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entitled 'Reading First: States Report Improvements in Reading 
Instruction but Additional Procedures Would Clarify Education's Role in 
Ensuring Proper Implementation by States' which was released on March 
23, 2007. 

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United States Government Accountability Office: 

Report to Congressional Requesters: 

GAO: 

February 2007: 

Reading First: 

States Report Improvements in Reading Instruction, but Additional 
Procedures Would Clarify Education's Role in Ensuring Proper 
Implementation by States: 

GAO-07-161: 

GAO Highlights: 

Highlights of GAO-07-161, a report to congressional requesters 

Why GAO Did This Study: 

The Reading First program was designed to help students in kindergarten 
through third grade develop stronger reading skills. This report 
examines the implementation of the Reading First program, including (1) 
changes that have occurred to reading instruction; (2) criteria states 
have used to award sub-grants to districts, and the difficulties, if 
any, states faced during implementation; and (3) the guidance, 
assistance, and oversight the Department of Education (Education) 
provides states. GAO’s study is designed to complement several studies 
by Education’s Inspector General (IG) in order to provide a national 
perspective on some of the specific issues being studied by the IG. For 
this report, GAO administered a Web-based survey to 50 states and the 
District of Columbia, and conducted site visits and interviews with 
federal, state, and local education officials and providers of reading 
programs and assessments. 

What GAO Found: 

States reported that there have been a number of changes to, as well as 
improvements in, reading instruction since the implementation of 
Reading First. These included an increased emphasis on the five key 
components of reading (awareness of individual sounds, phonics, 
vocabulary development, reading fluency, and reading comprehension), 
assessments, and professional development with more classroom time 
being devoted to reading activities. However, according to publishers 
we interviewed, there have been limited changes to instructional 
material. Similarly, states report that few changes occurred with 
regard to their approved reading lists. 

States awarded Reading First sub-grants using a variety of different 
eligibility and award criteria, and some states reported difficulties 
with implementing key aspects of the program. After applying federal 
and state eligibility and award criteria, Education reported that over 
3,400 districts were eligible to apply for sub-grants in the states’ 
first school year of funding. Of these districts, nearly 2,100 applied 
for and nearly 1,200 districts received Reading First funding. (See 
figure for percentages.) 

Education officials made a variety of resources available to states 
during the application and implementation processes, and states were 
generally satisfied with the guidance and assistance they received. 
However, Education developed no written policies and procedures to 
guide Education officials and contractors in their interactions with 
state officials and guard against officials mandating or directing 
states’ decisions about reading programs or assessments, which is 
prohibited by NCLBA and other laws. Based on survey results, some state 
officials reported receiving suggestions from Education officials or 
contractors to adopt or eliminate certain reading programs or 
assessments. Similarly, the IG reported in September 2006 that the 
Department intervened to influence a state’s and several school 
districts’ selection of reading programs. In addition, while Education 
officials laid out an ambitious plan for annual monitoring of every 
state’s implementation, they did not develop written procedures guiding 
monitoring visits and, as a result, states did not always understand 
monitoring procedures, timelines, and expectations for taking 
corrective actions. 

Figure: Percentages of Eligible, Applicant and Awarded Districts 
Nationwide During States' First School Year of Funding: 

[See PDF for Image] 

Source: GAO analysis based on U.S. Department of Education data. 

[End of figure] 

What GAO Recommends: 

GAO recommends that Education establish control procedures to guide 
departmental officials and contractors in their interactions with 
states, districts, and schools to ensure compliance with statutory 
provisions. GAO also recommends that Education establish and 
disseminate clear procedures governing its monitoring process. 
Education, in its response to a draft of this report, agreed with GAO’s 
recommendations. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-161]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cornelia Ashby at (202) 
512-8403 or ashbyc@gao.gov. 

[End of figure] 

Contents: 

Letter: 

Results in Brief: 

Background: 

States Reported Changes as Well as Improvements in Reading Instruction 
Since the Inception of Reading First: 

States Awarded Reading First Sub-Grants to School Districts Using a 
Variety of Different Criteria, and Some States Reported Difficulties 
with Implementation: 

Education Provided a Wide Range of Guidance, Assistance, and Oversight, 
Generally Satisfying State Officials, but Education Lacked Controls to 
Guard against Mandating or Endorsing Curricula and Did Not Provide 
Written Monitoring Procedures: 

Conclusions: 

Recommendations: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Descriptions of Assessment Types: 

Appendix III: Comments from the Department of Education: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Reading Program Publishers Most Frequently Represented on 
States' Approved Lists: 

Table 2: Approaches States Used to Develop Their Approved Lists: 

Table 3: Guidance and Assistance Provided to States during Application 
and Implementation Processes: 

Table 4: States' Reported Sources of Guidance for Key Reading First 
Implementation Components: 

Figures: 

Figure 1: The Process for Awarding State Sub-grants to School 
Districts: 

Figure 2: Improvements in Professional Development for Reading First 
Teachers: 

Figure 3: All School Districts Nationwide That Were Eligible for, That 
Applied for, and Were Awarded Reading First Sub-grants in the First 
School Year of Funding: 

Figure 4: States Level of Ease or Difficulty Implementing Key Reading 
First Program Aspects: 

Figure 5: Issues Education Raised About States' Reading First 
Applications: 

Figure 6: Geographic Regions for Reading First Regional Technical 
Assistance Centers: 

Figure 7: States' Assessment of Whether Written Guidance Provided 
Information Needed to Adequately Address Application Components: 

Abbreviations: 

AIR: American Institutes for Research: 

CRRFTAC: Central Regional Reading First Technical Assistance Center: 

DEOA: Department of Education Organizing Act: 

DIBELS: Dynamic Indicators of Basic Early Literacy Skills: 

Education: Department of Education: 

ERRFTAC: Eastern Regional Reading First Technical Assistance Center: 

IG: Inspector General: 

Interim Report: Education's Reading First Implementation: 

Evaluation: Interim Report: 

K-3rd: kindergarten through third grade: 

NCLBA: No Child Left Behind Act: 

NIFL: National Institute for Literacy: 

RMC: RMC Research Corporation: 

SEA: state education agency: 

SBRR: scientifically-based reading research: 

TAC: Technical Assistance Center: 

WRRFTAC: Western Regional Reading First Technical Assistance Center: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 28, 2007: 

The Honorable Edward M. Kennedy: 
Chairman: 
The Honorable Michael B. Enzi: 
Ranking Minority Member: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable George Miller: 
Chairman: 
Committee on Education and Labor: 
House of Representatives: 

The Honorable Jeff Bingaman: 
United States Senate: 

The Honorable Richard G. Lugar: 
United States Senate: 

The Reading First program, signed into law in 2002 as part of the No 
Child Left Behind Act (NCLBA), was designed based on reading research 
to help children in kindergarten through third grade develop stronger 
reading skills. Since 2002, Congress has appropriated about $1 billion 
a year for Reading First, more than for any other federal reading 
program, to fund 6-year grants to states. States, in turn, have awarded 
sub-grants to school districts to establish reading programs. These sub-
grants are targeted to districts and schools with the highest 
percentage or numbers of students in kindergarten through third (K-3rd) 
grade reading below grade level and to districts and schools with large 
numbers of low-income students. However, in awarding sub-grants, states 
do have some discretion to establish priorities, such as giving 
priority to districts that demonstrated leadership and commitment to 
improving reading. 

The Reading First program places a number of requirements on state and 
local grant recipients to ensure they adopt reading programs and 
methods that are effective, while, at the same time, NCLBA provisions 
restrict the ability of Department of Education (Education) officials 
to mandate or direct state and local decisions on reading curriculum. 
In particular, Reading First requires states and participating school 
districts to adopt scientifically-based reading programs containing key 
instructional components identified in the law. In some instances, 
state officials have required prospective Reading First districts to 
choose their reading program from a state-approved list. In contrast, 
other states have opted to vest district applicants with responsibility 
for researching and selecting the reading programs to be used in their 
Reading First schools. States and participating school districts are 
also required to provide professional development in reading that is 
based on scientific research and to track students' progress in reading 
using valid and reliable assessments. However, NCLBA and various other 
statutory provisions place limits on what Education officials can 
require states, districts, and schools to do. For example, under NCLBA, 
Education officials are not authorized to mandate, direct, or control 
state, school district or school curriculum or program of 
instruction.[Footnote 1] In other words, these provisions are intended 
to preserve state and local control over key aspects of the public 
school system. 

During the implementation of the Reading First program some concerns 
were raised by publishers of reading programs to Congress and others 
about Education's interactions with state and local grantees regarding 
reading programs and assessments. Specifically, several groups 
representing reading programs filed complaints with Education's 
Inspector General alleging that Education officials, contractors, and 
consultants pressured state and local applicants to choose specific 
reading programs and assessments--actions that are expressly prohibited 
by NCLBA. 

In response to these allegations, Education's Inspector General (IG) 
undertook several separate investigations and audits of various aspects 
of the program's administration. For the first of these reports, issued 
in September 2006, the IG reviewed various aspects of the application 
process for awarding Reading First grants to states, including the 
selection and composition of the expert panel that reviewed state 
applications, application review and feedback procedures, and 
interactions between Education and state-level officials.[Footnote 2] 
During its review, the IG, among other things, interviewed federal and 
selected state officials and reviewed departmental guidance, internal e-
mail correspondence, and state applications from 11 states and 1 
territory. Among its findings, the IG reported that the Department 
intervened to influence a state's and several school districts' 
selection of reading programs, actions that call into question whether 
program officials violated statutory prohibitions against directing or 
controlling state and local curricular decisions.[Footnote 3] The IG 
made a number of related recommendations, including that the Department 
should (1) develop internal management policies and procedures to 
ensure that programs are managed in compliance with applicable laws and 
regulations, (2) review the management and staff structure of the 
Reading First program office, and (3) develop guidance for program 
officials on statutory prohibitions on intervening in state and local 
curricular decisions. The Secretary of Education concurred with all of 
the report's recommendations. In their written comments to the IG 
report, Education officials detailed numerous action steps they planned 
to undertake in response to the report's findings and recommendations, 
including the appointment of new internal leadership for the Reading 
First program,[Footnote 4] the development of annual training on 
internal controls, and the drafting of a memorandum for all program 
managers regarding the importance of impartial job performance. 

