and 36 
percent enrolled in geology/earth/space science classes were taught by 
out-of-field teachers.

Some states also cited several other conditions that might hinder their 
ability to meet the requirement for highly qualified teachers. For 
example, 13 of the 37 state respondents reported few programs to 
support new teachers,[Footnote 14] and 9 reported large classes as 
hindrances. State respondents also cited work environment factors such 
as teacher performance assessments, a lack of principal leadership, and 
lack of school supplies and equipment as hindrances. See table 3 for 
more information on hindrances reported by state officials.

Additionally, 7 state officials who responded to our survey cited union 
agreements as a hindrance. Officials in 5 states that we visited said 
that the teachers' unions objected to testing currently certified 
teachers for subject area knowledge, and officials in 2 of these states 
also said that current teachers might leave rather than take a test. An 
official representing the American Federation of Teachers (AFT), an 
organization that represents teachers, school support staff, higher 
education faculty and staff, among others, said that AFT supports the 
federal definition for highly qualified teachers and incentive pay for 
teachers in high-need subject areas and that certified teachers should 
have a choice between taking a test and having a state evaluation to 
determine subject area knowledge. The National Education Association, 
an organization with members who work at every level of education, 
issued an analysis of the NCLBA that identified several changes it 
believes should be made in the law, including clarifying the 
requirement for highly qualified teachers. The union officials we spoke 
with from 2 states we visited said they also support the requirement 
for highly qualified teachers but expressed concerns about how their 
states would implement the legislation. One state union official said 
the current state process for certification requires multiple tests--
more than is required in the legislation--and the union is concerned 
that the state will collapse the testing and streamline the teacher 
preparation process as part of its changes to meet the requirement. The 
union official from the other state said that his union was concerned 
because the state's approach for implementing the requirement for 
highly qualified teachers has become a moving target and this causes 
frustration for teachers.

Table 3: Number of States Reporting on Conditions That Hinder Their 
Ability to Meet the Requirement for Highly Qualified Teachers (Ranked 
from Highest to Lowest):

Number of states reporting this condition to be a hindrance[A] (n=37): 
32; Condition: Teachers' salaries low compared to other occupations.

Number of states reporting this condition to be a hindrance[A] (n=37): 
23; Condition: Shortage in the number of teachers who meet the Title II 
requirement for highly qualified teachers in subject areas where there 
is high need.

Number of states reporting this condition to be a hindrance[A] (n=37): 
21; Condition: Teachers' salaries low compared to teachers elsewhere.

Number of states reporting this condition to be a hindrance[A] (n=37): 
18; Condition: Lack of incentive pay programs.

Number of states reporting this condition to be a hindrance[A] (n=37): 
17; Condition: Lack of a career ladder for teachers.

Number of states reporting this condition to be a hindrance[A] (n=37): 
14; Condition: Professional development programs not of sufficient 
duration to have an effect on teacher quality.

Number of states reporting this condition to be a hindrance[A] (n=37): 
13; Condition: Few programs to support new teachers.

Number of states reporting this condition to be a hindrance[A] (n=37): 
12; Condition: Few alternative certification programs.

Number of states reporting this condition to be a hindrance[A] (n=37): 
12; Condition: Shortage in the number of new teachers who meet the 
Title II requirement for highly qualified teachers in subject areas 
that are not high need.

Number of states reporting this condition to be a hindrance[A] (n=37): 
12; Condition: School lacks supplies and equipment.

Number of states reporting this condition to be a hindrance[A] (n=37): 
11; Condition: Lack of leadership on the part of principals.

Number of states reporting this condition to be a hindrance[A] (n=37): 
9; Condition: College of Arts and Science Departments do not work with 
college Education Departments to develop teacher preparation programs.

Number of states reporting this condition to be a hindrance[A] (n=37): 
9; Condition: Large class sizes resulting in teacher retention 
problems.

Number of states reporting this condition to be a hindrance[A] (n=37): 
9; Condition: Many currently employed teachers do not meet the Title II 
requirement for highly qualified teachers in areas that are not high 
need.

Number of states reporting this condition to be a hindrance[A] (n=37): 
7; Condition: Teacher assessments not based on the Title II requirement 
for highly qualified teachers.

Number of states reporting this condition to be a hindrance[A] (n=37): 
7; Condition: Weak training for teachers in the use of technology.

Number of states reporting this condition to be a hindrance[A] (n=37): 
7; Condition: Union agreements inhibit implementing activities 
encouraged by Title II to develop highly qualified teachers.

Number of states reporting this condition to be a hindrance[A] (n=37): 
7; Condition: Professional development programs not based on recent 
scientific research on teaching methods or subject matter.

Number of states reporting this condition to be a hindrance[A] (n=37): 
4; Condition: State certification requirements not meeting the Title II 
requirement for highly qualified teachers.

Number of states reporting this condition to be a hindrance[A] (n=37): 
3; Condition: Alternative certification programs not providing teachers 
with adequate teaching skills.

Number of states reporting this condition to be a hindrance[A] (n=37): 
3; Condition: Teacher preparation programs not aligned with state 
subject content standards.

Number of states reporting this condition to be a hindrance[A] (n=37): 
3; Condition: State and local laws and regulations inhibit implementing 
activities encouraged by Title II to develop highly qualified 
teachers.

Number of states reporting this condition to be a hindrance[A] (n=37): 
2; Condition: Teacher preparation programs not providing teachers with 
adequate subject matter expertise.

Source: GAO survey.

[A] These numbers include states that reported these conditions as a 
moderate, great, or very great hindrance.

[End of table]

School Districts Reported Hindrances Similar to Those Reported by 
States and More High-Poverty Districts Reported Certain Hindrances:

School district estimates from our survey show that, similar to state 
respondents, salary issues hinder districts' efforts to meet the 
requirement for highly qualified teachers. Almost 60 percent of 
district officials cited low teacher salaries compared to other 
occupations as a hindrance, with a significantly higher number of high-
poverty than low-poverty district officials reporting this as a 
hindrance. During our site visits to 4 rural districts, officials said 
that their salaries could not compete with salaries offered in other 
occupations and locations. One official said that pay in the rural 
districts was low compared to teacher salaries in surrounding states. 
Both state and district officials also said that these salary 
conditions affect the recruitment and retention of highly qualified 
teachers.

Our survey estimates also show that conditions related to teacher 
development were hindering districts' ability to meet the highly 
qualified teacher requirement. The conditions reported by districts 
included (1) weak training for teachers in the use of technology (28 
percent), (2) few alternative certification programs (18 percent), and 
(3) professional development programs that are not of sufficient 
duration to improve teacher quality (23 percent). Weak training 
programs can leave teachers unprepared to deal with all the challenges 
of teaching and lead to job dissatisfaction. Table 4 provides estimates 
of the percentages of districts reporting conditions that hinder their 
ability to meet the requirement for highly qualified teachers.

