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United States Government Accountability Office:
GAO:
Report to the Chairman, Committee on Health, Education, Labor, and
Pensions, U.S. Senate:
January 2011:
Elementary and Secondary Education Act:
Potential Effects of Changing Comparability Requirements:
GAO-11-258:
Contents:
Letter:
Agency Comments and Our Evaluation:
Appendix I: Briefing Slides:
Appendix II: GAO Contact and Staff Acknowledgments:
Abbreviations:
CCD: Common Core of Data:
Education: U.S. Department of Education:
ESEA: Elementary and Secondary Education Act of 1965:
NCES: National Center for Education Statistics:
OIG: Office of Inspector General:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
January 28, 2011:
The Honorable Tom Harkin:
Chairman:
Committee on Health, Education, Labor, and Pensions:
United States Senate:
Dear Chairman Harkin:
For fiscal year 2010, Congress appropriated $14.5 billion for Title I,
Part A of the Elementary and Secondary Education Act of 1965 (ESEA),
which funds services to students in schools with high concentrations
of students from low-income families. Title I, Part A includes several
fiscal requirements, which are designed to prevent local school
districts from using federal dollars to replace state and local
education funding. One of these measures, Title I comparability,
requires districts to provide services with state and local funds to
Title I schools that are at least comparable to services provided in
schools not served by Title I.[Footnote 1] State educational agencies
monitor district compliance with Title I comparability requirements.
Districts may comply with comparability requirements through one of
several measures. Under Title I, districts are deemed to be in
compliance with comparability requirements if they have established
and implemented a districtwide salary schedule; a policy to ensure
equivalence among schools in teachers, administrators, and other
staff; and a policy to ensure equivalence among schools in the
provision of curriculum materials and instructional supplies. Guidance
from the U.S. Department of Education (Education) also allows
districts to comply with requirements through several other measures,
including student-teacher ratios (referred to in guidance as student-
to-instructional-staff ratios) and expenditures per pupil. Under Title
I, districts are precluded from including staff salary differentials
for years of employment in determining comparability. Thus, actual
teacher salaries may not be used in comparability calculations.
An Education analysis of a nationally representative sample of school
districts did not find a significant difference between Title I and
non-Title I schools in state and local expenditures on personnel for
the 2004-2005 school year.[Footnote 2] However, this study did not
attempt to evaluate whether expenditures at Title I and non-Title I
schools within the same district were different. Some other research
shows that teachers at Title I schools in some districts have fewer
years of experience and lower average salaries than teachers at non-
Title I schools in the same district.[Footnote 3] As a result, Title I
schools in these districts may receive less state and local funding
per pupil than non-Title I schools.
A bill was introduced in the prior session of Congress to require
districts to demonstrate comparability using an expenditure-per-pupil
measure that includes actual teacher salaries.[Footnote 4] Advocates
believe that this kind of requirement would help eliminate any funding
discrepancies between Title I and non-Title I schools due to lower
teacher salaries at Title I schools and improve educational outcomes
at Title I schools.
Based on your request, this report addresses the following questions:
* Which of the methods for demonstrating comparability are used by
school districts in selected states and how does the chosen method
affect resource allocation in selected school districts?
* What have been Education's monitoring and audit findings for
comparability?
* What might be the benefits and drawbacks of requiring school
districts to use an expenditure-per-student ratio that includes actual
teacher salaries to demonstrate compliance with comparability
requirements?
To identify methods districts use to demonstrate comparability and
assess potential benefits and drawbacks of changing comparability
requirements, we selected a nongeneralizable sample of three states
(California, Ohio, and North Carolina) using criteria including
geographical dispersion, diversity of school districts, and
availability of data on district methods of determining comparability.
