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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

March 2011: 

Education Of Military Dependent Students: 

Better Information Needed to Assess Student Performance: 

GAO-11-231: 

GAO Highlights: 

Highlights of GAO-11-231, a report to congressional committees. 

Why GAO Did This Study: 

Since the early 1990s, Congress has supplemented the Department of 
Education’s (Education) Impact Aid program by providing funds for the 
Department of Defense’s (DOD) Impact Aid program to compensate school 
districts with a high number of military dependent students. The 
National Defense Authorization Act for Fiscal Year 2010 required GAO 
to review the use of these funds. GAO reviewed (1) what is known about 
the utilization and effectiveness of DOD Impact Aid funds, (2) the 
challenges faced by school districts in serving military dependent 
students, and (3) how DOD and Education have collaborated on their 
assistance. To address these issues, GAO conducted a Web-based survey 
of all 154 school districts that received DOD Impact Aid in any year 
from 2001 to 2009, with a response rate of 77 percent. GAO also 
interviewed officials from DOD and Education and seven school 
districts in five states, ranging in school district size, location, 
and percentage of military dependent students. The findings from these 
visits cannot be projected nationwide, but illustrate valuable 
perspectives. 

What GAO Found: 

DOD Impact Aid has three distinct funding components, with more than 
three quarters of the funds provided through the DOD Impact Aid 
Supplemental program. Eighty five percent of the 87 responding school 
districts that received funds for the 2009–2010 school year reported 
placing these funds into their general fund to use for overall 
maintenance and operations. (See figure below.) Because there are no 
reporting requirements on districts’ use of the funding, it is 
difficult to assess how the funds are used and to what extent military 
dependent students benefit. Further, there are no data available on 
these students that could be used to assess their academic achievement 
or educational outcomes, or determine where funding needs are 
greatest. Such reporting requirements exist for certain other groups 
of students, such as economically disadvantaged students and students 
with disabilities. Federal agency officials acknowledged this need for 
information, and Education has begun discussing how to address this 
need. 

School districts GAO contacted reported that issues related to the 
mobility of military dependent students and serving students with 
special needs were among the greatest challenges they faced in serving 
these students. Mobility increased academic needs due to differences 
in state and district curricula and behavioral and emotional issues in 
the classroom. To address challenges in serving military dependent 
students, school districts reported adopting a range of strategies, 
including additional counseling for students with a deployed parent 
and flexibility on academic requirements for newly transferred 
students. 

Guided by a memorandum of understanding signed in 2008, DOD and 
Education have implemented practices that facilitate their 
collaboration to assist military dependent students, according to 
practices GAO has identified that enhance collaboration. For example, 
beginning in 2008, the departments completed eight joint site visits 
to high-growth military installations, which helped them advise school 
districts on preparation for an influx of military dependent students. 
To monitor these collaborative efforts, DOD and Education have 
developed a strategic plan that tracks their progress. 

Figure: School District Allocation of DOD Impact Aid Supplemental 
Funds, 2009–2010 School Year: 

[Refer to PDF for image: horizontal bar graph] 

Account: General fund; 
Percentage of respondents: 85%. 

Account: Capital Project fund; 
Percentage of respondents: 15%. 

Account: Special Revenue fund: 
Percentage of respondents: 11%. 

Account: Other accounts; 
Percentage of respondents: 5%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

Note: School districts may place funds in more than one account. 

[End of figure] 

What GAO Recommends: 

GAO recommends that the Secretary of Education determine whether to 
require school districts to report data on the academic outcomes of 
military dependent students, and if so, to determine the need for any 
additional legislative authority. Education agreed with GAO’s 
recommendation, and DOD provided oral concurrence. 

View [hyperlink, http://www.gao.gov/products/GAO-11-231] or key 
components. For more information, contact George Scott at (202) 512-
7215 or scottg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Little Is Known About the Specific Use and Effectiveness of DOD Impact 
Aid and There Are No National Data on Military Dependent Students as a 
Group: 

Military Dependent Students' Frequent Moves and Educating Military 
Dependents with Special Needs are Primary Challenges for School 
Districts, and Various Strategies Help Address These Challenges: 

DOD and Education's Collaborative Practices Have Assisted Military 
Dependent Students, Their Schools, and Families: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Information on Additional Mandate Provisions: 

Appendix III: The 13 Objectives from Education and DOD's MOU: 

Appendix IV: Comments from the Department of Education: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Annual Funding for Fiscal Years 2001-2010 for DOD Impact Aid 
Components: 

Table 2: School Districts Interviewed in Five Selected States: 