Table 4: Estimated Percentages of Districts Reporting on Conditions 
That Hinder Their Ability to Meet the Requirement for Highly Qualified 
Teachers (Ranked from Highest to Lowest):

Percent of all districts reporting this condition to be a hindrance[A]: 
57; Condition: Teachers' salaries low compared to other occupations.

Percent of all districts reporting this condition to be a hindrance[A]: 
37; Condition: Teachers' salaries low compared to teachers elsewhere.

Percent of all districts reporting this condition to be a hindrance[A]: 
28; Condition: Training for teachers in the use of technology is weak.

Percent of all districts reporting this condition to be a hindrance[A]: 
25; Condition: Lack of incentive pay programs.

Percent of all districts reporting this condition to be a hindrance[A]: 
23; Condition: Professional development programs not of sufficient 
duration to have an effect on teacher quality.

Percent of all districts reporting this condition to be a hindrance[A]: 
19; Condition: Shortage in the number of teachers who meet the Title II 
requirement for highly qualified teachers in subject areas where there 
is high need.

Percent of all districts reporting this condition to be a hindrance[A]: 
18; Condition: Teacher preparation programs not providing teachers with 
adequate subject matter expertise.

Percent of all districts reporting this condition to be a hindrance[A]: 
18; Condition: Few alternative certification programs.

Percent of all districts reporting this condition to be a hindrance[A]: 
17; Condition: College of Arts and Science Departments not working with 
college Education Departments to develop teacher preparation programs.

Percent of all districts reporting this condition to be a hindrance[A]: 
16; Condition: Alternative certification programs not providing 
teachers with adequate teaching skills.

Percent of all districts reporting this condition to be a hindrance[A]: 
16; Condition: Few programs to support new teachers.

Percent of all districts reporting this condition to be a hindrance[A]: 
16; Condition: Lack of a career ladder for teachers.

Percent of all districts reporting this condition to be a hindrance[A]: 
16; Condition: Shortage in the number of new teachers who meet the 
Title II requirement for highly qualified teachers in low achieving 
schools.

Percent of all districts reporting this condition to be a hindrance[A]: 
15; Condition: Teacher preparation programs not aligned with state 
subject content standards.

Percent of all districts reporting this condition to be a hindrance[A]: 
14; Condition: School lacks supplies and equipment.

Percent of all districts reporting this condition to be a hindrance[A]: 
12; Condition: Teacher assessments not based on the Title II 
requirement for highly qualified teachers.

Percent of all districts reporting this condition to be a hindrance[A]: 
10; Condition: Union agreements that inhibit implementing activities 
encouraged by Title II to develop highly qualified teachers.

Percent of all districts reporting this condition to be a hindrance[A]: 
7; Condition: Lack of leadership on the part of principals.

Percent of all districts reporting this condition to be a hindrance[A]: 
7; Condition: Large class sizes resulting in teacher retention 
problems.

Percent of all districts reporting this condition to be a hindrance[A]: 
7; Condition: Professional development programs not based on recent 
scientific research on teaching methods or subject matter.

Percent of all districts reporting this condition to be a hindrance[A]: 
7; Condition: State certification requirements not meeting the Title II 
requirement for highly qualified teachers.

Percent of all districts reporting this condition to be a hindrance[A]: 
6; Condition: Many currently employed teachers not meeting the Title II 
requirement for highly qualified teachers in areas that are not high 
need.

Percent of all districts reporting this condition to be a hindrance[A]: 
4; Condition: State and local laws and regulations inhibit implementing 
activities encouraged by Title II to develop highly qualified 
teachers.

Source: GAO survey.

[A] These percentages include districts that reported these conditions 
as a moderate, great, or very great hindrance.

[End of table]

While the ranking of most of the hindrances reported by districts and 
states were similar, three conditions were reported among the top third 
of hindrances for districts but among the bottom third for states. 
Specifically, these conditions were (1) alternative certification 
programs do not provide teachers with adequate teaching skills, (2) 
teacher preparation programs do not provide teachers with adequate 
subject matter expertise, and (3) training for teachers in the use of 
technology is weak. The first two of these conditions relate to 
programs that are usually responsibilities of the state departments of 
education. States or districts can address the third condition, 
technology training. These conditions indicate areas in which states 
and districts can work together to improve programs and help meet the 
requirement for highly qualified teachers.

A significantly higher number of high-poverty districts than low-
poverty districts identified some conditions as hindrances. As table 5 
shows, in addition to teacher shortages and pay issues, a larger 
percentage of high-poverty districts cited few programs to support new 
teachers and few alternative certification programs, among others, as 
hindrances to meeting the requirement.

Table 5: Estimated Percentages of High-and Low-Poverty Districts with 
Significant Differences in the Hindrances to Meeting the Requirement:

Condition: Teachers' salaries are low compared to other occupations; 
Percent of high-poverty districts: 75; Percent of low-poverty 
districts: 50.

Condition: Teachers' salaries are low compared to teachers elsewhere; 
Percent of high-poverty districts: 57; Percent of low-poverty 
districts: 33.

Condition: Lack of incentive pay programs; Percent of high-poverty 
districts: 32; Percent of low-poverty districts: 17.

Condition: Few programs to support new teachers; Percent of high-
poverty districts: 30; Percent of low-poverty districts: 6.

Condition: Shortage in the number of teachers who meet the Title II 
requirement for highly qualified teachers in subject areas where there 
is a high need; Percent of high-poverty districts: 29; Percent of low-
poverty districts: 13.

Condition: Shortage in the number of new teachers who meet the Title II 
requirement in low achieving schools; Percent of high-poverty 
districts: 26; Percent of low-poverty districts: 10.

Condition: Lack of career ladder for teachers; Percent of high-poverty 
districts: 25; Percent of low-poverty districts: 8.

Condition: Few alternative certification programs; Percent of high-
poverty districts: 24; Percent of low-poverty districts: 11.

Condition: Teacher preparation programs do not provide adequate subject 
matter expertise; Percent of high-poverty districts: 24; Percent of 
low-poverty districts: 13.

Condition: Many currently employed teachers do no meet the Title II 
requirement in areas that are not high need; Percent of high-poverty 
districts: 13; Percent of low-poverty districts: 4.

Condition: Large class sizes resulting in teacher retention problems; 
Percent of high-poverty districts: 12; Percent of low-poverty 
districts: 4.

Condition: Lack of leadership on the part of principals; Percent of 
high-poverty districts: 12; Percent of low-poverty districts: 3.

Source: GAO survey.

Note: Each difference between high-and low-poverty districts in this 
table is significant at the 95 percent confidence interval.