In each state, we interviewed state education officials and reviewed
school district comparability data for the 2009-2010 school year. We
determined that these data were sufficiently reliable for our
purposes. We also selected a nongeneralizable sample of three school
districts in each state using criteria including district size,
whether the district was urban or rural, and the method used to
demonstrate comparability. We interviewed district officials and, in
some cases, local teachers' union officials as well. The findings for
these three states and nine districts cannot be projected nationwide,
but we believe they illustrate valuable perspectives on Title I
comparability. Lastly, to summarize Education findings related to
comparability, we reviewed 2009-2010 Education Title I monitoring
reports and relevant Inspector General audits for comparability
findings, and reviewed relevant federal laws and regulations.
We conducted this performance audit from November 2010 to January 2011
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
On December 17, 2010, we briefed bipartisan committee staff on the
results of this study, and this report formally conveys the
information provided during this briefing (see appendix I for the
briefing slides). In summary, we found that: 1) Districts in selected
states commonly demonstrate comparability using student-teacher
ratios, but factors other than comparability may drive their resource-
allocation decisions; 2) Education has found weaknesses in state
oversight of district compliance with comparability requirements; and
3) Potential changes in comparability requirements could increase
funding to some Title I schools, but may be challenging for some
districts to implement. Some district and union officials we
interviewed supported providing additional funds to Title I schools,
but some also noted potential challenges and budgetary implications of
complying with revised requirements, including transferring teachers
and negotiating changes to union contracts. For example, Oakland
Unified School District currently distributes state and local funds to
schools to ensure comparable per-pupil funding, but some schools have
had difficulty balancing their budgets.
Agency Comments and Our Evaluation:
We provided a draft copy of this report to Education for review and
comment. Education did not have any comments on the report.
As agreed with your office, unless you publicly announce the contents
of the report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to relevant congressional committees, the Secretary of Education, and
other interested parties. In addition, this report will be available
at no charge on GAO's Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to
this report are listed in appendix II.
Sincerely yours,
Signed by:
George A. Scott:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Briefing Slides:
Elementary and Secondary Education Act:
Potential Effects of Changing Comparability Requirements:
Briefing to Committee on Health, Education, Labor, and Pensions:
United States Senate:
December, 2010:
Overview:
* Introduction;
* Research Objectives;
* Scope and Methodology;
* Summary of Findings;
* Background;
* Findings;
* Conclusions.
Introduction:
School Districts Received $14.5 Billion in Title I, Part A Funds for
Disadvantaged Students in 2010:
For fiscal year 2010, Congress appropriated $14.5 billion for Title I,
Part A of the Elementary and Secondary Education Act of 1965 (ESEA),
which funds services to students in schools with high concentrations
of students from low-income families.
Title I, Part A fiscal-accountability measures are designed to prevent
local school districts from using federal dollars to replace state and
local education funding.
Maintenance of Effort: Districts must maintain spending at 90 percent
or more of their previous year's state and local education
expenditures.
Supplement-not-Supplant: Districts must use Title I funds to
supplement, and not supplant, nonfederal funds that would otherwise be
available for students assisted by Title I.
Comparability: Districts must provide services with state and local
funds to Title I schools that are comparable to services in schools
not served by Title 1.[Footnote 5]
[End of section]
Research Objectives:
1. Which of the methods for demonstrating comparability are used by
school districts in selected states and how does the chosen method
affect resource allocation in selected school districts?
2. What have been U.S. Department of Education's (Education)
monitoring and audit findings for comparability?
3. What might be the benefits and drawbacks of requiring school
districts to use an expenditure-per-student ratio that includes actual
teacher salaries to demonstrate compliance with comparability
requirements?
[End of section]
Scope and Methodology:
We selected three states (California, Ohio, North Carolina) using
criteria including:
* geographical dispersion;
* diversity of school districts;
* availability of data.
We interviewed state educational agency officials in each state.
We also reviewed school district comparability data for the 2009-2010
school year, and determined that these data were sufficiently reliable
for our purposes.
In each state we selected three school districts using criteria
including: {3 California districts, 3 Ohio districts, 3 North Carolina
districts)
* urban or rural location;
* comparability method used;
* size.
We interviewed district officials and, in some cases, local teachers'
union officials as well.