Figures: 

Figure 1: Photo of a School Bulletin Board Showing Previous and Future 
Residences of Military Dependent Students, May 2010: 

Figure 2: School District-Reported Allocation of DOD Impact Aid 
Supplemental Funds for 2009-2010 School Year: 

Figure 3: School District-Reported General Fund Allocations: 

Figure 4: School District-Reported Difficulty in Tracking DOD Impact 
Aid Supplemental Funds: 

Figure 5: School District-Reported Areas of Cuts or Adjustments If DOD 
Impact Aid Supplemental Funding Was Not Received for the 2010-2011 
School Year: 

Figure 6: School District-Reported Challenges in Educating Military 
Dependent Students: 

Figure 7: School District-Reported Strategies Used to Support Military 
Dependent Students: 

Abbreviations: 

BRAC: Base Realignment and Closure: 

DOD: Department of Defense: 

DoDEA: Department of Defense Education Activity: 

Education: Department of Education: 

ESEA: Elementary and Secondary Education Act of 1965: 

MOU: memorandum of understanding: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 1, 2011: 

The Honorable Carl Levin: 
Chairman: 
The Honorable John McCain: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Howard P. "Buck" McKeon: 
Chairman: 
The Honorable Adam Smith: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

Roughly 1.1 million school-age children in the United States are 
military dependents, with parents in the armed forces.[Footnote 1] The 
majority of these students are estimated to attend public schools. 
Military dependent children often move multiple times throughout their 
school careers and sometimes have a parent absent due to deployment, 
creating unique challenges for their school districts. In recent 
years, appropriations for the Department of Education's (Education) 
Impact Aid program has been more than $1 billion a year. Since the 
early 1990s, Congress has authorized and provided additional funds for 
school districts that serve a significant number of military 
dependents.[Footnote 2] One of several Department of Defense (DOD) 
programs to assist these students--DOD Impact Aid, with funding 
totaling approximately $342.3 million since fiscal year 2002--helps to 
ensure that school districts with significant numbers of military 
dependent students have additional funding in order to maintain 
certain educational standards. Education of military dependent 
students is becoming an increasingly important issue with recent 
growth in and moves of military personnel at some military 
installations located in the United States. These changes are due to 
several factors, including implementation of recommendations from the 
2005 Base Realignment and Closure (BRAC) Commission, relocation of 
U.S. forces in overseas locations back to the United States, global 
rebasing, and other force structure changes. As of September 2009, 
these changes were expected to add more than 120,000 military and DOD 
civilian personnel, not including family members and contractors, to 
U.S. military installations by September 2011. 

The National Defense Authorization Act for Fiscal Year 2010 required 
us to examine the use of DOD Impact Aid assistance by school districts 
and its effectiveness in improving the quality of education provided 
to military dependent students from fiscal years 2001 through 2009. 
[Footnote 3] To do this, we reviewed (1) what is known about the use 
and effectiveness of DOD Impact Aid funds, (2) the challenges faced by 
school districts in serving military dependent students and the 
strategies they have in place to address these challenges, and (3) how 
DOD and Education have collaborated on their assistance to districts. 
[Footnote 4] 

To address these issues, we conducted a Web-based survey in August and 
September 2010 of all 154 school districts that received DOD Impact 
Aid in any year from 2001 through 2009--we received responses from 
118, for a response rate of 77 percent. We conducted site visits to 
four school districts in Colorado and Virginia and phone calls with 
officials in three school districts in California, Missouri, and 
Texas. We selected these districts based on recommendations from DOD 
and national organizations involved in the education of military 
dependent students, and attempted to include diversity in geographic 
location, school district size, and the percentage of the district 
made up of military dependents from different branches of military 
service. During the visits we interviewed superintendents, assistant 
superintendents, budget office officials, guidance counselors, and, in 
some locations, military school liaisons, teachers, and students. In 
one school district, we met with a group of parents. We also 
interviewed officials from DOD and Education who are involved with the 
implementation of DOD Impact Aid and the related memorandum of 
understanding (MOU) between the two agencies. Finally, we reviewed key 
agency documents and relevant literature, including prior GAO reports 
on elementary and secondary education, military restructuring, and 
practices that can help to enhance collaboration. We also reviewed 
relevant federal laws and regulations. A more detailed explanation of 
our methodology can be found in appendix I. 