[End of table]

During our site visits, officials from high-poverty districts told us 
they had great difficulty retaining teachers. For example, officials in 
one district said that although the district provided training for new 
teachers in the skills they needed, these teachers became more 
marketable after they completed the training and often left for higher 
paying teaching positions. According to these officials, the schools in 
this district did not always benefit from the district's training 
programs. High-poverty district officials also said they could not 
compete with surrounding, wealthier districts in teacher pay. Officials 
in these districts and at the American Association of School 
Administrators also said that some unions do not support the use of 
incentive pay for high-poverty schools because they believe that salary 
scales should be equal for all schools within a district.

Rural district officials we visited and also those who provided survey 
comments said they faced unusual hindrances because some of them were 
very small, isolated, or had only one or two teachers in total at some 
schools. During our site visits, some officials from rural districts 
also said that they were facing teacher shortages because not enough 
teachers were willing to teach in rural districts. For example, one 
official in a large, rural state said that the state had only one 
university, which makes it difficult for teachers to obtain further 
course work to meet the federal criteria for subject area knowledge. 
Since many teachers in this state's rural districts had to teach more 
than one core subject, with limited access to subject area training, 
they may not meet the highly qualified criteria for all subjects they 
teach. One survey respondent also wrote, "Rural schools have to assign 
teachers to several subject areas at [the] secondary level. We do not 
have large numbers of students, and teachers have to wear more than one 
hat. Rural schools are also a long way from colleges and to require 
licensure in every subject they teach is ludicrous." In a 2001 report 
to Congress, Education estimated that 84 percent of 4-year institutions 
would offer distance education courses[Footnote 15] in 2002. Such 
courses may help address this hindrance.

States Say They Need More Information from Education and Education 
Plans to Work with States on Some Issues:

As districts work to address the conditions that affect their ability 
to meet the new federal requirement, they look to their state officials 
for guidance and technical assistance. In turn, states look to 
Education for help. Many of the hindrances that state and district 
officials reported related to conditions that they could address such 
as teachers' salaries, the number of alternative certification 
programs, and certification requirements. However, states indicated 
they needed some additional information and assistance from Education. 
At least half of the 37 state respondents reported needing (1) 
information or other assistance to meet the requirement that 
professional development programs be based on recent scientific 
research and be of sufficient duration to have an effect on teacher 
quality, (2) information on best practices in the area of teacher 
quality, and (3) assistance in developing incentives for teachers to 
teach in high-poverty schools. Education's 2002-07 strategic plan 
identifies several steps it will take to work with states. 
Specifically, the strategies listed under the plan's goal for improving 
teacher and principal quality include supporting professional 
development in research-based instruction and encouraging innovative 
teacher compensation and accountability systems. Additionally, in 
December 2002, Education reorganized and established a new office to 
administer the Title II program.

To Help Teachers Meet the Requirement States Planned to Spend Most 
Title II Funds on Professional Development Activities, and Districts 
Will Spend Most on Recruitment and Retention Activities:

To help meet the requirement for highly qualified teachers, state 
officials planned to spend most of their Title II funds on professional 
development activities, and district officials planned to spend a 
majority of their Title II funds on recruitment and retention 
activities. State and district officials planned to spend much larger 
amounts of other federal,[Footnote 16] state, and local funds than 
Title II funds on the activities authorized in the act. Generally, 
state and district officials told us they were continuing activities 
from previous years. The survey data also indicated high-poverty 
districts relied more on Title II funds for recruitment and retention 
activities than low-poverty districts. In addition, while the act 
requires districts to target their Title II funds to schools that meet 
certain criteria, until district officials know the number of highly 
qualified teachers and where they are located, they cannot fully comply 
with this requirement.

States Planned to Spend the Majority of Title II Funds on Professional 
Development:

Generally, state educational agencies could use up to 2.5 percent of 
the state's Title II funds for authorized state activities.[Footnote 
17] Twenty-four state officials responding to our survey planned to 
spend about 65 percent of their Title II funds on professional 
development activities to develop and support highly qualified teachers 
and principals. For example, professional development activities could 
help teachers enhance their subject area knowledge and complete state 
licensing requirements to meet the criteria for highly qualified 
teachers. During our site visits, state officials described their 
professional development activities as seminars, conferences, and 
various instructional initiatives. For example, in one state we 
visited, officials planned to hold a workshop to provide middle and 
high school math teachers with technology training so that they could 
incorporate interactive Web sites in their instruction. Generally, 
state officials said they planned to use Title II funds to continue 
activities that were begun in previous years.

While professional development activities were to receive the largest 
share of funds, survey results show state officials planned to also 
spend Title II funds on other activities cited in the act. Officials in 
28 states planned to spend about 18 percent on technical assistance 
activities, such as providing information about the requirement for 
highly qualified teachers to districts via the state Web site. 
Certification activities received the smallest percentage of Title II 
funds-2 percent. These activities include efforts to promote 
certification reciprocity with other states and efforts to establish, 
expand, or improve alternative routes for certification. (See fig. 2.):

Figure 2: Planned Spending of Title II Funds by Reporting States:

[See PDF for image]

[End of figure]

Title II Funds Are a Small Part of Total Funds:

State officials reported they planned to spend much larger amounts of 
other federal and state funds than Title II funds on nearly all of the 
authorized Title II activities. For example, states reported that 85 
percent of the total funds they planned to spend on professional 
development activities would come from other federal and state funds. 
The one exception was technical assistance activities, where Title II 
funds accounted for 77 percent of the total. (See fig. 3.) Providing 
technical assistance to districts is an important role for states. In 
our visits to districts, several officials said they needed more 
information and technical assistance from their state to understand and 
implement the law.

Figure 3: Sources of Funds for Planned Spending by States on Title II 
Activities:

[See PDF for image]

[End of figure]

Districts Planned to Spend a Majority of Their Title II Funds on 
Recruitment and Retention Activities:

Districts received about 95 percent of their state's Title II funds for 
authorized activities.[Footnote 18] Based on our survey, district 
officials planned to spend an estimated 66 percent of their Title II 
funds on recruitment and retention activities and 34 percent on 
activities related to professional development. Class size reduction 
activities were the largest funded recruitment and retention activity 
and accounted for 56 percent of total Title II funds. In a majority of 
our site visits we learned that district officials used these funds to 
hire additional highly qualified teachers to continue activities 
developed under the previous Class Size Reduction Program. Class size 
reduction activities may help improve teacher retention because, 
according to an Education report,[Footnote 19] teachers in small 
classes spend less time on classroom management and more time providing 
instruction, thus raising the teacher's level of job satisfaction. 
While class size reduction activities can be seen as a retention tool, 
they may also increase the number of highly qualified teachers that 
need to be hired. This may be a problem for some districts and states. 
In fact, officials in one large state we visited said class size 
reduction activities presented a challenge by increasing the number of 
classes not being taught by a highly qualified teacher.