Education 2009-2010 Title I monitoring reports:
* We reviewed these reports for comparability findings.
Education's Office of Inspector General (01G) audits:
* We reviewed audits of comparability compliance.
We also reviewed relevant federal laws and regulations.
We conducted our work from November 2010 to January 2011 in accordance
with generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings
based on our audit objectives.
[End of section]
Summary of Findings:
Potential Changes in Comparability Requirements Could Increase Funding
to Some Title I Schools, But May Be Challenging for Some Districts to
Implement:
Districts in selected states commonly demonstrate comparability using
student-teacher ratios, but factors other than comparability may drive
their resource-allocation decisions.
Education has found weaknesses in state oversight of district
compliance with comparability requirements.
Potential changes in comparability requirements could increase funding
to some Title I schools, but may be challenging for some districts to
implement.
[End of section]
Background:
Districts Currently Have Several Options to Demonstrate Comparability:
Under Title I, a district is deemed to be in compliance with
comparability requirements if it has established and implemented:
* (1) A districtwide salary schedule; (2) a policy to ensure
equivalence among schools in teachers, administrators, and other
staff; and (3 a policy to ensure equivalence among schools in the
provision of curriculum materials and instructional supplies.
Education guidance also allows districts to comply with requirements
through several other measures, including:
* Student-teacher ratios (referred to in guidance as student-to-
instructional-staff ratios), and;
* Expenditures per pupil.[Footnote 6]
Actual Teacher Salaries Cannot Be Included in Comparability
Calculations:
Under Title I, a district is precluded from including staff salary
differentials for years of employment in determining comparability.
[Footnote 7]
* Thus, actual teacher salaries may not be used in comparability
calculations.
In comparing Title I schools to non-Title I schools:
* Districts may group schools by size and grade span.
* Districts may exclude schools with less than 100 students.
A district with only Title I schools must demonstrate that those
schools are substantially comparable to each other.
States Monitor District Compliance with Comparability Requirements:
State educational agencies monitor district compliance and may:
* Specify the comparability methods districts should use, and;
* Establish whether all instructional staff or classroom teachers only
may be included in comparability calculations.
Education requires that state educational agencies review districts'
comparability calculations at least once every two years.[Footnote 8]
* Districts must perform comparability calculations each year.
While National Data Show Similar Personnel Expenditures for Title I
and non-Title I Schools, Some Districts May Spend Less on Teachers in
Title I Schools:
An Education analysis of a nationally representative sample of school
districts did not find a significant difference between Title I and
non-Title I schools in state and local expenditures on personnel for
the 2004-2005 school year.[Footnote 9]
* This study did not attempt to evaluate whether expenditures at Title
I and non-Title I schools within the same district were different.
Some research shows that teachers at Title I schools in some districts
have fewer years of experience and lower average salaries than
teachers at non-Title I schools.[Footnote 10]
* Title I schools in these districts may receive less state and local
funding per pupil than non-Title I schools as a result.
Advocates Believe Requiring Comparable Expenditures Per Pupil Could
Improve Outcomes at Title I Schools:
A bill was introduced in the 111th Congress to require districts to
demonstrate comparability using an expenditure-per-pupil measure that
includes actual teacher salaries.[Footnote 11]
Advocates believe that this kind of requirement would help:
* Eliminate any funding discrepancies between Title I and non-Title I
schools within the same district due to lower teacher salaries at
Title I schools.
* Improve educational outcomes at Title I schools.
[End of section]
Finding 1: Current Methods:
Districts in Selected States Commonly Demonstrate Comparability Using
Student-Teacher Ratios, but Factors Other than Comparability May Drive
their Resource Allocation Decisions:
80 percent or more of districts in each of the three states we
selected use student-teacher ratios to demonstrate comparability.
Most of the nine selected districts allocate resources to achieve
target class sizes, but factors other than comparability may drive
these decisions.
Officials from selected districts do not believe it is difficult to
comply with current comparability requirements.