GAO's study is designed to complement the IG's work by providing a 
national perspective on some of the specific issues being studied by 
the IG, as well as providing some information on how the program has 
been implemented at the state level, primarily. To obtain a better 
understanding of how the Reading First program is being implemented at 
the state level and to determine how Education conducts its 
interactions with states and the kind of guidance and oversight it 
provides, GAO agreed to answer the following questions: 

1. What changes have occurred to reading instruction since the 
inception of Reading First? 

2. What criteria have states used to award Reading First sub-grants to 
districts, and what, if any, difficulty did states face in implementing 
the program? 

3. What guidance, assistance, and oversight did Education provide 
states related to the Reading First program? 

To answer these questions, we collected information about the Reading 
First program from a variety of sources. We conducted a Web- based 
survey of the Reading First Directors in all 50 states and the District 
of Columbia, and 100 percent responded. We also obtained and analyzed 
data from the Department of Education for each state on Reading First 
districts' eligibility, applications, and awards for states' first 
school year of funding. To assess the reliability of this data, we 
talked to agency officials about data quality control procedures and 
reviewed relevant documentation. We also conducted semi- structured 
follow-up interviews with Reading First Directors in 12 states and 
conducted site visits to 4 of the 12 states. During the site visits, we 
met with state and district officials, as well as school officials, 
including teachers, principals, and Reading First coaches. We selected 
these 12 states to represent diversity in terms of geographic 
distribution, grant size, poverty rates, and student reading 
achievement, as well as the presence or absence of a statewide list of 
approved reading programs. In our selection of the 12 states, we also 
took into consideration whether or not state officials reported that 
they had received guidance from Education officials advocating for or 
against particular reading programs or assessments. For both the survey 
and follow-up interviews, we agreed to protect the respondents' 
confidentiality to encourage candid responses: therefore; we will not 
identify states by name in this report. We also interviewed 
administrators from each of the three regional Reading First Technical 
Assistance Centers (TAC), officials from RMC Research--which provided 
technical assistance to states during the application process and 
oversaw the TACs, and the American Institutes for Research (AIR)--the 
contractor responsible for conducting monitoring visits in each state. 
In addition, we interviewed several publishers and other providers of 
reading curricula and assessments, as well as Reading First officials 
and attorneys at Education. We also reviewed state grant files, 
monitoring reports, and related correspondence for the 12 states where 
we conducted follow-up interviews, as well as legislation and guidance 
related to Reading First. We also interviewed Education officials about 
the implementation of the Reading First program. Finally, we reviewed 
Education's study "Reading First Implementation Evaluation: Interim 
Report" to identify information collected at the district and school 
level that related to the findings from our state survey and also the 
two relevant reports that had been issued by Education's Inspector 
General at the time our audit work was completed. 

See appendix I for additional information on the survey, as well as our 
other data collection methods. We conducted our work from December 2005 
through January 2007 in accordance with generally accepted government 
auditing standards. 

Results in Brief: 

Since the inception of Reading First, states reported changes as well 
as improvements in reading instruction due to increased emphasis on 
reading instruction, assessments, and professional development, despite 
limited changes to instructional material. In our survey, 69 percent of 
all states reported great or very great improvement in reading 
instruction. One specific area in which states reported an improvement 
is the degree to which classroom instruction explicitly incorporates 
the key instructional components of the program. In addition, state and 
local officials we interviewed reported that the use of assessments 
changed after Reading First, especially in the way that teachers use 
data from these assessments to better inform reading instruction. All 
states reported improvement in professional development with more than 
80 percent of states reporting that professional development for 
reading teachers improved greatly or very greatly. Further, over 75 
percent of states reported great or very great increases in the 
frequency of and resources devoted to teacher professional development. 
At the same time, the publishers we interviewed reported making few 
significant changes to instructional materials as a result of Reading 
First. While three of the four major publishers reported that they had 
not made significant changes, some of these publishers stated that they 
had made minor changes to their reading materials to highlight the key 
instructional components of Reading First. 

States awarded Reading First sub-grants to districts using a variety of 
different eligibility and award criteria, and some states reported 
difficulties with implementing key aspects of the program. States 
varied in how they defined and established eligibility and award 
criteria as permitted under Reading First. After applying eligibility 
criteria, Education reported that over 3,400 school districts--or about 
20 percent of all districts nationwide--were eligible to apply for 
Reading First sub-grants in the states' first school year of funding. 
After applying award criteria to the nearly 2,100 eligible districts 
that applied, Education reported that nearly 1,200 school districts--or 
about 34 percent of all eligible districts and nearly 7 percent of all 
districts nationwide--received Reading First funds. With respect to 
implementation difficulties, 22 states reported that it was difficult 
or very difficult to help districts with reading scores that had not 
improved sufficiently. Furthermore, 17 states reported that it was 
either difficult or very difficult to assess how districts applied 
scientifically-based reading research in choosing their reading 
program. 

Education officials made a variety of resources available to states 
during the application and implementation process, including written 
guidance and criteria, workshops, conferences, dedicated contractors 
and regional technical assistance centers, as well as written feedback 
from both the application review panel and annual monitoring visits. 
States were generally satisfied with the various forms of Reading First 
guidance and assistance they received, but Education failed to 
establish controls to guard against mandating or directing curricula 
and clear monitoring procedures. For example, state officials were 
generally positive in characterizing the assistance they received from 
Education officials and contractors, with officials from 48 states 
reporting in our survey that Education staff were helpful or very 
helpful in addressing states' implementation-related questions and 
officials from 41 states reporting the same for the TACs. However, 
Education developed no written or other formal guidance outlining 
policies and procedures to guide the behavior of Education officials or 
contractors in providing Reading First guidance and assistance to 
states. Responses from several state officials suggest that Education 
officials may have violated the statutory prohibition against mandating 
or directing local curricular decisions by effectively endorsing or 
directing the selection of particular Reading First programs. According 
to responses to our survey, Reading First officials or contractors made 
specific recommendations about reading programs and assessments to 
officials in several states. Specifically, officials from 10 states 
reported receiving suggestions that they eliminate specific programs or 
assessments, and officials from 4 states reported receiving suggestions 
to adopt specific programs or assessments. Five states also reported 
receiving recommendations from Reading First officials to change some 
of their proposed professional development providers. In addition, 
while Education officials laid out an ambitious plan for annually 
monitoring every state's implementation, Education did not develop 
transparent procedures to guide its monitoring visits and, as a result, 
states did not always understand monitoring procedures, timelines, and 
expectations. For example, officials from one state said they were 
unaware of Education's expectation that states respond to monitoring 
findings, and officials from another state told us that Education 
officials never responded to the justification they submitted in 
response to specific monitoring findings. 

We are making two recommendations to Education. First, in addition to 
addressing the IG's recommendations to develop internal (1) policies 
and procedures to guide program managers on when to solicit advice from 
General Counsel and (2) guidance on the prohibitions imposed by section 
103(b) of the Department of Education Organizing Act (DEOA), we 
recommend that Education also establish control procedures to guide 
departmental officials and contractors in their interactions with 
states, districts, and schools. We also recommend that Education 
develop and distribute guidelines regarding its monitoring procedures 
so that states and districts are aware of their roles, 
responsibilities, and timelines. In its comments on a draft of this 
report, Education agreed with our recommendations and indicated that it 
will take actions to address them. 

Background: 

Reading First, which was enacted as part of NCLBA, aims to assist 
states and local school districts in establishing reading programs for 
students in kindergarten through third grade by providing funding 
through 6-year formula grants. The goal of the program is to ensure 
that every student can read at grade level or above by the end of third 
grade. To that end, Reading First provides funds and technical 
assistance to states and school districts to implement programs 
supported by scientifically-based reading research (SBRR), increase 
teacher professional development based on this research, and select and 
administer reading assessments to screen, diagnose, and monitor the 
progress of all students. NCLBA defines SBRR as research that (1) uses 
systematic, empirical methods that draw on observation or experiment; 
(2) involves rigorous data analyses that test stated hypotheses and 
justify general conclusions; (3) relies on measurements or 
observational methods that are valid; and (4) has been accepted by a 
peer-reviewed journal or approved by a panel of independent experts. 
Further, NCLBA requires states to adopt reading programs that contain 
the five essential components of reading--(1) phonemic awareness; (2) 
phonics; (3) vocabulary development; (4) reading fluency, including 
oral reading skills; and (5) reading comprehension strategies.[Footnote 
5] 

While Education has responsibility for overseeing the Reading First 
program and states' implementation and compliance with statutory and 
program requirements, NCLBA places restrictions on what Education 
officials can require states to do. Specifically, Education is not 
authorized to mandate, direct, control, or endorse any curriculum 
designed to be used in elementary or secondary schools.[Footnote 6] 
Further, when Education was formed in 1979, Congress was concerned 
about protecting state and local responsibility for education and, 
therefore, placed limits in Education's authorizing statute on the 
ability of Education officials to exercise any direction, supervision, 
or control over the curriculum or program of instruction, the selection 
of textbooks or personnel, of any school or school system.[Footnote 7] 

Every state could apply for Reading First funds, and states were 
required to submit a state plan for approval that demonstrates how they 
will ensure that statutory requirements will be met by districts. 
Education, working in consultation with the National Institute for 
Literacy (NIFL), as required in NCLBA, established an expert review 
panel composed of a variety of reading experts to evaluate state plans 
and recommend which plans should be approved. In these plans, states 
were required to describe how they would assist districts in selecting 
reading curricula supported by SBRR, valid and reliable[Footnote 8] 
reading assessments, and professional development programs for K-3RD 
grade teachers based on SBRR. The law does not call for Education to 
approve or disapprove particular reading programs or curricula 
identified in state plans. When appropriate, the peer review panel was 
to also recommend clarifications or identify changes it deemed 
necessary to improve the likelihood of a state plan's success. NCLBA 
requires that Education approve each state's application only if it 
meets the requirements set forth in the law. 

Reading First allows states to reserve up to 20 percent of their funds 
for professional development; technical assistance; and planning, 
administrative, and reporting activities.[Footnote 9] For example, 
states can use their funds to develop and implement a professional 
development program to prepare K-3rd teachers in all essential 
components of reading instruction. One model for supporting teachers' 
reading instruction involves hiring a Reading Coach who works with 
teachers to implement reading activities aligned with SBRR. Almost all 
states require Reading First schools to have a Reading Coach tasked 
with supporting teachers and principals with instruction, administering 
assessments, and interpreting assessment data. 