Additionally, district officials in our site visits said that they 
implemented or planned to implement a broad range of professional 
development activities. For example, one district had a teacher-coach 
program for its math and science teachers. This program used senior 
teachers as full-time coaches to assist less experienced teachers with 
instructional strategies and curriculum preparation. Other programs 
focused on math and reading, varied instructional strategies for 
different types of students, and use of technology. District officials 
in our site visits said most activities were in place prior to the act.

While all districts spent more on recruitment and retention activities 
than professional development, there were differences between high-and 
low-poverty districts. From our survey, we estimate that high-poverty 
districts planned to spend a significantly larger percentage of Title 
II funds on recruitment and retention and a smaller percentage on 
professional development activities than low-poverty districts. (See 
table 6.):

Table 6: Estimated Percent of Spending Title II Funds by Activities for 
All Districts, High-Poverty Districts, and Low-Poverty Districts:

Activity: Professional development activities; All districts: 34; All 
high-poverty districts: 23; All low-poverty districts: 41.

Activity: Recruitment and retention/class size reduction; All 
districts: 66; All high-poverty districts: 77; All low-poverty 
districts: 59.

Source: GAO survey.

Note: Each difference between high-and low-poverty districts in this 
table is significant at the 95 percent confidence interval.

[End of table]

Districts Planned to Spend Larger Amounts of Other Funds and Title II 
Funds Are a Larger Percentage of Total for High-Poverty Districts:

From our survey, we estimated all districts planned to spend much 
larger percentages of other federal, state, and local funds than Title 
II funds on authorized activities but in high-poverty districts the 
share of the funds was lower. Overall, 80 percent of the total funds 
districts planned to spend on professional development activities came 
from other federal, state, and local funds. Title II funds represented 
a larger percentage of total funds spent on authorized activities for 
high-poverty districts than low-poverty districts. For example, in 
high-poverty districts Title II funds were 48 percent of the funds they 
planned to spend for recruitment and retention activities compared to 
15 percent in low-poverty districts. There may be several reasons for 
these differences. For example, Title II allocated more funds to those 
districts with more high-poverty families, and low-poverty districts 
may have had more local funds to contribute to the total. Figure 4 
shows the Title II percentage of total funds for professional 
development activities and recruitment and retention activities, for 
all, high-poverty, and low-poverty districts. A majority of district 
officials said they planned to fund activities that were begun in 
previous years.

Figure 4: Estimated Spending of Title II Funds as a Percentage of Total 
Funds by Activities for All Districts, High-Poverty Districts, and Low-
Poverty Districts:

[See PDF for image]

[End of figure]

Approximately One-Third of All Districts Were Targeting Funds:

We estimated about one-third of all districts (34 percent) were 
targeting their Title II funds as required by the act. The act requires 
districts to target funds to those schools (1) with the highest number 
of teachers who are not highly qualified, (2) with the largest class 
sizes, or (3) in need of improvement. There was little difference 
between the percentages of high-and low-poverty districts that targeted 
their funds or between urban and rural districts. For example, 29 
percent of high-poverty districts and 30 percent of low-poverty 
districts reported targeting some of their Title II funds. 
Additionally, some district officials we visited said they did not 
target funds according to the criteria listed in the act but that they 
targeted funds in other ways such as to support math and science 
programs for teachers and for administrative leadership programs. It 
may be too early for district officials to fully implement this 
targeting requirement. Until they know the true number of teachers who 
are highly qualified, they cannot target the schools with the highest 
numbers of teachers who are not highly qualified.

Conclusions:

Education officials have had to interpret and help states implement 
many new requirements established by the NCLBA, including the highly 
qualified teacher requirement. During this first year of 
implementation, state officials were still determining how they could 
assess whether their teachers met all the criteria and identifying 
steps they needed to take to meet the new requirement. Generally, state 
and district officials continued to be challenged by many longstanding 
hindrances and they continued to fund activities from previous years.

Education issued regulations and draft guidance to help states begin to 
implement the requirement for highly qualified teachers and has plans 
to help states with some of their challenges. However, state officials 
need more assistance from Education, especially about methods to 
evaluate current teachers' subject area knowledge. Without this 
information state officials are unsure how to assess whether their 
current teachers meet the highly qualified requirement. This would also 
help them accurately determine the number of teachers who are highly 
qualified and take appropriate steps, such as deciding on which 
activities to spend Title II funds and targeting Title II funds to 
schools with the highest numbers of teachers who are not highly 
qualified. It is important that states have the information they need 
as soon as possible in order to take all necessary actions to ensure 
that all teachers are highly qualified by the 2005-06 deadline.

Recommendation for Executive Action:

In order to assist states' efforts to determine the number of highly 
qualified teachers they have and the actions they need to take to meet 
the requirement for highly qualified teachers by the end of the 2005-06 
school year, we recommend that the Secretary of Education provide more 
information to states. Specifically, information is needed about 
methods to evaluate subject area knowledge of current teachers.

Agency Comments and Our Evaluation:

We received written comments on a draft of this report from Education. 
These comments are reprinted in appendix IV. In response to our 
recommendation related to requirements for special education teachers, 
Education stated that the appendix of the Title I Final Regulations 
clarifies how the highly qualified requirements apply to special 
education teachers. Consequently, we modified the report to reflect 
this information and we withdrew this recommendation.

Education indicated it plans to take steps to address our 
recommendation on the need for information about methods to evaluate 
subject area knowledge of current teachers. Education stated that it 
will continue to work with state officials and will actively share 
promising strategies and models for "high objective uniform State 
standard of evaluation" with states to help them develop ways for 
teachers to demonstrate subject area competency.

Also, Education commented that it views a "one-size fits all" approach 
to addressing many of the issues raised in the report as undesirable 
because states and districts will have to meet the requirement highly 
qualified teachers in a manner that is compatible with their teacher 
certification, assessment and data collection processes. Education 
stated that it will provide assistance wherever possible to help states 
meet the requirement. We generally agree that this is an appropriate 
approach.

Additionally, Education provided technical comments and we made changes 
as appropriate.

We are sending copies of this report to appropriate congressional 
committees, the Secretary of Education, and other interested parties. 
Copies will be made available to other interested parties upon request. 
In addition, the report will be available at no charge on GAO's Web 
site at http://www.gao.gov. If you have any questions about this 
report, please call me at (202) 512-7215. Key contributors are listed 
in appendix V.

Marnie S. Shaul, 
Director 
Education, Workforce, and Income Security Issues:

Signed by Marnie S. Shaul: 

[End of section]

Appendix I: Scope and Methodology:

In conducting our work, we administered a Web survey to the 50 states 
and the District of Columbia, and a separate Web survey to a nationally 
representative sample of 830 school districts, that included strata for 
high-poverty, low-poverty, rural, and urban districts. The response 
rate for the state survey was 71 percent and for the district survey 62 
percent. The surveys were conducted between December 4, 2002, and April 
4, 2003. We analyzed the survey data and identified significant 
results. See figure 5 for a geographic display of responding and 
nonresponding states.