80 Percent Or More of Districts in Selected States Use Student-Teacher
Ratios to Demonstrate Comparability:
Between 80 and 97 percent of districts in selected states that
reported data for the 2009-2010 school year used student-teacher
ratios.
* Ohio recommends student-teacher ratios for ease of calculation and
verification.
* California and North Carolina do not recommend a particular method,
but California provides extra support to encourage usage of student-
teacher ratios.
Figure 1: Methods Used By Districts in Selected States to Demonstrate
Comparability, 2009-2010:
[Refer to PDF for image: horizontal bar graph]
State: California;
Expenditures per pupil: 1%;
Other method: 3%;
Student-teacher ratio: 97%.
State: Ohio;
Expenditures per pupil: 8%;
Other method: 1%;
Student-teacher ratio: 91%.
State: North Carolina;
Expenditures per pupil: 19%;
Other method: 1%;
Student-teacher ratio: 80%.
Source: GAO analysis of district data.
Note: Twelve school districts in Ohio and California demonstrated
comparability using student-teacher ratios along with another method.
To avoid double counting, we categorized these districts as using
student-teacher ratios for the purposes of our analysis.
[End of figure]
Selected Districts Allocate Resources to Achieve Target Class Sizes,
But Comparability May Not Drive Decisions:
Most selected districts use student-teacher ratios to demonstrate
comparability and allocate teachers to achieve target class sizes as a
normal part of their annual budget process.
However, most officials said that factors other than comparability
requirements drive their decisions to allocate teachers to achieve
target class sizes. These factors include:
* Union contract requirements;
* State guidance;
* District goals.
Officials in Selected Districts Do Not Believe it is Difficult to
Comply With Current Comparability Requirements:
District officials said they do not generally have problems complying
with comparability requirements.
Three districts found compliance problems during initial comparability
calculations in recent years. In response:
* One reallocated $500 to one school.
* One funded additional instructional positions at two schools.
* One filled vacant positions at multiple schools.
State officials we interviewed said districts rarely report compliance
problems.
* Two states said most issues can be resolved by altering the method
of calculating comparability rather than reallocating resources.
Finding 2: Education Monitoring:
Education Has Found Weaknesses in State Oversight of Comparability
Requirements:
In 2009-2010, Education found weaknesses in state oversight of Title I
comparability requirements in 7 of the 13 states it monitored.
Specifically, it found:
* 7 states had gaps in their oversight.
* 2 states allowed noncompliant school districts to receive Title I
funds.
Education's OIG found inadequate state monitoring and district
noncompliance in all three state comparability audits it conducted
between 2003 and 2006.
Education Found Gaps in State Oversight of District Comparability
Compliance:
7 out of 13 states monitored by Education in 2009-2010 were found to
have gaps in oversight:
* 2 failed to verify district supporting data.
* 2 failed to ensure that districts properly grouped schools when
making comparability comparisons.
* 2 monitored compliance every 5 years, rather than every 2 years as
required.
* 1 provided incorrect guidance to districts.
For 4 of the 7 states, the problems had been identified in prior
monitoring reports.
Education Found that Some Districts Improperly Received Title I Funds:
Two states allowed districts to receive Title I funding without
demonstrating comparability, as required by law.
* One state inappropriately waived comparability requirements for a
large school district.
* Another state distributed Title I funds to a large school district
that told the state it could not afford to provide additional funds to
Title I schools whose services were not comparable to those at non-
Title I schools.
IG Audits Identified Inadequate Monitoring and District Noncompliance:
Education's OIG conducted three state comparability audits between
2003 and 2006, and found that:
* All three states had inadequate monitoring practices.
* Seven of the nine districts reviewed in these states used inaccurate
or unsupported data to determine comparability.
The OIG recommended that all three states improve monitoring to ensure
district compliance with comparability requirements.
Finding 3: Benefits and Drawbacks:
Potential Changes in Comparability Requirements Could Increase Funding
to Some Title I Schools, But May Be Challenging for Some Districts to
Implement:
Some Title I schools could receive additional state and local funding
if districts are required to ensure comparable per-pupil expenditures
including actual teacher salaries.