States that receive Reading First grants are required to conduct a 
competitive sub-grant process for eligible school districts and must 
distribute at least 80 percent of the federal Reading First grants they 
receive to districts. NCLBA and Education guidance provides states with 
flexibility to set eligibility criteria for school districts so that 
eligible districts are among those in the state that have the highest 
number or percentage of K-3RD grade students reading below grade level 
and (1) have jurisdiction over an empowerment zone or enterprise 
community,[Footnote 10] (2) have a significant number or percentage of 
schools identified as in need of improvement,[Footnote 11] or (3) are 
among the districts in the state that have the highest number or 
percentages of children counted as poor and school-aged for the 
purposes of Title I.[Footnote 12] NCLBA establishes priorities that 
states must consider when awarding a Reading First sub-grant, while 
also allowing states to establish other priority areas. For instance, 
NCLBA requires that the state sub-grant process give priority to 
districts with at least 15 percent of students or 6,500 children from 
families with incomes below the poverty line, but states also have some 
flexibility to establish additional priorities, such as a demonstrated 
commitment to improving reading achievement. The sub-grant process 
along with the criteria at each stage is summarized in figure 1. 

Figure 1: The Process for Awarding State Sub-grants to School 
Districts: 

[See PDF for image] 

Source: GAO analysis based on U.S. Department of Education guidance. 

[End of figure] 

Districts are required to use their sub-grant funds to carry out 
certain activities identified in NCLBA. For example, districts must use 
these funds to select and implement reading programs based on SBRR that 
include the essential components of reading instruction, to select and 
implement diagnostic reading assessment tools, and to provide 
professional development opportunities for teachers. Additionally, 
districts are permitted to use Reading First funds in support of other 
activities, such as training parents and tutors in the essential 
components of reading instruction. 

States are required to report to Education annually on the 
implementation of Reading First, including their progress in reducing 
the number of students who are reading below grade level. Additionally, 
states are required to submit a mid-point progress report to Education 
at the end of the third year of the grant period. These mid-point 
progress reports are subject to review by the same expert peer review 
panel that evaluated state applications. If Education determines, after 
submission and panel review of a state's mid-point progress report and 
on the basis of ongoing Education monitoring, that a state is not 
making significant progress, Education has the discretion to withhold 
further Reading First grant payments from that state. While these state 
reports to Education are intended to provide information on the 
effectiveness of Reading First, Education is also required to contract 
with an independent organization outside Education for a rigorous and 
scientifically-valid, 5-year, national evaluation of the program, with 
a final report scheduled to be issued in 2007. 

The Reading First program has relied on several key contractors to 
perform a number of program functions. For example, Education officials 
hired RMC Research Corporation, a company that provides research, 
evaluation, and related services to educational and human services 
clients, to provide technical assistance to states and districts that 
have received Reading First funding. According to Education officials, 
RMC contractors were tasked initially with providing specific, 
individualized guidance on the application process to state officials 
who requested it. RMC later became the national coordinator for the 
contract overseeing the National Center for Reading First Technical 
Assistance and its three regional subsidiaries: the Eastern Regional 
Reading First Technical Assistance Center (ERRFTAC) in Tallahassee, 
Florida; the Central Regional Reading First Technical Assistance Center 
(CRRFTAC) in Austin, Texas; and the Western Regional Reading First 
Technical Assistance Center (WRRFTAC) in Eugene, Oregon. In this role, 
RMC staff provides support to the TACs and their employees, as well as 
weekly coordination among the TACs, and regular training seminars. 
Operated out of universities recognized by Education officials for 
their expertise in SBRR and related areas, the centers began operations 
in 2003 and are responsible for providing an array of technical 
assistance activities to states, including national and regional 
conferences, training and professional development, products and 
materials, and liaisons to national reading experts. Education 
officials also contracted with Learning Point Associates to provide 
technical assistance to states as they launched their sub-grant 
competitions. 

Once Reading First sub-grants had been awarded to local districts, 
Education contracted with the American Institutes for Research (AIR), a 
behavioral and social science research organization, to conduct annual 
monitoring visits to each state. These visits incorporate sessions with 
state officials, as well as visits to a few districts in each state and 
are designed to assess states' and districts' compliance with their 
approved plans. After each monitoring visit, AIR representatives submit 
a report, including any findings of non-compliance, to Reading First 
officials. Reading First officials are to forward these reports to the 
cognizant state officials. 

States Reported Changes as Well as Improvements in Reading Instruction 
Since the Inception of Reading First: 

States reported that there have been a number of changes and 
improvements[Footnote 13] in reading instruction since the 
implementation of Reading First. There has been an increased emphasis 
on the five key components of reading,[Footnote 14] assessments, and 
professional development with more classroom time being devoted to 
reading activities. However, according to publishers we interviewed, 
there have been limited changes to instructional material. Similarly, 
many states that approved reading programs for districts to choose from 
report few changes to their lists of approved programs. 

States Reported That Reading Instruction Changed or Improved Following 
the Implementation of Changes under Reading First: 

In responding to our survey, 69 percent of all states reported great or 
very great improvement in reading instruction since inception of 
Reading First. One area in which states[Footnote 15] reported a change 
that may have contributed to improvement of reading was the degree to 
which classroom instruction explicitly incorporated the five key 
components. In our survey, at least 39 states reported that Reading 
First schools had incorporated each of the five required components of 
reading into curriculum to a great or very great degree as a result of 
Reading First. State and local officials we talked to during some of 
our site visits reinforced this opinion and in particular noted that 
Reading First teachers had awareness of and were more focused on the 
five components. In addition, the increased time devoted to reading 
activities under Reading First may have contributed to improvement. 
Several district officials we met with told us they were including a 
protected, uninterrupted block of time for reading instruction of 90 
minutes or more per day--which the department's Guidance for the 
Reading First Program lists as a key element of an effective reading 
program. Education's Reading First Implementation Evaluation: Interim 
Report (The Interim Report)[Footnote 16] also found that Reading First 
teachers reported allocating over 90 minutes per day, on average, for a 
designated reading block. 

States officials reported improvement in reading instruction resulting 
from the use of assessments.[Footnote 17] In responding to our survey, 
one state official said, "One of the strengths of the Reading First 
program has been its strong adherence to SBRR and to the use of valid 
and reliable assessments in guiding instruction and program 
evaluation." A number of state and local officials we interviewed 
reported that the use of assessments changed after Reading First, 
especially in the way that teachers use data from these assessments to 
better inform reading instruction. Specifically, district officials we 
talked to during our site visits reported that teachers review 
students' assessment results to determine the areas in which they need 
more targeted instruction. One official also reported that assessment 
data can sometimes be used to identify successful teachers from whom 
other teachers can learn teaching techniques, with one official 
asserting that "Reading First has and is making a great impact on 
teachers' instructional practices, techniques, and strategies." Also, 
according to Education's Interim Report, researchers estimated that 83 
percent of Reading First teachers cited assessment results essential to 
organizing instructional groups, 85 percent cited the results essential 
to determining progress on skills, and 75 percent cited the results 
essential to identifying students who need reading intervention. 

According to our survey, most states also reported that the assessments 
they used differed greatly or very greatly from the ones they used 
prior to Reading First. States reported a wide variety of reading 
assessments on their state-approved lists, with over 40 different 
assessments listed. By far, the most frequently approved assessment was 
Dynamic Indicators of Basic Early Literacy Skills (DIBELS), approved by 
45 states. Also, a few states reported to us that they were moving 
toward a more uniform systematic assessment system for the first time, 
whereas previously each school could choose which assessment it would 
use. Some state and district officials told us that having a more 
uniform and systematic assessment was beneficial, because, for 
instance, it allowed the officials to track and compare reading scores 
more easily. 

Professional development is another area in which state officials noted 
improvement. All states reported improvement in professional 
development as a result of Reading First, with at least 41 states 
reporting that professional development for reading teachers improved 
greatly or very greatly in each of five key instructional areas. 
Further, a considerable majority of states reported great or very great 
increases in the frequency of professional development and the 
resources devoted to it, 45 and 39, respectively. One state reported, 
"The provision of funding to be used to support statewide professional 
development efforts for K-3 reading has been an important aspect of the 
program." The Interim Report on the Reading First program highlights 
that a vast majority of Reading First teachers had received training on 
the five key components of reading. In our site-visits, district 
officials confirmed that, for the most part, teachers in their Reading 
First classrooms had received training. However, in responding to our 
survey, 19 states did report some challenges in training of 100 percent 
of Reading First teachers, with teacher turnover cited by 12 states as 
the reason some Reading First teachers might not have taken any type of 
Reading First training. Figure 2 summarizes reported improvements in 
professional development for teachers. 

Figure 2: Improvements in Professional Development for Reading First 
Teachers: 

[See PDF for image] 

Source: GAO analysis. 

[End of figure] 

Professional development was provided by a variety of federal, state, 
and private sources. Staff from the TACs and officials from at least 
one state reported providing professional development to districts 
customized to the individual district's needs and perceived future 
needs. Education's Interim Report on Reading First implementation noted 
that state Reading First coordinators in 33 states reported that state 
staff chose and organized all statewide professional development 
efforts and played a key role in selecting professional development 
topics for districts and schools. In addition, publishers we spoke with 
told us they often provide training to acclimate teachers to their 
products. Certain publishers of major commercial reading programs and 
assessments told us that since the implementation of Reading First, 
districts demand much more training. Specifically, according to some of 
the publishers and TAC staff we spoke with, districts have been 
interested in more in-depth workshops on particular topics such as 
teaching techniques and using and interpreting assessments. 

Finally, another aspect of professional development pertinent to 
Reading First is the presence of a Reading Coach. State and district 
officials reported that Reading Coaches receive training that better 
enables them to assist schools. Education's Interim Report found that 
each Reading Coach worked with an average of 1.2 schools and with 21 
teachers to help implement activities aligned with SBRR. 