We conducted this performance audit from March 2010 through February 
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 and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

Military Dependent Students: 

There are approximately 1.1 million school-age dependents of military 
parents in the United States and an increasing number of these 
dependents have a parent deployed overseas. While DOD operates 194 
schools for military dependents in seven states, two territories, and 
in 12 countries, DOD estimates the majority of military dependent 
students attend U.S. public schools operated by local school 
districts. Because of their family situations, military dependent 
students may face a range of unique challenges, such as frequent moves 
throughout their school career and the emotional difficulties of 
having deployed parents. Figure 1 is a photo from a school we visited 
with about 90 percent military dependent students that showed the 
global locations of students' previous and future residences. Military 
dependent students often find stability in the school routine during 
the challenges of deployment and the resulting disruptions to daily 
life, according to a DOD publication.[Footnote 5] 

Figure 1: Photo of a School Bulletin Board Showing Previous and Future 
Residences of Military Dependent Students, May 2010: 

[Refer to PDF for image: photograph] 

Source: GAO. 

[End of figure] 

Education and DOD's Impact Aid Programs: 

Appropriations for Education's Impact Aid program, reauthorized and 
incorporated into Title VIII of the Elementary and Secondary Education 
Act of 1965 (ESEA),[Footnote 6] were almost $1.3 billion in fiscal 
year 2010, and DOD provided $41 million in additional funding for DOD 
Impact Aid. DOD Impact Aid was established in the early 1990s to 
supplement the Education Impact Aid program which, as we testified at 
that time, was underfunded (i.e., meaning that appropriations did not 
fully fund authorizations). Together, the programs are intended to 
compensate school districts for revenue losses resulting from federal 
activities and to maintain educational standards for all students. 
[Footnote 7] Federal activities that can affect revenues or the 
ability to maintain standards include federal ownership of property 
within a district as well as the enrollment of children whose parents 
work or live on federal land (e.g., military bases). 

Education Impact Aid funds are awarded in formula grants based on 
various types of federally connected children in the school district 
and other measures.[Footnote 8] If appropriations are not sufficient 
to provide funding at the level for which all districts qualify, 
funding is reduced with more heavily impacted districts receiving 
higher percentages of their maximum payments than less impacted 
districts. Of the more than 14,000 school districts nationwide, 902 
received Education Impact Aid payments for federally connected 
children in fiscal year 2009. Because Impact Aid payments are not 
aimed at specific educational goals, accountability requirements for 
the use of funds or for specific outcomes are minimal. 

DOD Impact Aid, administered by DOD's Education Activity (DoDEA) 
Educational Partnership office is intended to supplement the much 
larger Education Impact Aid program. All districts that receive DOD 
Impact Aid also receive Education Impact Aid. There are no statutory 
requirements mandating that school districts report on the use of 
these funds. DOD Impact Aid has three distinct funding components for 
school districts with military dependent students. These funding 
components are: 

* Supplemental assistance. These funds are allocated to school 
districts in which military dependents made up at least 20 percent of 
average daily attendance during the previous school year.[Footnote 9] 
Data from Education's Impact Aid application are used to determine a 
district's eligibility. About 120 districts receive funds from DOD 
Impact Aid Supplemental assistance annually. Total amounts awarded to 
all districts combined have ranged from $30 to $40 million in each 
fiscal year from 2002 through 2010,[Footnote 10] and the funding has 
been included by Congress in DOD's annual appropriation for operation 
and maintenance for defensewide activities. 

* Assistance for children with severe disabilities. Funds are 
allocated to school districts with at least two military dependent 
children with severe disabilities where the costs exceed certain 
criteria.[Footnote 11] The funding is a reimbursement for expenses 
paid, and is sent to the school districts after the expenses are 
incurred. According to a DOD official, approximately 40-50 school 
districts that apply and meet the cost criteria are awarded funds each 
year out of the 400-500 school districts that are potentially 
eligible.[Footnote 12] Total amounts awarded to all districts combined 
have generally ranged from $4 to $5 million in each fiscal year from 
2002 through 2010.[Footnote 13] 

* Assistance for districts significantly affected by BRAC. Funds are 
allocated to school districts that have been heavily impacted as a 
direct result of large scale military rebasing. Beginning in the late 
1980s, the U.S. military has attempted to streamline the nation's 
defense infrastructure through a series of base realignments and 
closures. For example, as part of the 2005 BRAC round, DOD has 
relocated or plans to relocate more than 120,000 military and DOD 
civilian personnel by September 2011. In addition, DOD and local 
community officials expect thousands of dependents to relocate to 
communities near the BRAC 2005 growth bases. Thus, several U.S. bases 
could each see the addition of more than 10,000 military and DOD 
civilian personnel, along with their families and children. To qualify 
for these DOD Impact Aid BRAC funds, districts must have had at least 
20 percent military dependent students in average daily attendance 
during the previous school year and have had an overall increase or 
decrease of 5 percent or more of these students, or an increase or 
decrease of no less than 250 military dependent students at the end of 
the prior school year. No school district is permitted to receive more 
than $1 million in assistance in a fiscal year. In fiscal years 2006 
and 2007, 45 districts received BRAC funding from DOD Impact Aid 
totaling $15 million. Although authorized, funding was not provided in 
fiscal years 2002, 2008, 2009, and 2010 (see table 1). 