Some district and union officials we interviewed supported providing
additional funds to Title I schools, but some also noted potential
challenges including:
* Transferring teachers.
* Negotiating union contract changes.
Oakland Unified School District currently distributes state and local
funds to schools to ensure comparable per-pupil funding, but some
schools have had difficulty balancing their budgets.
Potential Changes in Comparability Requirements Could Benefit Title I
Schools:
Additional state and local funds may benefit Title I schools with low
per-pupil costs in various ways.
* In Oakland, some schools that received funding increases have
reduced class sizes or introduced additional educational supports.
* In another selected district, officials discussed extending
instructional hours at Title I schools.
However, changes in comparability requirements may not result in funds
being reallocated to Title I schools in all districts.
* Officials in some selected districts believed they would be in
compliance currently without reallocating resources.
Districts May Need to Transfer Higher-Salaried Teachers to Achieve
Comparability:
Officials from some districts believed they would need to transfer
higher-salaried teachers out of schools with high per-pupil
expenditures to comply with revised comparability requirements.
Teacher salaries and benefits make up the large majority of schools'
instructional expenditures.
* Nationally, 90 percent of average 2006-2007 instructional expenses
were for salaries and benefits, while 5 percent were for supplies.
[Footnote 12]
Therefore, transferring high-salaried teachers into schools with low
per-pupil expenditures may be an effective way for some districts to
ensure comparability if requirements are changed.[Footnote 13]
Districts May Need to Negotiate Changes to Union Contracts to
Reallocate Resources:
Some union and district officials said that if teacher transfers
were needed to achieve comparability:
* Seniority rights may prevent districts from compelling more
experienced teachers to transfer schools.
* Districts may not be able to use incentive pay as a tool to
encourage voluntary transfers due to union opposition.
Additionally, some district officials said they would need to
work with unions to undertake other actions. For instance:
* Officials from one district said they would need to work with their
union to reduce class sizes in Title I schools.
* Officials in another district said that in the past teachers had to
vote in favor of extending instructional hours.
Teacher Transfers May Harm Teacher Morale and Union Relationships:
California district and union officials were concerned about the
possible effects of involuntary transfers on teacher morale and union
relations.
* These officials cited other challenges currently facing teachers,
particularly budget cuts.
North Carolina and Ohio district officials were also concerned about
the potential for transfers to disrupt rural communities. They
mentioned cases where:
* there are long distances between schools, and;
* the majority of staff grew up in the community and attended the
school where they now work.
Requiring Comparable Per-Pupil Expenditures May Not Improve
Educational Quality:
District officials in all three selected states were concerned that
requiring comparable per-pupil expenditures may not improve
educational quality.
District officials said moving high-cost experienced teachers to high-
poverty schools may not improve education in all cases, such as if:
* Younger teachers are better suited to handle challenges of a high-
poverty school.
* Experienced teachers are highly effective in their current schools,
but may not succeed elsewhere.
Officials from one North Carolina district noted that all of its Title
I schools made adequate yearly progress last year and questioned the
purpose of requiring it to reallocate resources.
Some Districts May Need to Reallocate Resources Among Title I Schools:
Reallocating resources within districts could follow two patterns:
* Non-Title I school to Title I school;
* Title I school to Title I school.[Footnote 14]
Officials in one district where all elementary schools received Title
I funds said some of the district's Title I schools would not be
comparable with others if comparability requirements were changed.
* Officials from this district believed they would need to transfer
teachers among their Title I schools to achieve comparability.
State and Local Class-Size Goals May Make Reallocating Resources More
Challenging:
All selected districts allocate teachers to achieve consistent class
sizes for reasons including:
* State guidance;
* Union contract requirements;
* Local priorities.
Ensuring that all schools have both equal class sizes and comparable
per-pupil expenditures may be challenging.