Figure 5: State Survey Respondents:

[See PDF for image]

[End of figure]

The study population for the district survey consisted of public school 
districts contained in the Department of Education's Core of Common 
Data (CCD) Local Education Agency (LEA) file for the 2000-2001 school 
year. From this, we identified a population of 14,503 school districts 
in the 50 states and the District of Columbia.

Sample Design. The sample design for this survey was a stratified 
sample of 830 LEAs in the study population. This sample included the 
100 largest districts and a stratified sample of the remaining 
districts with strata defined by community type[Footnote 20] (city, 
urban, and rural) and by the district's poverty level.[Footnote 21] 
Table 7 summarizes the population, sample sizes, and response rates by 
stratum.

Table 7: Population and Sample by Stratum:

Stratum number: 1; Description: Largest 100 districts; Districts in 
population: 100; Districts in sample: 100; Districts responding: 64; 
Response rate: 64%.

Stratum number: 2; Description: City, low poverty; Districts in 
population: 648; Districts in sample: 120; Districts responding: 76; 
Response rate: 63%.

Stratum number: 3; Description: City, high poverty; Districts in 
population: 210; Districts in sample: 94; Districts responding: 35; 
Response rate: 37%.

Stratum number: 4; Description: Urban, low poverty; Districts in 
population: 5,264; Districts in sample: 135; Districts responding: 87; 
Response rate: 64%.

Stratum number: 5; Description: Urban, high poverty; Districts in 
population: 648; Districts in sample: 120; Districts responding: 79; 
Response rate: 66%.

Stratum number: 6; Description: Rural, low poverty; Districts in 
population: 6,515; Districts in sample: 135; Districts responding: 87; 
Response rate: 64%.

Stratum number: 7; Description: Rural, high poverty; Districts in 
population: 1,118; Districts in sample: 126; Districts responding: 83; 
Response rate: 66%.

Total; Districts in 
population: Districts in population: 14,503; Districts in 
sample: Districts in sample: 830; Districts responding: 
Districts responding: 511; Response rate: Response rate: 62%.

Source: GAO analysis of Education's 2000-1 CCD data:

[End of table]

Estimates. All estimates produced from the district sample in this 
report are for a target population defined as all public school 
districts in the 50 states and the District of Columbia for the 2002-03 
school year. Estimates to this target population were formed by 
weighting the survey data to account for both the sample design and the 
response rates for each stratum. For our estimates of high-and low-
poverty districts, we defined high-poverty districts as those with 
participation rates in the free and reduced meals program of 70 percent 
or above. Low-poverty districts were defined as those with free and 
reduced meals program rates at 30 percent and below. One of the 
advantages of this approach was that it allowed for a sufficient number 
of cases in each category to conduct statistical analyses.

Sampling Error. Because we surveyed a sample of school districts, our 
results are estimates of a population of school districts and thus are 
subject to sampling errors that are associated with samples of this 
size and type. Our confidence in the precision of the results from this 
sample is expressed in 95 percent confidence intervals. The 95 percent 
confidence intervals are expected to include the actual results for 95 
percent of the samples of this type. We calculated confidence intervals 
for our study results using methods that are appropriate for a 
stratified, probability sample. For the percentages presented in this 
report, we are 95 percent confident that the results we would have 
obtained if we had studied the entire study population are within plus 
or minus 10 percentage points of our results, unless otherwise noted. 
For example, we estimate that 34 percent of the districts target at 
least some funds to specific types of schools. The 95 percent 
confidence interval for this estimate would be no wider than plus or 
minus 10 percent, or from 24 percent to 44 percent.

Nonsampling Error. In addition to these sampling errors, the practical 
difficulties in conducting surveys of this type may introduce other 
types of errors, commonly referred to as nonsampling errors. For 
example, questions may be misinterpreted, the respondents' answers may 
differ from those of districts that did not respond, or errors could be 
made in keying questionnaire data. We took several steps to reduce 
these errors.

To minimize some of these errors, the state and district questionnaires 
were each pretested three times to ensure that respondents would 
understand the questions and that answers could be provided. To 
increase the response rate, sampled districts received two calls 
encouraging them to complete and return the questionnaire.

We also performed an analysis to determine whether some sample-based 
estimates compared favorably with known population values.[Footnote 22] 
We performed this analysis for 12 estimates providing information on 
students, teachers, number of schools, and administrators that covered 
major segments those groups. For example, we did an analysis on all 
full-time equivalent classroom teachers but not on teachers of ungraded 
students, which is a very small proportion of all teachers. We used 
these values for the 511 sample respondents to produce sample estimates 
to the total population of all 14,503 districts. These estimated 
values, their associated 95 percent confidence intervals, and their 
true population values are presented in table 8.

Table 8: Sample Estimates Compared to Population Values:

Description of estimate: Students with Individualized Education 
Programs; Mean per district estimated from survey respondents: 455.6; 
Lower bound of 95 percent confidence interval: 391.8; Upper bound: of 
95 percent confidence interval: 519.5; Mean per district for 
population: 424.8.

Description of estimate: Full-time equivalent classroom teachers; Mean 
per district estimated from survey respondents: 186.0; Lower bound of 
95 percent confidence interval: 157.8; Upper bound: of 95 percent 
confidence interval: 214.2; Mean per district for population: 180.8.

Description of estimate: Students in Pre-Kindergarten to 12th grade; 
Mean per district estimated from survey respondents: 3,306.8; Lower 
bound of 95 percent confidence interval: 2,851.2; Upper bound: of 95 
percent confidence interval: 3,762.3; Mean per district for population: 
3,168.1.

Description of estimate: Total diploma recipients; Mean per district 
estimated from survey respondents: 198.5; Lower bound of 95 percent 
confidence interval: 169; Upper bound: of 95 percent confidence 
interval: 227.9; Mean per district for population: 201.4.

Description of estimate: Limited English proficient students; Mean per 
district estimated from survey respondents: 268.9; Lower bound of 95 
percent confidence interval: 210.5; Upper bound: of 95 percent 
confidence interval: 327.3; Mean per district for population: 340.9.

Description of estimate: Schools in district; Mean per district 
estimated from survey respondents: 6.7; Lower bound of 95 percent 
confidence interval: 5.9; Upper bound: of 95 percent confidence 
interval: 7.5; Mean per district for population: 6.2.

Description of estimate: Local Education Authority administrators; Mean 
per district estimated from survey respondents: 4.2; Lower bound of 95 
percent confidence interval: 3.6; Upper bound: of 95 percent confidence 
interval: 4.8; Mean per district for population: 3.7.