Publishers Reported Making Few Changes to Reading Programs, and States 
Reported Adopting a Variety of Approaches to Select Reading Programs: 

Three of the four major publishers of reading programs we spoke with 
reported that they had not made significant changes to the content of 
their reading programs as a result of Reading First. Two publishers 
stated that they made minor changes to their reading materials to make 
more explicit how the content of the existing programs align with the 
five components emphasized in Reading First. Two of them reported that 
they made changes to their programs based on the National Reading 
Panel's findings, which was prior to the enactment of Reading First. 
For example, representatives of one company stated that they launched a 
new reading program based on the findings of the National Reading Panel 
that takes into account the requirements of Reading First. Despite 
limited changes to the actual instructional material, all the 
publishers noted a greater emphasis on assessing the efficacy of their 
reading programs as a result of Reading First. In an effort to measure 
the effectiveness of their programs, the publishers reported devoting 
more effort to research and to evaluate how effective their reading 
programs were at raising reading assessment scores. 

States followed two main approaches in selecting reading programs for 
districts --22 identified a state-approved list of programs for 
districts to select, while the other 29 did not have a state-approved 
list, thereby requiring districts in those states to self-select 
reading programs and determine, with some state oversight and subject 
to state approval, whether they satisfy the requirements of SBRR. Of 
the 22 states with approved lists, reading program publishers most 
frequently represented on the lists were Houghton Mifflin, McGraw-Hill, 
and Harcourt (see table 1). At the school level, Education found in its 
Interim Report that these three reading program publishers were also 
the most frequently used, estimating that between 11 and 23 percent of 
schools used programs from one of them. 

Table 1: Reading Program Publishers Most Frequently Represented on 
States' Approved Lists: 

Publisher name: Houghton Mifflin[A]; 
Number of states: 21. 

Publisher name: McGraw-Hill-Education[B]; 
Number of states: 21. 

Publisher name: Harcourt[C]; 
Number of states: 19. 

Publisher name: Pearson[D]; 
Number of states: 15. 

Publisher name: Success for All Foundation "Success for All"; 
Number of states: 11. 

Source: GAO analysis. 

[A] Because some states listed publisher (parent company) names instead 
of reading program names, our analysis will only reflect overall totals 
based on publisher names. "The Nation's Choice," a program published by 
Houghton Mifflin, would be included in this category. 

[B] McGraw-Hill Education includes SRA-"Open Court," SRA-"Reading 
Mastery," and "MacMillan McGraw-Hill Reading." 

[C] Harcourt, Inc. publishing includes "Trophies." 

[D] Pearson Scott Foresman includes "Scott Foresman Reading," "Longman 
ESL," and "Scott Foresman Reading Street." 

[End of table] 

Additionally, of the 22 states that identified a list of approved core 
reading programs[Footnote 18] for Reading First, 8 already had a list 
of approved core reading programs for adoption by all schools in their 
state prior to Reading First. Only two of these states reported 
removing reading programs--a total of six--from their lists because 
they did not meet Reading First requirements. According to Education's 
Interim Report, an estimated 39 percent of Reading First schools 
reported adopting a new core reading program at the beginning of the 
2004-2005 school year in which they received their Reading First grant, 
in contrast with an estimated 16 percent of non-Reading First Title I 
schools. 

States used a variety of sources to help them identify and select 
reading programs that met Reading First's criteria. For example, 15 of 
the 22 states with state-approved lists reported using the Consumer's 
Guide to Evaluating A Core Reading Program Grades K-3: A Critical 
Elements Analysis to make this decision.[Footnote 19] Other frequently 
used resources include criteria in the state's application for Reading 
First, information obtained at Reading First Leadership 
Academies[Footnote 20] provided by Education, and other states' 
approved lists. Based on responses to our survey, the table below 
summarizes approaches states used to develop their approved lists (see 
table 2). 

Table 2: Approaches States Used to Develop Their Approved Lists: 

Approaches: Conducted review of reading programs using A Consumer's 
Guide to Evaluating a Core Reading Program (Kame'enui & Simmons); 
Number of states: 15. 

Approaches: Conducted review of reading programs using criteria 
outlined in your state's Reading First application; 
Number of states: 12. 

Approaches: Based on information obtained during Reading First 
Leadership Academies; 
Number of states: 8. 

Approaches: Adopted reading programs from another state's approved 
list(s); 
Number of states: 7. 

Approaches: Used existing textbook adoption list; 
Number of states: 6. 

Approaches: Requested a Reading First Technical Assistance Center 
review of reading programs; 
Number of states: 3. 

Approaches: Based on recommendation from U.S. Department of Education 
officials; 
Number of states: 2. 

Source: GAO analysis. 

[End of table] 

Based on our survey results, 25 of the 29 states reporting that they 
did not have a list of approved core reading programs said they 
provided guidance for districts and schools to identify core reading 
programs. Fifteen of these states reported directing districts and 
schools to conduct a review of reading programs using A Consumer's 
Guide to Evaluating a Core Reading Program. Other states reported 
providing a variety of guidance to districts to help them select 
reading programs supported by SBRR, including referring them to the 
approved lists of other states and reviews conducted by academic 
experts. 

States Awarded Reading First Sub-Grants to School Districts Using a 
Variety of Different Criteria, and Some States Reported Difficulties 
with Implementation: 

States varied in how they exercised their flexibility to set additional 
eligibility and award criteria as allowed by the Reading First program, 
and some states reported difficulty with implementing key aspects of 
the Reading First program while other states did not. In the areas in 
which they were given flexibility, states used a variety of criteria 
for determining eligibility and in awarding sub-grants to eligible 
districts, such as awarding grants to districts that had previously 
received federal reading dollars. Education reported that over 3,400 
school districts were eligible to apply for Reading First sub-grants in 
the states' first school year of funding.[Footnote 21],[Footnote 22] Of 
these districts, nearly 2,100 applied for and nearly 1,200 received 
Reading First sub-grants in the states' first school year of funding. 
In addition, 22 states reported that it was difficult or very difficult 
to help districts with reading scores that had not improved 
sufficiently. On the other hand, 28 states reported that it was easy or 
very easy to determine whether districts' applications met criteria for 
awarding sub-grants. 

States Varied in How they Exercised Their Flexibility to Set Additional 
School District Sub-grant Eligibility and Award Criteria: 

States varied in how they exercised their flexibility to set school 
district eligibility criteria for sub-grants. The Reading First program 
provides states with some flexibility to define eligibility criteria 
within the statutory guidelines. For instance, while Reading First 
requires that states target districts with students in kindergarten 
through third grade reading below grade level, states have flexibility 
to set eligibility criteria based on the percentage and/or number of 
these students within districts. While 34 states reported electing to 
base eligibility on a percentage of schools with students reading below 
grade level, 18 states reported electing to base eligibility on a 
number of students reading below grade level.[Footnote 23] After 
applying eligibility criteria, Education reported that states 
determined that over 3,400 school districts were eligible to apply for 
Reading First sub-grants for states' first school year of funding, or 
about 20 percent of all school districts nationwide. However, the 
percentage of eligible districts varied greatly across the states, 
ranging from about 3 to 93 percent. 

Of those districts eligible to apply, 62 percent, or nearly 2,100 
districts, did so, as summarized in figure 3 below. States reported a 
variety of reasons why eligible school districts did not apply such as 
the prescriptive nature of the program, differences in educational 
philosophy, and inadequate resources for the application process. For 
example, officials from a few states reported that some districts did 
not have the capacity to write the grant application. An official from 
one state reported that some districts did not have the time and the 
staff to complete the sub-grant process. Furthermore, an official from 
another state reported that the application process was too lengthy and 
time-consuming to complete. 

Nineteen states reported in our survey that they exercised flexibility 
in establishing priorities when awarding Reading First sub-grants. 
States set a variety of additional priorities for awarding grants to 
school districts. For instance, six states reported that they gave 
priority to districts that already had other grants, such as Early 
Reading First grants,[Footnote 24] or indicated that they could somehow 
use their Reading First funds in combination with other resources to 
maximize the number of students reading at grade level. In contrast, 
two states gave priority to districts that had not received other grant 
funding. In addition, two states gave priority to districts based on 
the population of Native Americans or students with limited English 
proficiency. After applying selection criteria, states awarded Reading 
First sub-grants to about 34 percent or nearly 1,200 school districts 
for states' first school year of funding. This represented about 56 
percent of the 2,100 eligible districts that applied and nearly 7 
percent of all school districts nationwide for states' first school 
year of funding (see fig. 3). 

Figure 3: All School Districts Nationwide That Were Eligible for, That 
Applied for, and Were Awarded Reading First Sub-grants in the First 
School Year of Funding: 

[See PDF for image] 

Source: GAO analysis based on U.S. Department of Education data. 

[End of figure] 

Some States Reported Difficulty Implementing Key Aspects of the 
Program: 

Some states reported difficulty in implementing key aspects of the 
Reading First program. Twenty-two states reported that it was either 
difficult or very difficult to help districts with reading scores that 
had not improved sufficiently.[Footnote 25] Officials from one state 
said that this was difficult because it requires close examination of 
students reading deficiencies and the commitment of school leadership. 
Officials from another state reported some difficulty in improving 
selected reading skills of students with limited English proficiency, 
which are concentrated in pockets around the state. Seventeen states 
reported that it was either difficult or very difficult to assess how 
districts applied SBRR in choosing their reading program. Finally, 
seven states reported difficulty implementing four or more of six key 
program aspects listed in our survey and shown in figure 4. Officials 
from one of these states told us that the difficulty with 
implementation was due to the newness of the program for which 
everything had to be developed from scratch. 

On the other hand, states reported ease implementing other key aspects. 
In particular, 28 states reported that it was easy or very easy to 
determine whether districts' applications met criteria for awarding sub-
grants. For example, states are required to determine whether districts 
will adhere to the key components of the program, such as developing a 
professional development program or using reading assessments to gauge 
performance. Several states we interviewed suggested that it was easy 
to make this determination because some of the Reading First 
requirements were already in place in their states before Reading First 
was implemented. For example, some state officials we interviewed 
mentioned using reading assessments prior to Reading First. In 
addition, officials in one state told us that they already had a 
professional development program in place to train teachers on the 
state's reading program. Twenty-four states reported that it was easy 
or very easy to identify reading programs based on SBRR. 