Table 1: Annual Funding for Fiscal Years 2001-2010 for DOD Impact Aid 
Components: 

Fiscal year: 2001; 
Type of DOD Impact Aid: Supplemental: [Empty][A]; 
Type of DOD Impact Aid: Children with severe disabilities: n/a[B]; 
Type of DOD Impact Aid: BRAC: n/a[C]; 
Total: [Empty]. 

Fiscal year: 2002; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $4.3 
million; 
Type of DOD Impact Aid: BRAC: 0; 
Total: $34.3 million. 

Fiscal year: 2003; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $3 million; 
Type of DOD Impact Aid: BRAC: n/a; 
Total: $33 million. 

Fiscal year: 2004; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $5 million; 
Type of DOD Impact Aid: BRAC: n/a; 
Total: $35 million. 

Fiscal year: 2005; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $5 million; 
Type of DOD Impact Aid: BRAC: n/a; 
Total: $35 million. 

Fiscal year: 2006; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $5 million; 
Type of DOD Impact Aid: BRAC: $7 million; 
Total: $42 million. 

Fiscal year: 2007; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $5 million; 
Type of DOD Impact Aid: BRAC: $8 million; 
Total: $43 million. 

Fiscal year: 2008; 
Type of DOD Impact Aid: Supplemental: $30 million; 
Type of DOD Impact Aid: Children with severe disabilities: $5 million; 
Type of DOD Impact Aid: BRAC: 0; 
Total: $35 million. 

Fiscal year: 2009; 
Type of DOD Impact Aid: Supplemental: $40 million; 
Type of DOD Impact Aid: Children with severe disabilities: $4 million; 
Type of DOD Impact Aid: BRAC: 0; 
Total: $44 million. 

Fiscal year: 2010; 
Type of DOD Impact Aid: Supplemental: $37 million; 
Type of DOD Impact Aid: Children with severe disabilities: $4 million; 
Type of DOD Impact Aid: BRAC: 0; 
Total: $41 million. 

Source: DOD. 

[A] DOD could not provide data for Supplemental Impact Aid for fiscal 
year 2001. 

[B] The Floyd D. Spence National Defense Authorization Act for Fiscal 
Year 2001 began authorizing payments for this program in fiscal year 
2002. Pub. L. No. 106-398, appendix § 363, 114 Stat. 1654, 1654A-77, 
78. 

[C] Funding was authorized for this program in fiscal year 2002, and 
since fiscal year 2006. See, e.g., National Defense Authorization Act 
for Fiscal Year 2006, Pub. L. No. 109-163, § 572(b), 119 Stat. 3136, 
3271-73. 

[End of table] 

Other DOD Assistance for Military Dependent Children: 

In addition to DOD Impact Aid, DOD provides other assistance to school 
districts and military families for school-age children through the 
following programs: 

* DoDEA grants to schools. DoDEA has two programs that provide grants 
for military-connected schools nationwide. These grant programs began 
in 2008, and are authorized through fiscal year 2013.[Footnote 14] 
Unlike the Supplemental Impact Aid program, the DoDEA grants are 
targeted for specific uses and have specific evaluation requirements. 
The competitive grant program aims to enhance student achievement, 
provide professional development for educators, and integrate 
technology into curricula at schools experiencing growth in numbers of 
military dependent students. The invitational grant program aims to 
enhance student achievement and ease challenges that military 
dependent students face due to their parents' military service. 
Through these two programs, DoDEA awarded approximately $56 million to 
40 schools in fiscal year 2009, and approximately $38 million to 32 
schools in fiscal year 2010. 

* Military family life consultants. DOD's Office of the Deputy Under 
Secretary of Defense for Family Policy, Children, and Youth 
administers the Military Family Life Consultant program, which 
provides counseling services to faculty, staff, parents, and children 
in school districts with a high percentage of parent deployments. The 
program began in fiscal year 2004 as a demonstration program, and 
received $150 million in fiscal year 2009 and $259 million in fiscal 
year 2010. Working as DOD contract employees, these consultants 
typically assist with issues including school transitions, adjustment 
to deployments and reunions, and parent-child communication. In 
addition, consultants try to promote a culture that encourages service 
members and their families to seek counseling or other assistance when 
they have a problem. As of fall 2010, there were more than 200 
consultants supporting 297 schools and 105,000 military dependent 
students worldwide. 