Description of estimate: LEA support staff; Mean per district estimated 
from survey respondents: 11.8; Lower bound of 95 percent confidence 
interval: 9.8; Upper bound: of 95 percent confidence interval: 13.9; 
Mean per district for population: 10.9.

Description of estimate: School administrators; Mean per district 
estimated from survey respondents: 10.4; Lower bound of 95 percent 
confidence interval: 8.9; Upper bound: of 95 percent confidence 
interval: 11.9; Mean per district for population: 9.7.

Description of estimate: School administrative support staff; Mean per 
district estimated from survey respondents: 17.3; Lower bound of 95 
percent confidence interval: 14.6; Upper bound: of 95 percent 
confidence interval: 19.9; Mean per district for population: 16.5.

Description of estimate: Student support services staff; Mean per 
district estimated from survey respondents: 10.8; Lower bound of 95 
percent confidence interval: 9.3; Upper bound: of 95 percent confidence 
interval: 12.2; Mean per district for population: 10.6.

Description of estimate: Instructional coordinators and supervisors; 
Mean per district estimated from survey respondents: 2.9; Lower bound 
of 95 percent confidence interval: 2.2; Upper bound: of 95 percent 
confidence interval: 3.6; Mean per district for population: 2.5.

Source: GAO analysis of Education's 2000-1 CCD data:

Note: LEAs are also known as school districts.

[End of table]

For 11 out of the 12 estimates we examined, the population value falls 
within the 95 percent confidence interval for the estimate, thus 
providing some indication that respondents to this survey reflect the 
12 characteristics we examined in the population. Although these 
characteristics were selected because they might be related to other 
characteristics of district teachers and district administration, we do 
not know the extent to which the survey respondents would reflect the 
population characteristics for the specific questions asked on our 
survey. For example, we are not certain whether districts responding to 
the survey were further along in the implementation of Title II 
requirements than the districts that did not respond.

Our sample was not designed to produce geographical area estimates, and 
we did not explicitly stratify our sample by state or region. However, 
our sample was selected nationally and all regions are represented in 
our sample. The following table summarizes sample size and responses 
for 10 regions.

Table 9: Population and Sample by Region:

Region number: 1; State in each region: CT, ME, MA, NH, RI, and VT; 
Districts in population: 1,079; Districts in sample: 42; Districts 
responding: 25.

Region number: 2; State in each region: NY and NJ; Districts in 
population: 1,281; Districts in sample: 49; Districts responding: 27.

Region number: 3; State in each region: DE, DC, MD, PA, VA, and WV; 
Districts in population: 731; Districts in sample: 41; Districts 
responding: 26.

Region number: 4; State in each region: AL, FL, GA, KY, MS, NC, SC, and 
TN; Districts in population: 1,049; Districts in sample: 113; Districts 
responding: 76.

Region number: 5; State in each region: IL, IN, MI, MN, OH, and WI; 
Districts in population: 3,413; Districts in sample: 179; Districts 
responding: 111.

Region number: 6; State in each region: AR, LA, NM, OK, and TX; 
Districts in population: 2,061; Districts in sample: 144; Districts 
responding: 100.

Region number: 7; State in each region: IA, KS, MO, and NE; Districts 
in population: 1,744; Districts in sample: 54; Districts responding: 
30.

Region number: 8; State in each region: CO, MT, ND, SD, UT, and WY; 
Districts in population: 1,111; Districts in sample: 42; Districts 
responding: 32.

Region number: 9; State in each region: AZ, CA, HI, and NV; Districts 
in population: 1,375; Districts in sample: 135; Districts responding: 
62.

Region number: 10; State in each region: AK, ID, OR, and WA; Districts 
in population: 659; Districts in sample: 31; Districts responding: 22.

Total: Districts in population: 14,503; Districts in sample: 830; 
Districts responding: 511.

Source:

Note: for this table, we adopted the Department of Education's region 
definitions as provided at http://www.ed.gov/offices/OIIA/Regions.

[End of table]

On the basis of the national distribution of our sample and on the 
result of our comparison of a set of survey estimates to known 
population values from the CCD file, we chose to include the survey 
results in our report and to produce sample based estimates to the 
total population of school districts in our study population.

We chose not to report the survey responses to questions asking about 
the number of highly qualified teachers because other information from 
the survey and our in-depth discussions with officials during our site 
visits indicated that the respondents could not accurately answer the 
question. For example, three of five officials who completed the survey 
but did not answer this question commented in the survey that they 
could not answer because they could not count the number of teachers. 
Additionally, one official who reported that 100 percent of the 
teachers were highly qualified and another who reported 94 percent, 
also commented that they were unable to count their teachers. During 
our site visits we learned that officials did not have know the 
criteria for some groups of teachers, did not have data systems to 
allow them to track teachers by class and therefore, could not 
accurately determine how many teachers were highly qualified.

Other Methodology:

We also visited 8 states with a range of characteristics that might 
affect their meeting Title II requirement for highly qualified 
teachers. Those states were California, Connecticut, Illinois, Iowa, 
Maryland, North Carolina, Delaware, and Wyoming. We visited and 
interviewed officials in 2 districts in each state, one of which was a 
high-poverty district, and one school in each district. We interviewed 
Department of Education officials, and officials and representatives 
from several professional organizations. We also reviewed the 
legislation, the regulations, and guidance as well as related reports 
and other relevant documents. We conducted our work between July 2002 
and May 2003 in accordance with generally accepted government auditing 
standards.

[End of section]

Appendix II: Activities on Which States Can Spend Title II, Part A 
Funds:

Table 10 lists our summaries of the authorized activities on which 
states can spend Title II funds and shows the five categories we used 
to group them.

Table 10: Title II, Part A State Activities:

Category: Accountability; Activity: Developing systems to measure the 
effectiveness of professional development programs and strategies to 
document improvements in students' academic achievement; 
Ensuring that teachers use 
challenging state academic content standards, assessments, and student 
achievement standards to improve their teaching practices and their 
students' achievement.

Category: Certification; Activity: Reforming teacher and principal 
certification; Reforming tenure and implementing tests for subject 
matter knowledge; Promoting license and certification reciprocity 
agreements with other states for teachers and principals; Providing 
programs that 
establish, expand, or improve alternative routes for state 
certification, especially for highly qualified individuals in the areas 
of mathematics and science.

Category: Professional development; Activity: Conducting programs that 
provide support to teachers, such as those that provide teacher 
mentoring and use assessments that are consistent with student academic 
achievement standards; 
Providing professional development for teachers and principals; 
Developing or assisting local educational agencies 
(LEAs) in developing and using, proven innovative strategies for 
intensive professional development programs that are both cost 
effective and easily accessible; 
Encouraging and supporting the training of teachers 
and administrators to integrate technology into curricula and 
instruction, including training to improve their ability to use data to 
improve their teaching; Providing assistance to 
teachers to enable them to meet certification, licensing, or other 
Title II requirements needed to become highly qualified.