Figure 4: States Level of Ease or Difficulty Implementing Key Reading 
First Program Aspects: 

[See PDF for image] 

Source: GAO analysis. 

[End of figure] 

Education Provided a Wide Range of Guidance, Assistance, and Oversight, 
Generally Satisfying State Officials, but Education Lacked Controls to 
Guard against Mandating or Endorsing Curricula and Did Not Provide 
Written Monitoring Procedures: 

Education officials provided states a wide variety of guidance, 
assistance, and oversight, but Education lacked written procedures to 
guide its interactions with the states and provided limited information 
on its monitoring procedures. Education's guidance and assistance 
included written guidance, preparatory workshops, feedback during the 
application process, and feedback from monitoring visits. Additionally, 
guidance and assistance were provided by Education's contractors, 
including the regional technical assistance centers. For the most part, 
state officials characterized the guidance and assistance they received 
from Education officials and contractors, especially the regional 
technical assistance centers, as being helpful or very helpful, and 
many also reported relying on the expertise of Reading First officials 
in other states. However, Education lacked controls to ensure that its 
officials did not endorse or otherwise mandate or direct states to 
adopt particular reading curricula. For example, according to state 
officials, Education officials and contractors made suggestions to some 
states to adopt or eliminate certain reading programs, assessments, or 
professional development providers. In addition, some state officials 
reported a lack of clarity about key aspects of the annual monitoring 
process, including time frames and expectations of states in responding 
to monitoring findings. 

Education Provided a Wide Range of Guidance and Assistance: 

Education provided a variety of written and informal guidance and 
assistance to states to help them prepare their applications. For 
example, three months after the enactment of NCLBA in January 2002, 
Education issued two key pieces of written guidance to states 
pertaining to the Reading First program and grant application process: 
the Guidance for the Reading First Program and Criteria for Review of 
State Applications. Education officials also sponsored three Reading 
Leadership Academies in the early part of 2002. The Academies were 
forums for state education officials to obtain information and build 
their capacity to implement key aspects of the Reading First program, 
including professional development and the application of SBRR. 
Education contracted with RMC Research Corporation to provide technical 
assistance to states related to the grant application process. States 
reported seeking guidance from RMC on various aspects of the Reading 
First application, in particular the use of instructional assessments 
(17 states) and instructional strategies and programs (14 states). 
Throughout the application process, both Education and RMC officials 
were available to address states' questions. In particular, Education 
officials provided feedback to states on the results of expert review 
panel evaluations of their applications. Consequently, a large number 
of states reported that Education required them to address issues in 
their applications, most commonly related to the use of instructional 
assessments (33 states) and instructional strategies and programs (25 
states). See figure 5 for issues raised about state applications. Forty-
eight states reported that they needed to modify their application at 
least once, and 27 reported modifying them three or more times. 

Figure : Issues Education Raised About States' Reading First 
Applications: 

[See PDF for image] 

Source: GAO analysis. 

[End of figure] 

Once grants were awarded, Education continued to provide assistance and 
contracted with RMC Research to oversee three regional TACs to help 
states implement Reading First. RMC established three TACs affiliated 
with state university centers in Florida, Texas, and Oregon, which RMC 
and TAC officials told us were selected based on their expertise in one 
or more areas central to the success of the Reading First program, such 
as professional development or reading assessment. Each technical 
assistance center was responsible for providing comprehensive support 
to each of the states in its geographic region (see fig. 6). States 
reported that they looked to these centers for guidance on a variety of 
issues, especially creating professional development criteria, using 
reading assessments, and helping districts with reading scores that had 
not improved sufficiently. According to TAC staff, some of the most 
common requests they receive pertain to the use and interpretation of 
assessment data and use of Reading Coaches. TAC staff also told us that 
they catalog recurring issues or problems. 

Figure 6: Geographic Regions for Reading First Regional Technical 
Assistance Centers: 

[See PDF for image] 

Source: U.S. Department of Education. 

[End of figure] 

In addition, according to one RMC official and some state officials, 
the TACs provided support to states during implementation to help them 
supplement their capacity and expertise in evaluating whether or not 
reading programs proposed by districts were based on SBRR. For 
instance, staff from the TAC in Florida explained that some states in 
their region had asked for assistance in evaluating reading programs 
that had been in use prior to Reading First to gauge their compliance 
with the requirements of Reading First. Staff from the TAC emphasized 
that in reviewing these reading programs, they used the criteria in 
each state's approved state plan as the criteria for determining 
compliance with Reading First requirements. Officials in one state 
explained that while the staff at their state educational agency (SEA) 
possessed the knowledge necessary to conduct reviews of reading 
programs, scarce state staff resources would have made it difficult to 
conclude the reviews in the short time frame available. Though 
Education officials were aware of and initially condoned the TAC review 
process, Education officials advised all TACs to discontinue reviews of 
programs--to avoid the appearance of impropriety--after allegations 
were raised about Reading First officials expressing preference for 
specific reading programs. (Table 3 provides a summary of the types of 
guidance and assistance provided by Education and its contractors.) 

Table 3: Guidance and Assistance Provided to States during Application 
and Implementation Processes: 

Source: Final Guidance for the Reading First Program and Criteria for 
Review of State Applications; 
Type: Written guidance; 
Purpose: Interpreting the provisions of NCLBA authorizing the Reading 
First program and providing guidance on the criteria review panel 
members would be using in evaluating states' applications; 
Time frame: Application process. 

Source: Reading Leadership Academies; 
Type: Workshops; 
Purpose: Helping states master key features of the Reading First 
program, in particular the application of SBRR in classroom and 
professional development activities; 
Time frame: Application process. 

Source: RMC Research technical assistance providers; 
Type: Technical assistance; 
Purpose: Providing technical assistance to states including training in 
SBRR; 
Time frame: Application process. 

Source: Regional Reading First Technical Assistance Centers; 
Type: Technical assistance; 
Purpose: Providing guidance to states about conducting their district 
sub-grant competitions, delivering training, assistance, and related 
materials in response to requests from state- level Reading First 
officials, and training including annual workshops for states; 
Time frame: Implementation process. 

Source: GAO analysis. 

[End of table] 

During the application and implementation phases of the Reading First 
program, many states came to rely on other unofficial sources of 
guidance, including other states' Reading First officials, in addition 
to the written guidance provided by Education. For example, as noted 
earlier, among the 22 states that had an approved list of reading 
programs for Reading First districts, 15 reported using A Consumer's 
Guide to Evaluating a Core Reading Program to assist them in reviewing 
potential reading programs. In addition, officials from 21 states 
reported that other states' Reading First Coordinators provided great 
or very great help during the Reading First state grant application 
process. Further, a number of state officials reported using the 
information from other states' websites, such as approved reading 
programs, to help inform their own decisions pertaining to the 
selection of reading programs. One state official explained, "With our 
limited infrastructure and dollars, we were never able to muster the 
resources needed to run an in-house programs review," and further that, 
"It worked well for us to use the programs and materials review results 
from larger states that ran rigorous review processes." Another state 
official reported that the state did not feel equipped to apply the 
principles of SBRR in evaluating reading programs and responded by 
comparing one state's review and subsequent list of reading programs to 
those of a few other states to make judgments about allowable programs. 

States Were Generally Satisfied with the Guidance and Assistance 
Available to Them: 

Most states reported making use of and being satisfied with the primary 
sources of guidance available to them over the course of the Reading 
First application and implementation processes. For example, 46 states 
reported making use of the two key pieces of Education's written 
guidance in preparing their Reading First applications. A majority of 
states also reported that these pieces of guidance provided them with 
the information needed to adequately address each of the key 
application components. For example, over 40 states reported that the 
guidance related to the definition of sub-grant eligibility and 
selection criteria for awarding sub-grants helped them adequately 
address these areas in their application. However, officials in eight 
states reported that the guidance on the use of instructional 
assessments did not provide them with the information needed to 
adequately address this area. (See fig. 7.) 

Figure 7: States' Assessment of Whether Written Guidance Provided 
Information Needed to Adequately Address Application Components: 

[See PDF for image] 

Source: GAO analysis. 

[End of figure] 

Overall, most state officials were also satisfied with the level of 
assistance they received from Education staff and their contractors in 
addressing issues related to the Reading First application and 
implementation processes. For example, state officials in 39 states 
reported that Education staff were of great or very great help during 
the application or implementation process. Additionally, officials from 
48 states reported that Education officials were helpful or very 
helpful in addressing states' implementation-related questions, which 
frequently dealt with using reading assessments and helping districts 
with reading scores that had not improved sufficiently. A number of 
state officials reported to us that they appreciated the guidance and 
attention they received from Reading First officials at Education. For 
example, one state Reading First Coordinator reported, "the U.S. 
Department of Education personnel have been wonderful through the 
process of implementing Reading First. I can't say enough about how 
accessible and supportive their assistance has been." Another state 
official remarked that the state's efforts to make reading improvements 
"would have been impossible without their [Education officials and 
contractors] guidance and support." Even officials from one state who 
had a disagreement with Education over its suggestion to eliminate a 
certain reading program characterized most of the guidance they 
received from Reading First officials as "excellent." However, one 
state official reported feeling that the technical assistance workshops 
have served as conduits for Education officials to send messages about 
the specific reading programs and assessments they prefer. Another 
state official reported that, "core programs and significant progress 
have not been defined" and that "SBRR programs are not clearly 
designated." 

According to responses obtained to our survey, the three TACs also 
provided a resource for states seeking advice on issues pertaining to 
the implementation of their Reading First programs. Specifically, 41 
states cited the Centers as helpful or very helpful in addressing 
states' inquiries related to the implementation of Reading First. In 
addition, on a variety of key implementation components, more state 
officials reported seeking information from their regional TACs than 
they did from Education officials (see table 4). 

Table 4: States' Reported Sources of Guidance for Key Reading First 
Implementation Components: 

Implementation component: Creating professional development criteria; 
Number of states seeking guidance or assistance from Education and the 
TACs: Education: 6; 
Number of states seeking guidance or assistance from Education and the 
TACs: TACs: 41. 

Implementation component: Identifying reading programs based on SBRR; 
Number of states seeking guidance or assistance from Education and the 
TACs: Education: 9; 
Number of states seeking guidance or assistance from Education and the 
TACs: TACs: 24. 