Selected Districts Generally Have Capacity to Report Per-Pupil
Expenditure Data:
Officials from most of the nine districts we spoke with said they have
the technical capacity to report per-pupil expenditures. However:
* Some district officials said it would be time consuming.
* California officials said districts frequently do not code
expenditures to specific schools.
* Ohio officials said the state would need to develop new mechanisms
to collect school-level salary and other expenditure data.
Nationally, Some Districts Could Face Challenges Reporting Per-Pupil
Expenditure Data:
Education officials said all states reported school-level expenditure
data in response to Recovery Act requirements.[Footnote 15] However,
they noted that:
* Most districts' data systems currently do not track expenditures at
the school level.
* Districts may have difficulty tracking expenditures of state and
local funds separately from expenditures of federal funds.
* Districts had difficulty reporting school-level expenditures for
nonpersonnel resources, such as professional development, which may be
accounted for in a centralized manner.
Case Study: Oakland Implemented a Per-Pupil Funding Model as a Part of
Wider Reforms:
In the 2004-2005 school year, Oakland Unified School District began
distributing state and local funds to schools using a per-pupil
formula as a part of a wider reform effort aimed at instituting:
* Smaller schools;
* Site-based decision making.
School principals were given control over their budgets.
Oakland officials said this funding formula was implemented in
response to perceived inequity, with high-poverty schools receiving
less state and local funds than low-poverty schools due to lower
teacher salaries.[Footnote 16]
Case Study: Oakland Schools with Low Per-Pupil Expenses Have Received
Extra Funding:
Under Oakland's new funding formula, schools with below average per-
pupil costs have received additional funding.
High-poverty schools have benefited in particular. According to an
American Institutes for Research study, between the 2002-2003 and 2006-
2007 school years, total per-pupil expenditures (including federal
funds) increased by:[Footnote 17]
* 24 percent (from $5,200 to $6,400) at high-poverty elementary
schools, vs.
* 4 percent (from $5,600 to $5,800) at low-poverty elementary schools.
Officials said some of these schools have used funds to:
* Reduce class sizes;
* Add intervention services;
* Extend instructional hours;
* Introduce parent supports.
Case Study: Oakland Schools with High Per-Pupil Expenses Have Faced
Budget Cuts:
Under Oakland's new funding formula, schools with high per-pupil
expenses have faced budget cuts. These schools include:
* Schools with high-salaried teachers (both low- and high-poverty);
* Small schools with high fixed administrative costs.
According to district officials and principals:
* Some schools with high-salaried teachers do not have funds for
administrative staff and nonclassroom teachers.
* Small schools with high fixed costs have had serious difficulty
balancing their budgets.
* Low-poverty schools with high-salaried teachers have avoided cutting
costs by raising funds through parent-teacher associations.
Case Study: Oakland Redistributes Funds to Help Some Schools Balance
Their Budgets:
Oakland provided subsidies to small schools and schools with
relatively high teacher salaries.
* The district planned to phase out subsidies after 3 years, but
officials said some schools were still unable to balance budgets.
[Footnote 18]
District officials said they currently work with schools facing budget
shortfalls to cut expenses by taking steps including:
* Consolidating classrooms.
* Cutting administrative positions.
Officials said the district still had to redistribute $1.8 million in
2010-2011 to fund necessary educational services at schools with
budget shortfalls.
[End of section]
Conclusions:
Potential Changes in Comparability Requirements May Have Unintended
Consequences:
While one goal of potential changes to comparability requirements may
be to improve educational quality in Title I schools, new
comparability requirements could have other consequences.
School districts may:
* Face challenges in reallocating resources.
* Lack technical capacity to track school-level expenditures.
States and Education may face:
* Increased district noncompliance.
* Enforcement challenges due to difficulty verifying complex financial
data.
[End of section]
On the Web:
Web site: [hyperlink, http://www.gao.gov].