Category: Recruitment and retention; Activity: Developing or assisting 
LEAs to develop, merit-based performance systems and strategies that 
provide pay differentials and bonus pay for teachers in academic 
subjects in which there is high need; Developing projects and programs 
to encourage men to become elementary teachers; Establishing and 
operating a statewide clearinghouse and programs for the recruitment, 
placement, and retention of teachers; 
Assisting LEAs and schools in recruiting and 
retaining highly qualified teachers, including specialists in core 
subjects; Developing or assisting LEAs to 
develop, teacher advancement initiatives that promote professional 
growth, and emphasize multiple career paths and pay differentiation.

Category: Technical assistance; Activity: Fulfilling the state agency's 
responsibility to properly and efficiently carry out the administration 
of programs, including providing technical assistance to LEAs; 
Assisting LEAs to develop and implement 
professional development programs and school leadership academies for 
principals and superintendents.

Source: NCLBA Pub.L. No. 107-110, section 2113 (2002).

[End of table]

[End of section]

Appendix III: Activities on Which Districts Can Spend Title II, Part A 
Funds:

Table 11 lists our summaries of the authorized activities on which 
districts can spend Title II funds and shows the two categories we used 
to group them.

Table 11: Title II, Part A District Activities:

Category: Professional development; Activity: Providing professional 
development activities for teachers and principals that improve their 
knowledge of their core subjects and effective instructional 
strategies; Carrying out professional development activities 
designed to improve the quality of principals and superintendents; 
Carrying out teacher advancement initiatives to 
promote professional growth and to emphasize multiple career paths and 
pay differentiation; Carrying out programs and 
activities that are designed to improve the quality of teachers, such 
as professional development programs, merit pay programs, and testing 
teachers in the subjects they teach.

Category: Recruitment and retention; Activity: Developing and 
implementing mechanisms to assist schools in effectively recruiting and 
retaining highly qualified teachers and principals; 
Developing and implementing initiatives to retain 
highly qualified teachers and principals, particularly in schools with 
a high percentage of low-achieving students; including programs that 
provide teacher mentoring and incentives; Carrying out programs and 
activities related to exemplary teachers; 
Developing and implementing initiatives to assist 
schools in recruiting and hiring teachers, including providing 
financial incentives, and establishing programs that train and hire 
special education and other teachers, recruit qualified professionals 
from other fields, and provide increased opportunities for minorities, 
individuals with disabilities and others; Hiring highly qualified 
teachers in order to reduce class size, particularly in the early 
grades.

Source: NCLBA Pub.L. No. 107-110, section 2123 (2002).

[End of section]

[End of table]

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

UNITED STATES DEPARTMENT OF EDUCATION:

THE UNDER SECRETARY:

July 3, 2003:

Ms. Marnie Shaul Director:

Education, Workforce, and Income Security Issues 
United States General Accounting Office 
Washington, D.C. 20548:

Dear Ms. Shaul:

This is in response to your draft report entitled "No Child Left Behind 
Act: Complete Guidance and More Information Would Help States Determine 
How Many Teachers are Highly Qualified" (GAO-03-631). We have carefully 
reviewed the document and appreciate the opportunity to provide 
comments.

The U.S. Department of Education recognizes that States, districts, and 
schools face many implementation issues as they strive to meet the 
teacher qualification standards created in the No Child Left Behind Act 
of 2001. The law sets forth basic requirements for teachers, but 
provides States considerable flexibility in such areas as determining 
what constitutes full State certification and what is a "high objective 
uniform State standard of evaluation" of teacher competence. We 
recognize it is important to provide timely and informative guidance, 
while respecting each State's ability to develop its own systems for 
implementing the law.

The report recommends that the Secretary provide complete guidance and 
more information to the States. We have been working with States to 
provide accurate and timely assistance, recognizing that in these early 
stages of implementation, issues take time and attention. The 
Department released, on December 2, 2002, Title I Regulations and, on 
December 19, 2002, Title II - A Non-Regulatory Guidance. In response to 
requests for clarification about how the "highly qualified" 
requirements apply to special education and limited English proficient 
(LEP) teachers, guidance included in the Appendix of the Title I Final 
Regulations clarifies that both special education and LEP teachers "who 
are providing instruction in core academic content areas must meet the 
highly qualified requirements of ESEA." This guidance further clarifies 
that "special educators who do not directly instruct students on any 
core academic subject or who provide only consultation to highly 
qualified teachers of core academic subjects on behavioral supports and 
interventions and selecting appropriate accommodations do not need to 
meet the same "highly qualified" subject-matter competency requirements 
that apply under NCLB to teachers of core academic subjects.":

We continue to work with the Council of Chief State School Officers' 
INTASC (Interstate New Teachers Assessment and Support Coalition) to 
discuss teacher quality issues at several national meetings. The 
Department convened all State Title II Directors to discuss teacher 
quality issues at a national meeting on June 12, 2003. We are in the 
process of sending out teacher quality
support teams, establishing a technical assistance and evaluation 
support plan, and expanding our guidance on issues that are still 
outstanding.

Additionally, the Department has funded the new "What Works 
Clearinghouse" to identify research-based best practices related to, 
among other things, teacher training and teaching in subject areas. 
Many States have asked for our help, and we have provided and will 
continue to provide assistance. We engage in conversations daily 
assisting States in meeting the highly qualified teacher goals of NCLB.

Demonstration of subject area competency is a key requirement in the 
highly qualified teacher provisions. Each State has the option within 
the law to develop a way for veteran teachers to demonstrate that 
competency. The Department has not issued written guidance on the "high 
objective uniform State standard of evaluation" (HOUSSE) requirements, 
but we have provided large-scale technical assistance at various 
meetings across the country, such as at a recent meeting of the 
National Association of State Directors of Teacher Education and 
Certification (NASDTEC). We continue to work with State officials by 
offering technical assistance on ensuring that a State's HOUSSE system 
reflects the requirements in the law. Several States have developed 
draft procedures and have asked the Department for feedback and 
comments. As we continue to learn more about promising strategies and 
models for HOUSSE, the Department will actively share these with 
States.

Additionally, the report identifies many issues that are outside of the 
scope of the federal requirements, and that are matters of State and 
local policy. A Federal "one size fits all" approach would be 
undesirable and counterproductive, as States and districts strive to 
meet the requirements of the statute in a manner that meshes with the 
teacher certification, teacher assessment, and data collection systems 
of each individual State. The Department will continue to provide 
technical assistance wherever possible, in order to assist States in 
the development of their plans.