Implementation component: Assessing how districts applied principles of 
SBRR; 
Number of states seeking guidance or assistance from Education and the 
TACs: Education: 10; 
Number of states seeking guidance or assistance from Education and the 
TACs: TACs: 29. 

Implementation component: Using reading assessments; 
Number of states seeking guidance or assistance from Education and the 
TACs: Education: 20; 
Number of states seeking guidance or assistance from Education and the 
TACs: TACs: 40. 

Implementation component: Helping districts with reading scores that 
have not improved sufficiently; 
Number of states seeking guidance or assistance from Education and the 
TACs: Education: 12; 
Number of states seeking guidance or assistance from Education and the 
TACs: TACs: 36. 

Implementation component: Other implementation issues related to 
approving district applications; 
Number of states seeking guidance or assistance from Education and the 
TACs: Education: 18; 
Number of states seeking guidance or assistance from Education and the 
TACs: TACs: 20. 

Source: GAO analysis. 

[End of table] 

Education Lacked Written Procedures to Guide Its Interactions with 
States: 

We found that Education developed no written guidance, policies, or 
procedures to direct or train Education officials or contractors 
regarding their interactions with the states. Federal agencies are 
required under the Federal Managers' Financial Integrity Act of 
1982[Footnote 26] to establish and maintain internal controls to 
provide a reasonable assurance that agencies achieve objectives of 
effective and efficient operations, reliable financial reporting, and 
compliance with applicable laws and regulations.[Footnote 27] When 
executed effectively, internal controls work to ensure compliance with 
applicable laws and regulations by putting in place an effective set of 
policies, procedures, and related training. We found that Education had 
not developed written guidance or training to guide managers on how to 
implement and comply with statutory provisions prohibiting Education 
officials from directing or endorsing state and local curricular 
decisions. Department officials told us that it was their practice that 
program managers should consult the Office of General Counsel if they 
had questions regarding interactions with grantees. Reading First 
officials told us that it was their approach to approve each state's 
method and rationale for reviewing or selecting reading programs as 
outlined in each state's plan and that state compliance with program 
requirements, including adherence to the principles of SBRR, would then 
be assessed using the provisions of these plans as the criteria. 
Similarly, officials from Education's contractors responsible for 
conducting monitoring visits told us that they were instructed by 
Education to use state plans as the criteria for gauging states' 
compliance with Reading First reading program requirements, but that 
they were provided no formal written guidance or training. A senior 
Education attorney who is currently working with Reading First program 
officials told us that he was not aware that they had used this 
approach and that he felt that the statutory requirements should also 
play an important role in the monitoring process. Following the 
publication of the IG's report in September, Education's Office of 
General Counsel has provided training to senior management on internal 
control requirements and has begun working with the Reading First 
office to develop procedures to guide the department's activities. 

Despite the statutory prohibition against mandating or endorsing 
curricula and the department's stated approach to rely on state plans, 
and the processes articulated in them, to assess compliance, states 
reported to us several instances in which Reading First officials or 
contractors appeared to intervene to influence their selection of 
reading programs and assessments. For example, officials from four 
states reported receiving suggestions from Education or its contractors 
to adopt specific reading programs or assessments. Specifically, two 
states reported that it was suggested that they adopt a particular 
reading assessment. Similarly, Education's first IG report also 
documented one instance in which Reading First officials at Education 
worked in concert with state consultants to ensure that a particular 
reading program was included on that state's list of approved reading 
programs.[Footnote 28] 

In addition, states reported that Education officials or contractors 
suggested that they eliminate specific reading programs or assessments 
related to Reading First. Specifically, according to our survey 
results, officials from 10 states reported receiving suggestions that 
they eliminate specific programs or assessments. In some cases, the 
same program was cited by officials from more than one state. In one 
instance, state officials reported that Education officials alerted 
them that expert reviewers objected to a reading program that was under 
consideration but not named explicitly in the state's application. An 
official from a different state reported receiving suggestions from 
Education officials to eliminate a certain reading program, adding that 
Education's justification was that it was not aligned with SBRR. In 
another instance, state officials pointed out that they had adopted a 
program that was approved by other states, according to the procedures 
in their approved state plan, but were told by Education officials that 
it should be removed from their list and that Education would 
subsequently take a similar course of action with regard to those other 
states as well. Also, Education officials did not always rely on the 
criteria found in state plans as the basis for assessing compliance. We 
found, for example, one summary letter of findings from a monitoring 
report in which Education officials wrote that "Two of the monitored 
districts were implementing reading programs that did not appear to be 
aligned with scientifically based reading research." Officials we spoke 
to in that state told us that they did not feel that they had been 
assessed on the basis of the procedures outlined in the state's plan, 
but rather that the reading program itself was being called into 
question. The IG also found that Reading First officials communicated 
to several states against the use of certain reading programs or 
assessments, including Rigby and Reading Recovery. 

Officials from a few states also reported being contacted by Education 
regarding district Reading First applications or reading programs. For 
example, officials from four states reported being contacted by an 
Education official about a district application under consideration and 
one of those states also reported being approached by staff from one of 
the regional technical assistance centers or another contractor for the 
same reason. Officials from each of these states indicated that the 
reason they were contacted stemmed from the reading programs being used 
by the districts in question. In a few cases, state officials reported 
being contacted by Education officials regarding the state's acceptance 
of a reading program or assessment that was not in compliance with 
Reading First. In one instance, state officials reported that Education 
contacted them outside of the normal monitoring process after they had 
obtained information from a national Reading First database maintained 
by a non-profit research organization that districts in the state were 
using a specific reading program. 

Five states also reported receiving recommendations from Reading First 
officials or contractors to change some of the professional development 
providers proposed in their original grant applications. When asked 
about the specific providers identified for elimination, three of the 
states indicated that the providers identified for elimination were in- 
state experts. In one case, a state was told that the review panel 
cited a lack of detail about the qualifications of the state's proposed 
professional development consultants. 

We also found that while Education officials laid out an ambitious plan 
to annually monitor every state, they failed to develop written 
procedures guiding its monitoring visits. For example, Education did 
not establish timelines for submitting final reports to states 
following monitoring visits, specifically how and when state officials 
were expected to follow up with Education officials regarding findings 
from the monitoring visits. As a result, states did not always 
understand monitoring response procedures, timelines, and expectations. 
While we found that most state officials we spoke with understood that 
they were to be monitored with the use of their state plans as the 
criteria, they did not always understand what was required of them when 
responding to monitoring findings. For example, one state official 
reported being unaware that the state was supposed to respond to 
Education officials about findings from its monitoring report. An 
official from another state maintained that he/she was unclear about 
the process the state was to follow to respond to findings, and that no 
timeline for responding was provided to him/her. Furthermore, one state 
reported that findings were not delivered in a timely manner, and 
another state reported that Education did not address the state's 
responses to the monitoring findings. Key aspects of an effective 
monitoring program include communicating to individuals responsible for 
the function any deficiencies found during the monitoring. 

Conclusions: 

The Reading First program, according to state coordinators, has brought 
about changes and improvements to the way teachers, administrators, and 
other education professionals approach reading instruction for children 
in at-risk, low-performing schools during the critical years between 
kindergarten and third grade. To assist states in implementing this 
large, new federal reading initiative, Education has provided a wide 
range of guidance, assistance, and oversight, that, for the most part, 
states have found helpful. However, Education failed to develop 
comprehensive written guidance and procedures to ensure that its 
interactions with states complied with statutory provisions. 
Specifically, Education lacked an adequate set of controls to ensure 
that Reading First's requirements were followed, while at the same time 
ensuring that it did not intervene into state and local curricular 
decisions. We concur with the Education IG's recommendations that the 
Department develop a set of internal procedures to ensure that federal 
statutes and regulations are followed and we feel it is important for 
the Secretary to follow up on these recommendations to ensure that they 
are properly implemented. Additionally, we feel it is important for the 
department to have clear procedures in place to guide departmental 
officials in their dealings with state and local officials. While 
Education's stated approach was to rely on state plans as its criteria 
for enforcing Reading First's requirements, states reported several 
instances in which it appears that Education officials did attempt to 
direct or endorse state and local curricular decisions. Such actions 
would prevent states from exercising their full authority under the law 
and would violate current statutory restrictions. Balancing Reading 
First's requirements and the limits placed on the department requires 
Education to have clear, explicit, and well-documented procedures to 
guide its interactions with the states. Failure to do so places the 
department at risk of violating the law and leaves it vulnerable to 
allegations of favoritism. 

Additionally, while Education's annual monitoring effort for Reading 
First is ambitious, it did not provide clear guidelines and procedures 
to states. As a result, states were not always aware of their roles and 
responsibilities in responding to findings of non-compliance, and 
Education was not always consistent in its procedures to follow up with 
states to resolve findings and let states know if they had taken proper 
actions. Key aspects of an effective monitoring program include 
transparency and consistency. Letting all states know in a timely 
manner whether or not their plans to address deficiencies are adequate 
is important to ensure that findings are dealt with in an appropriate, 
timely and clear manner. 

Recommendations: 

In addition to addressing the IG's recommendations to develop internal 
(1) policies and procedures to guide program managers on when to 
solicit advice from General Counsel and (2) guidance on the 
prohibitions imposed by section 103(b) of the DEOA, we recommend that, 
in order to ensure that the department complies with statutory 
prohibitions against directing, mandating, or endorsing state and local 
curricular decisions, the Secretary of Education also establish control 
procedures to guide departmental officials and contractors in their 
interactions with states, districts, and schools. 

In addition, to help the department conduct effective monitoring of the 
Reading First program, we recommend that the Secretary of Education 
establish and disseminate clear procedures governing the Reading First 
monitoring process. In particular, Education should delineate states' 
rights and responsibilities and establish timelines and procedures for 
addressing findings. 

Agency Comments: 

We provided a draft of this report to the Department of Education and 
received written comments from the agency. In its comments, included as 
appendix III of this report, Education agreed with our recommendations 
and indicated that it will take actions to address them. 