Contact:
Chuck Young, Managing Director, Public Affairs:
youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C., 20548:
Copyright:
This is a work of the U.S. government and is not subject to copyright
protection in the United States. The published product may be
reproduced and distributed in its entirety without further permission
from GAO. However, because this work may contain copyrighted images or
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if you wish to reproduce this material separately.
[End of briefing slides]
Appendix II: GAO Contact and Staff Acknowledgments:
GAO Contact:
George A. Scott, (202) 512-7215 or scottg@gao.gov:
Staff Acknowledgments:
The following staff members made key contributions to this report,
Cornelia Ashby, Director; Bryon Gordon, Assistant Director; Ellen
Phelps Ranen, Analyst-in-Charge; James Bennett; Sue Bernstein; Robert
Campbell; Jean McSween; Jim Rebbe; and Jill Yost.
[End of section]
Footnotes:
[1] 20 U.S.C. § 6321(c)(1)(A).
[2] See U.S. Department of Education, Office of Planning, Evaluation,
and Policy Development, Policy and Program Studies Service, State and
Local Implementation of the No Child Left Behind Act, Volume VI--
Targeting and Uses of Federal Education Funds, (Washington, D.C.,
2009).
[3] See, for example, Marguerite Roza and Paul T. Hill, How Within-
District Spending Inequities Help Some Schools Fail, Brookings
Institution, (Washington, D.C., 2004), 201-228.
[4] ESEA Fiscal Fairness Act, H.R. 5071, 111th Cong. (2010).
[5] 20 U.S.C. § 6321(c)(1)(A).
[6] Other measures include student-to-instructional-staff salary
ratios and a resource-allocation plan based on student characteristics
such as poverty, limited English proficiency, or disability.
[7] 20 U.S.C. § 6321 (c)(2)(B).
[8] Of our three selected states, California and Ohio require Title I
school districts to submit comparability reports to the state every
other year, while North Carolina requires comparability reports from
all of its Title I districts every year.
[9] See U.S. Department of Education, Office of Planning, Evaluation,
and Policy Development, State and Local Implementation of the No Child
Left Behind Act, Volume VI-—Targeting and Uses of Federal Education
Funds (Washington, D.C., 2009).
[10] See, for example, Marguerite Roza and Paul T. Hill, How Within-
District Spending Inequities Help Some Schools Fail, Brookings
Institution, (Washington, D.C., 2004), 201-228.
[11] ESEA Fiscal Fairness Act, H.R. 5071, 111th Cong. (2010). This
bill has not been introduced in the 112th Congress.
[12] See U.S. Department of Education, National Center for Education
Statistics (NCES), Common Core of Data (CCD), National Public
Education Financial Survey, 2005-2006 and 2006-2007.
[13] Under legislation proposed in the 111th Congress, school
districts would be able to include salary costs for non-instructional
administrative staff in comparability calculations. Thus, they could
possibly reallocate administrative resources to achieve comparability.
(See H.R. 5071, 111th Cong. (2010)). According to NCES data, in 2006-
2007, school districts spent $1 on school administration for every $10
spent on instructional salaries and benefits. See National Public
Education Financial Survey, 2005-2006 and 2006-2007.
[14] In districts where all schools receive Title I funds, the
district must show that the services in each school are comparable.
[15] Pub. L. No. 111-5, § 1512, 123 Stat. 115, 287 (2009).
[16] This funding formula does not include weights for student need.
[17] See Jay Chambers, Jesse Levin, Man Muraki, Lindsay Poland, and
Larisa Shambaugh, A Tale of Two Districts: A Comparative Study of
Student-Based Funding and School-Based Decision Making in San
Francisco and Oakland Unified School Districts (Washington, D.C.,
October 2008).
[18] According to the American Institutes for Research study, in 2004-
2005 Oakland distributed $9.9 million in subsidies, or $500-$600 per
student, to 44 schools. By 2006-2007, total subsidies had declined to
under $1 million. Small-school subsidies of $5.3 million were
distributed to 83 schools in 2006-2007. See Chambers et al., A Tale of
Two Districts.
[End of section]
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