There are significant resources available to States to meet the "highly 
qualified teacher" requirements. However, the report identifies only 
the amount of Title II-A funds that districts and States may use to 
help teachers become highly qualified. The report should instead note 
that, under NCLB, districts must use between five and ten percent of 
their Title I-A funding for this purpose, and that they also have 
available Title V and other Title I-A funds. Without that inclusion, 
the report significantly understates the Federal investment available 
to help districts and schools meet the requirements.

The No Child Left Behind Act also provides LEAs with flexibility to 
consolidate certain Federal funds to carry out activities, including 
programs that improve teacher quality, that best meet their own needs. 
For example, under the State and Local Transferability Act, an LEA not 
identified as being in need of improvement or corrective action under 
Title I may transfer up to 50 percent of its formula allocation under 
the Improving Teacher Quality State Grants, Educational Technology 
State Grants, State Grants for Innovative Programs, and Safe and Drug-
Free Schools State Grants programs to its allocation under: (1) any of 
the other authorized programs; or (2) Part A of Title I.

We encourage States to act boldly as they develop plans to meet the 
requirements of the law. Highly qualified teachers are vital to student 
achievement and realizing the promise and potential of NCLB. The law 
recognizes this fundamental principal, and the Department of Education 
does as well. We look forward to continuing our work assisting States 
in implementing these important goals.

Sincerely,

Eugene W. Hickok:

Signed by Eugene W. Hickok:

[End of section]

Appendix V: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Carolyn M. Taylor (202) 512-2974 or taylorcm@gao.gov Mary E. Roy (202) 
512-7072 or roym@gao.gov:

Staff Acknowledgments:

In addition to those named above, the following individuals made 
important contributions to this report: Susan Higgins, Anjali 
Tekchandani, David Garten, Joel Grossman, Richard Kelley, Mark Ramage, 
Minnette Richardson, Susan Bernstein, and Jeff Edmondson.


FOOTNOTES

[1] In this report, the term "district" refers to local education 
agencies.

[2] Core subjects include English, reading or language arts, 
mathematics, science, foreign languages, civics and government, 
economics, arts, history, and geography.

[3] All percentage estimates produced from the district survey have 
sampling errors of no more than plus or minus 10 percentage points, at 
a 95 percent confidence level, unless otherwise noted. 

[4] Sanders, W. and Rivers, J., Cumulative and Residual Effects of 
Teachers on Future Student Academic Achievement. Knoxville, TN: 
University of Tennessee Value-Added Research and Assessment Center, 
November, 1996.

[5] Kati Haycock, Closing the Achievement Gap (The Education Trust, 
March 2001). 

[6] National Center for Education Statistics, U.S. Department of 
Education, The Condition of Education 2002.

[7] Title I of NCLBA requires that every state that accepts Title I 
funds must ensure that all their teachers meet the requirement. All 
states and the District of Columbia have accepted the funds. Title I of 
NCLBA is designed to help educate disadvantaged children--those with 
low academic achievement attending schools serving high-poverty areas. 
Title I was appropriated funding of over $10 billion in fiscal year 
2002. 

[8] For 2002, the poverty threshold was $18,556 annually for a family 
of four. 

[9] Many states have alternate routes to certification, referred to 
here as alternative certification programs, that allow an individual 
who has a bachelor's degree from a college or university but who does 
not hold a degree in education, to receive a license to teach. 
Alternative certification programs range from those that place people 
in classrooms immediately to longer programs that delay placing people 
in classrooms until they have completed course work and received a 
mentor. While these programs vary within and among states, nearly all 
states have some type of alternative to the traditional path of 
majoring in education in order to become a teacher. 

[10] National Center for Education Statistics, Schools and Staffing 
Survey, 1990-2000, "Number and Percent of Public School Special 
Education Teachers Who Teach Special Education Classes as Their Main 
Assignment or as Their Second Assignment" (2002).

[11] Cynthia Prince, Higher Pay in Hard to Staff Schools: The Case for 
Financial Incentives, American Association of School Administrators, 
June 2002.

[12] In this report, when discussing a shortage of teachers in the high 
need subject area of special education, we are referring to a shortage 
of persons qualified to be special education teachers to teach core 
subjects to children with disabilities as defined in Section 602 of the 
Individuals with Disabilities Education Act Amendments of 1997. 

[13] Department of Education, Qualifications of the Public School 
Teacher Workforce: Prevalence of Out-of-Field Teaching 1987-88 and 
1999-2000, Statistical Analysis Report, Schools and Staffing Survey, 
National Center for Education Statistics, 2002.

[14] As provided in Title II of NCLBA, programs to support new teachers 
include teacher mentoring, team teaching, reduced class schedules, and 
intensive professional development.

[15] The Higher Education Act defines distance education as an 
educational process where the student is separated in time or place 
from the instructor.

[16] For example, districts must use 5 to 10 percent of their Title I-
A funds in fiscal years 2002 and 2003 for professional development 
activities to ensure that teachers become highly qualified. 

[17] State education agencies receive 5 percent of the total grant 
funds and can retain up to 1 percent of these funds for administrative 
costs. Of the remaining funds, 2.5 percent must be spent on subgrants 
to eligible partnerships and the remaining funds are to be used for 
authorized activities. We grouped the Title II activities into five 
categories: (1) accountability, (2) certification, (3) professional 
development, (4) recruitment and retention, and (5) technical 
assistance. Appendix II lists all 18 activities.

[18] Districts are to spend their Title II funds on 9 authorized 
activities that we grouped into 2 categories: (1) professional 
development and (2) recruitment and retention. Appendix III lists all 9 
activities.

[19] U. S. Department of Education, The Class-Size Reduction Program: 
Boosting Student Achievement in Schools Across the Nation, A First-Year 
Report, September 2000.

[20] "City" is defined as a central city of Consolidated Metropolitan 
Statistical Area (CMSA) or as a central city of a Metropolitan 
Statistical Area (MSA). "Urban" refers to Urban Fringe (an incorporated 
place, Census Designated Place, or nonplace territory within a CMSA or 
MSA of a city and defined as urban by the Census Bureau), to a large 
town (an incorporated place or Census Designated Place with a 
population greater than or equal to 25,000 and located outside a CMSA 
or MSA), or to an incorporated place or Census Designated Place with a 
population less than 25,000 and greater than 2,500 located outside a 
CMSA or MSA. A "rural community" is any incorporated place, Census 
Designated Place, or nonplace territory designated as rural by the 
Census Bureau.

[21] Poverty level was not available on the CCD data files; however, as 
a proxy for poverty, we stratified based on participation in the free/
reduced student meals program. For sample selection, high-poverty 
districts are those districts having at least 60 percent participation 
in free/reduced meals programs. Less than 60 percent participation in 
this program identifies a district as a low-poverty district for 
stratification purposes.

[22] This was possible because the CCD population file contains certain 
data elements for the universe of districts from which we drew our 
sample.

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