Specifically, Education said it will provide written guidance to all 
departmental staff to remind them of the importance of impartiality in 
carrying out their duties and not construing program statutes to 
authorize the department to mandate, direct, or control curriculum and 
instruction, except to the extent authorized by law. On February 7, 
2007, the Secretary of Education issued a memorandum to senior officers 
reminding them that it is important to maintain objectivity, fairness, 
and professionalism when carrying out their duties. The Secretary's 
memorandum also emphasizes the importance of adhering to the statutory 
prohibitions against mandating, directing, and controlling curriculum 
and instruction, and strongly encourages managers to consult with 
Education's Office of General Counsel early on to identify and resolve 
potential legal issues. Also, according to Education's written comments 
on our draft report and the Secretary's February 7, 2007, memorandum to 
senior officers, annual training will be required on internal controls 
and this training will address statutory prohibitions against 
mandating, directing or controlling local curriculum and instruction 
decisions. 

Regarding its monitoring process for Reading First, in its comments, 
Education said that it will develop and disseminate guidelines to 
states outlining the goals and purposes of its monitoring efforts, 
revise the monitoring protocols, and develop timelines and procedures 
on states' rights and responsibilities for addressing monitoring 
findings. Education also included in its response a summary of its 
actions and planned actions to address recommendations from the 
department's Office of Inspector General's recent report on the 
implementation of the Reading First program. 

As agreed with your offices, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
after its issue date. At that time, we will send copies of this report 
to appropriate congressional committees, the Secretary of Education, 
and other interested parties. Copies will also be made available upon 
request. In addition, the report will be available at no charge on 
GAO's Web site at http://www.gao.gov. If you or your staff have any 
questions about the report, please contact me at (202) 512-7215. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. GAO staff who 
made major contributions to this report are listed in appendix IV. 

Signed by: 

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

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objective was to answer the following questions: (1) What changes 
have occurred to reading instruction since the inception of Reading 
First? (2) What criteria have states used to award Reading First sub- 
grants to districts, and what, if any, difficulty did states face in 
implementing the program? (3) What guidance, assistance, and oversight 
did Education provide states related to the Reading First program? To 
answer these questions, we collected both qualitative and quantitative 
information about the Reading First program from a variety of sources. 
We conducted a Web-based survey of the Reading First Directors in all 
50 states and the District of Columbia. We also obtained and analyzed 
data from the Department of Education for each state on Reading First 
districts' eligibility, applications and awards for states' first 
school year of funding. The first school year of funding varied across 
states. Twenty-five states received their first year of funding in the 
2002-2003 school year. Twenty-five states received their first year of 
funding in the 2003-2004 school year. To assess the reliability of this 
data, we talked to agency officials about data quality control 
procedures and reviewed relevant documentation. We excluded two states 
because of reporting inconsistencies, but determined that the data for 
the other states were sufficiently reliable for the purposes of this 
report. We also conducted semi-structured follow-up interviews with 
Reading First Directors in 12 states, mostly over the telephone. We 
conducted site visits to 4 of the 12 states. During the site visits, we 
met with state officials, local program administrators, and state-level 
technical assistance providers, as well as school officials from 
individual schools, including teachers, principals, and Reading First 
coaches. In identifying local sub-grant recipients to meet with in each 
state, we sought to incorporate the perspectives of urban, rural, and 
suburban school districts. We selected the 12 states to have diversity 
in a variety of factors, including geographic distribution, grant size, 
poverty rate, percentage of students reading at or below grade level, 
urban and rural distinctions, the presence of a statewide list of 
approved reading programs, and whether states had reported that they 
received guidance from Education officials advocating for or against 
particular reading programs or assessments. For both the survey and 
follow-up interviews, to encourage candid responses, we promised to 
provide confidentiality. As a result, state survey responses will be 
provided primarily in summary form or credited to unnamed states, and 
the states selected for follow-up interviews will not be specifically 
identified. Furthermore, in order to adequately protect state 
identities, we are unable to provide the names of particular reading 
programs or assessments Education officials or contractors suggested a 
state use or not use. We did not attempt to verify allegations made by 
state or local officials in their survey responses or during interviews 
or otherwise make any factual findings about Education's conduct. 

We also visited or talked with administrators from each of the three 
regional Reading First Technical Assistance Centers, located in 
Florida, Texas and Oregon, as well as RMC Research, the federal 
contractor tasked with administering the contract with the technical 
assistance centers. We also interviewed several publishers and other 
providers of reading curricula and assessments, to obtain their views 
about changes Reading First has prompted in states, districts, and 
schools. We chose these providers to reflect the perspectives of large, 
commercial reading textbook programs that are widely represented 
nationwide on states' lists of approved programs, as well as some other 
selected providers of reading curricula, including some that have filed 
complaints related to Reading First. We also interviewed Education 
officials about the implementation of the Reading First program. 

To obtain a better understanding of state program structure, as well as 
the nature of interactions between Education officials and state 
grantees, we reviewed state grant files, monitoring reports, and 
related correspondence for the 12 states where we conducted follow-up 
interviews. In addition, we reviewed NCLBA language authorizing Reading 
First, as well as statements of work articulating the responsibilities 
of the regional technical assistance centers and the contractor tasked 
with providing assistance to states in conducting local sub-grant 
competitions. We conducted our work from December 2005 through January 
2007 in accordance with generally accepted government auditing 
standards. 

Survey of States: 

To better understand state implementation of the Reading First program, 
we designed and administered a Web-based survey of the Reading First 
Directors in all 50 states and the District of Columbia. The survey was 
conducted between June and July 2006 with 100 percent of state Reading 
First Directors responding. The survey included questions about 
curriculum; professional development; and state Reading First grant 
eligibility, application, award, and implementation processes. The 
survey contained both closed-and open-ended questions. For the open- 
ended questions, we used content analysis to classify and code the 
responses from the states such as the publishers on states' approved 
lists. We had two people independently code the material, then 
reconciled any differences in coding. Because this was not a sample 
survey, there are no sampling errors. However, the practical 
difficulties of conducting any survey may introduce nonsampling errors, 
such as variations in how respondents interpret questions and their 
willingness to offer accurate responses. We took steps to minimize 
nonsampling errors, including pre-testing draft instruments and using a 
Web-based administration system. Specifically, during survey 
development, we pre-tested draft instruments with one expert reviewer 
and Reading First Directors in four states during April and May 2006. 
In the pre-tests, we were generally interested in the clarity of the 
questions and the flow and layout of the survey. For example, we wanted 
to ensure definitions used in the survey were clear and known to the 
respondents, categories provided in closed-ended questions were 
complete and exclusive, and the ordering of survey sections and the 
questions within each section was appropriate. On the basis of the pre- 
tests, the Web instrument underwent some slight revisions. A second 
step we took to minimize nonsampling errors was using a Web-based 
survey. By allowing respondents to enter their responses directly into 
an electronic instrument, this method automatically created a record 
for each respondent in a data file and eliminated the need for and the 
errors (and costs) associated with a manual data entry process. To 
further minimize errors, programs used to analyze the survey data were 
independently verified to ensure the accuracy of this work. 

[End of section] 

Appendix II: Descriptions of Assessment Types: 

Reading First Assessment Requirements and Descriptions: 
* Reading programs under Reading First must include rigorous 
assessments with proven validity and reliability; 
* Assessments must measure progress in the five essential components of 
reading instruction and identify students who may be at risk for 
reading failure or who are already experiencing reading difficulty; 
* Reading programs under Reading First must include screening 
assessments, diagnostic assessments, and classroom-based instructional 
assessments of progress. 

Assessment type: Screening; 
Description: Reading programs under Reading First must include rigorous 
assessments with proven validity and reliability.: Description: 
Determine which children are at risk for reading difficulty and need 
additional support. 

Assessment type: Diagnostic; 
Description: Reading programs under Reading First must include rigorous 
assessments with proven validity and reliability.: Description: Provide 
more in-depth information on students' skills and instructional needs; 
forms the basis of intervention strategies. 

Assessment type: Classroom- based instructional assessments of 
progress; 
Description: Reading programs under Reading First must include rigorous 
assessments with proven validity and reliability.: Description: 
Determine whether students are making progress and/or need more support 
to achieve grade-level reading outcomes. 

Source: GAO analysis based on Education guidance. 

[End of table] 

[End of section] 

Appendix III: Comments from the Department of Education: 

United States Department Of Education: 
The Deputy Secretary: 

January 30, 2007: 

Ms. Cornelia M. Ashby Director: 
Education, Workforce, and Income Security Issues: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Ashby: 

I am writing in response to your request for comments on the Government 
Accountability Office (GAO) draft report (GAO-07-161), dated February 
2007, and entitled "Reading First: States Report Improvements in 
Reading Instruction, but Additional Procedures Would Clarify 
Education's Role in Ensuring Proper Implementation by States." I 
appreciate the opportunity to comment on the draft report and provide 
further information on our activities to ensure that every student can 
read at grade level or above by the end of grade 3. 

Your report acknowledges the changes to and improvements in reading 
instruction that States indicated are occurring as a result of Reading 
First's support for scientifically based reading instruction, 
assessments, and professional development. According to the 
Department's Reading First Implementation Evaluation: Interim Report, a 
large percentage of Reading First teachers report using assessment 
results for a variety of purposes: to determine progress on skills (85 
percent), to organize instructional groups (83 percent), and to 
identify students who need reading intervention services (75 percent). 
The report indicates that all 50 States and the District of Columbia 
were surveyed and that 69 percent of these jurisdictions reported great 
or very great improvement in reading instruction since the inception of 
Reading First. One of the key factors behind this reported improvement 
is the incorporation of the five integral components of reading - 
phonemic awareness, phonics, vocabulary development, reading fluency, 
and reading comprehension - into the curriculum. Furthermore, a number 
of State and local officials indicated that the uses of assessments 
changed after Reading First began, especially in the way that teachers 
use data from assessments to inform reading instruction. In addition, 
all of the States reported improvements in professional development, 
with more than 80 percent reporting that professional development for 
reading teachers improved greatly or very greatly. 

Your report also demonstrates that States were satisfied with the forms 
of guidance and technical assistance they received during the 
application and implementation process for the Reading First program. 
In addition, nearly every State reported that the Departmental staff 
and technical assistance centers were helpful or very helpful in 
addressing the States' implementation issues. 

As your report notes, the Department's Office of Inspector General 
(OIG) found, in a recent Inspection Report, that there were some 
serious problems in the Department's initial implementation of the 
Reading First statute. Although the Department did not agree with all 
of the OIG's findings, the Department has acted quickly to implement 
the specific recommendations in the OIG report. Enclosed with this 
letter is a chart that details the actions that the Department has 
taken in response to the Inspection Report. 

Your draft report contains two specific recommendations that complement 
the recommendations in the OIG's Inspection Report. The GAO 
recommendations, and our responses, are as follows: 

GAO Recommendation 1. In addition to addressing the IG's 
recommendations to develop internal (1) policies and procedures to 
guide program managers on when to solicit advice from General Counsel 
and (2) guidance on prohibitions imposed by section 3403(b) of the 
DEOA, we recommend that, in order to ensure that the department 
complies with statutory prohibitions against directing, mandating or 
endorsing state and local curricular decisions, the Secretary of 
Education also establish control procedures to guide departmental 
officials and contractors in their interactions with states, districts, 
and schools. 

Department's Response. The Department agrees with this recommendation. 
We will provide written guidance in the near future to all Departmental 
staff reminding them of the importance of impartiality in the 
performance of their duties and of not construing program statutes to 
authorize the Department to mandate, direct, or control curriculum and 
instruction, except to the extent authorized by law. Integrity, 
objectivity, and professionalism are critical to ensuring effective 
program operations and maintaining the public's confidence in our 
operation of the Department's programs. 

We will also require all Department staff to have annual training on 
the standards for internal controls, similar to existing annual 
training requirements for ethics and for computer security, so that our 
systems, processes, and behaviors provide strengthened assurance of 
professional responsibility and full compliance with laws and 
regulations, as well as effective and efficient operations. The 
training will address provisions relating to curriculum and 
instruction, and will incorporate the following general standards for 
internal controls, each of which applies to the programmatic, 
compliance, and financial aspects of the Department's operations -: 

* Establishing and maintaining a "control environment" that sets a 
positive and supportive attitude toward internal control and 
conscientious management; 

* Using risk assessment from both external and internal sources; 

* Employing proper control activities to help ensure that management 
directives are implemented; 

* Providing information and fostering communication that is relevant, 
reliable, and timely; and: 

* Employing effective monitoring techniques at all levels to assess the 
quality of performance over time. 

GAO Recommendation 2. In addition, to help the department conduct 
effective monitoring of the Reading First program, we recommend that 
the Secretary of Education establish and disseminate clear procedures 
governing the Reading First monitoring process. In particular, 
Education should delineate states' rights and responsibilities and 
establish timelines and procedures for addressing findings. 

Department's Response. The Department agrees with this recommendation. 
We have initiated discussions of monitoring issues at a recent meeting 
with State Reading First Directors and staff from American Institutes 
for Research (AIR), the contractor that conducts monitoring of Reading 
First for the Department. The Department will be developing and 
disseminating guidelines on the goals and purposes of State and 
district monitoring, revising the monitoring protocols, and developing 
timelines and procedures on States' rights and responsibilities for 
addressing monitoring findings. We will better coordinate our 
activities with States so that their responsibilities to monitor local 
Reading First implementation are reinforced by Departmental monitoring. 
A second meeting to implement these actions in coordination with 
States, AIR, and the Reading First technical assistance contractor is 
planned for early May 2007. 

We appreciate the opportunity to provide our comments and to describe 
our actions and plans. Please let me know if you need additional 
information regarding the implementation or administration of the 
Reading First program. 

Sincerely, 

Signed by: 

Raymond Simon: 

Enclosure: 

Status Report On Actions Taken To Respond To OIG Inspection Report On 
Reading First's Grant Application Process: 

February 7, 2007: 

[See PDF for slides from Department of Education] 

[End of section] 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

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

Acknowledgments: 

Bryon Gordon, Assistant Director, and Tiffany Boiman, Analyst-in- 
Charge, managed this engagement and made significant contributions to 
all aspects of this report. Sonya Phillips, Sheranda Campbell, Janice 
Ceperich, and Andrew Huddleston also made significant contributions. 
Jean McSween provided methodological expertise and assistance. Sheila 
McCoy and Richard Burkard delivered legal counsel and analysis. 
Susannah Compton, Charlie Willson, and Scott Heacock assisted with 
message and report development. 

FOOTNOTES 

[1] 20 U.S.C. § 7907. 

[2] U.S. Department of Education Inspector General, The Reading First 
Program's Grant Application Process: Final Inspection Report 
(Washington D.C.: September 2006). 

[3] Section 103(b) of the Department of Education Organizing Act (DEOA) 
states that "No provision of a program administered by the Secretary or 
by any other officer of the Department shall be construed to authorize 
the Secretary or any such officer to exercise any direction, 
supervision, or control over the curriculum, program of instruction, 
administration, or personnel of any educational institution, school or 
school system….over the selection or content of…textbooks, or other 
instructional materials by any educational institution or school 
system, except to the extent authorized by law." 20 U.S.C. § 3403(b). 

[4] The Reading First Program Director resigned following publication 
of the Final Inspection Report. 

[5] These components were identified as integral parts of effective 
reading programs by the National Reading Panel, or NRP. Phonemic 
awareness refers to the ability to hear, identify, and manipulate the 
individual sounds--phonemes--in spoken words. Phonics refers to the 
relationship between the letters of written language and the sounds of 
spoken words. Vocabulary development refers to the development of 
stored information about the meanings and pronunciations of words 
necessary for communication. Reading fluency refers to the ability to 
read text accurately and quickly. It provides a bridge between word 
recognition and comprehension. Reading comprehension refers to the 
understanding, remembering, and communicating with others about what 
has been read. 

[6] 20 U.S.C. § 7907. 

[7] 20 U.S.C. § 3403. 

[8] Data collected must be valid and reliable to be considered 
accurate. Valid refers to the degree that it actually measures what it 
claims to measure. Reliable refers to the degree to which it 
consistently measures what it claims to measure. 

[9] From this 20 percent, states may spend up to 65 percent on 
professional development, up to 25 percent for technical assistance for 
districts and schools, and up to 10 percent for planning, 
administration, and reporting activities. 

[10] Empowerment zones and enterprise zones are defined in 26 U.S.C. § 
1392. Both are local areas of high poverty that meet certain 
eligibility requirements to receive specified forms of aid or 
regulatory flexibility. 

[11] Under NCLBA, each state creates its own content standards, 
academic achievement tests, and proficiency levels. States are required 
to test all children for reading and mathematics achievement annually 
in grades 3-8 to determine whether schools are making adequate yearly 
progress (AYP). Districts must identify as a school in need of 
improvement any school that has not made AYP for 2 consecutive years. 

[12] Title I of Elementary and Secondary Education Act, as amended and 
reauthorized by NCLBA, authorizes federal funds to help elementary and 
secondary schools establish and maintain programs that will improve the 
educational opportunities of economically disadvantaged children. Title 
I is the largest federal program supporting education in kindergarten 
through 12th grade. 

[13] Education has contracted with an independent research firm to 
conduct a 5-year, quantitative evaluation of the Reading First program, 
evaluating the effect of Reading First activities on improving reading 
instruction. In addition, in their annual reports and mid-point 
evaluations, states must include their progress in reducing the number 
of students in grades K-3 reading below grade level. 

[14] The five key components of reading include (1) phonemic awareness; 
(2) phonics; (3) vocabulary development; (4) reading fluency, including 
oral reading skills; and (5) reading comprehension strategies. 

[15] For the purposes of this report, the term "states" also includes 
the District of Columbia. 

[16] Education's "Reading First Implementation Evaluation: Interim 
Report." 

[17] The types of assessments are screening, diagnostic, and progress 
monitoring. See appendix II for more complete descriptions of each. 

[18] The Consumer's Guide to Evaluating A Core Reading Program Grades K-
3: A Critical Elements Analysis, or Consumer's Guide, describes the 
core reading program concept in the following way: "A core reading 
program is the primary instructional tool that teachers use to teach 
children to learn to read and ensure they reach reading levels that 
meet or exceed grade-level standards. The core program. . . should 
serve as the primary reading program for the school and the expectation 
is that all teachers within and between the primary grades will use the 
core reading program as the base of reading instruction. Such programs 
may or may not be commercial reading series." 

[19] Deborah C. Simmons and Edward Kame'enui. A Consumer's Guide to 
Evaluating A Core Reading Program Grades K-3: A Critical Elements 
Analysis (University of Oregon: March 2003). Hyperlink, 
http://reading.uoregon.edu/curricula/con_guide.php 

[20] Education officials sponsored three Reading Leadership Academies 
in the early part of 2002. The Academies were forums for state 
education officials to obtain information and build their capacity to 
implement key aspects of the Reading First program, including reliance 
on SBRR and professional development. 

[21] The first school year of funding varied across states. Twenty-five 
states received their first year of funding in the 2002-2003 school 
year. Twenty-five states received their first year of funding in the 
2003-2004 school year. 

[22] Two states were excluded from our analysis because of data 
inconsistencies. See appendix I for additional information about 
methodology. 

[23] The total number of states does not add to 51 because 1 state 
reported that its district eligibility included both a percentage 
figure as well as the number of schools. 

[24] The No Child Left Behind Act of 2001 added two new reading 
programs to the Elementary and Secondary Education Act, Reading First 
and Early Reading First. Early Reading First provides support to local 
efforts to enhance the early language, literacy, and pre-reading 
development of preschool-age children, particularly those from low- 
income families, through strategies and professional development that 
are based on scientifically based reading research. 

[25] States develop their own performance thresholds for districts to 
meet and develop policies for how to handle those districts with 
results that are below these thresholds. When monitoring participating 
districts, states must determine whether funding should continue or 
whether districts should be dropped from the program. Sixteen states 
reported dropping at least one district that was initially awarded a 
sub-grant. There were a variety of reasons that a state dropped a 
district, including districts not showing progress, non-compliance with 
state requirements, or a shift in reading philosophy. 

[26] 31 U.S.C. § 3512 (c) and (d). 

[27] For more information, see GAO's Standards for Internal Control in 
the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 
1999), P.L. 97-255 and 31 USC 1105, 1113, and 3512. 

[28] Department of Education, Office of the Inspector General, The 
Reading First Program's Grant Application Process: Final Inspection 
Report (Washington, D.C.: September 2006). 

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