* School liaison officers. Each service branch--the Army, Marine 
Corps, Navy, and Air Force--administers the School Liaison Officer 
program, which provides military commanders with the support necessary 
to coordinate assistance to and advise military parents of school-age 
children on educational issues and assist in solving education-related 
problems. In fiscal year 2010, the Army spent $14.7 million on its 
program, the Marine Corps $2.1 million, and the Navy $3.6 
million.[Footnote 15] A school liaison officer's responsibilities 
include promoting military parents' involvement in schools, assisting 
children and parents with overcoming obstacles to education that stem 
from the military lifestyle, and educating local communities and 
schools on the needs of military children. As of fall 2010, there were 
more than 250 school liaison officers assisting DOD and military- 
connected public schools throughout the world, and more than 150 of 
those were in the United States, all of whom are disbursed across the 
service branches. The Army reported funding 141 school liaison 
officers, the Marine Corps 24, the Navy 58, and the Air Force 82. 

* Tutor.com. Since the end of 2009, DOD has provided children of 
active duty military with free, unlimited access to online tutoring, 
academic skills courses, and homework assistance in math, science, 
social studies, and English for kindergarten through 12th grade (K-12) 
students through Tutor.com. The program received $2 million in fiscal 
year 2009. Professional tutors assist military dependent students with 
completing homework, studying for standardized tests, and writing 
papers. Some tutors are career specialists who can assist with resume 
writing and job searches. The program provided 162,570 sessions during 
fiscal year 2010. 

* Heroes at Home for preschool-age children. Heroes at Home, a pilot 
program established in fiscal year 2007,[Footnote 16] seeks to assist 
active duty parents of preschool-age children at military 
installations with significant transition or deployment activities. 
The program provides research-based curriculum and training for parent 
educators, who then work with other parents to help them mitigate any 
risk to children's well-being or educational readiness posed by 
military life. Over a 3 year period, Heroes at Home has served more 
than 1,900 military families and almost 2,400 children from birth 
until kindergarten. The program has received $3.4 million since fiscal 
year 2008. Activities supported by the funding ended in September 
2010, but will continue at some installations through other funding 
mechanisms and existing programs. 

Other Education Assistance for School Districts: 

In addition to Education and DOD Impact Aid and other DOD assistance 
for military dependent children, school districts may also qualify for 
other funding from Education. For example, a district may receive 
funding through Title I, Part A of ESEA,[Footnote 17] which authorizes 
financial assistance to school districts and schools with high numbers 
or high percentages of economically disadvantaged children. Funding 
may also come through the Individuals with Disabilities Education Act, 
[Footnote 18] which provides formula grants to states and school 
districts for children ages 3-21 who have a disability that impacts 
their education. 

Little Is Known About the Specific Use and Effectiveness of DOD Impact 
Aid and There Are No National Data on Military Dependent Students as a 
Group: 

Most School Districts Put DOD Impact Aid Supplemental Funds Into Their 
General Fund for Overall Expenses and Specific Uses Are Generally Not 
Tracked: 

Little is known about the specific use and effectiveness of DOD Impact 
Aid Supplemental funds because most school districts place the aid 
into their general fund to support salaries, maintenance, and 
operation of schools. In our survey of school districts that received 
DOD Impact Aid Supplemental funds in any year from 2001 through 2009, 
of the 87 school districts that reported receiving funds for the 2009-
2010 school year, 85 percent put at least some of their award in their 
general fund.[Footnote 19] Approximately 15 percent of reported funds 
went to a capital project fund, about 11 percent to a special revenue 
fund,[Footnote 20] and about 5 percent to another account (see figure 
2).[Footnote 21] When asked to provide a brief description of how DOD 
Impact Aid Supplemental funds were spent, survey respondents reported 
using them for salaries, supplies, technology, transportation, heating 
and cooling systems, and capital upgrades. 

Figure 2: School District-Reported Allocation of DOD Impact Aid 
Supplemental Funds for 2009-2010 School Year: 

[Refer to PDF for image: horizontal bar graph] 

Account: General fund; 
Percentage of respondents: 85%. 

Account: Capital Project fund; 
Percentage of respondents: 15%. 

Account: Special Revenue fund: 
Percentage of respondents: 11%. 

Account: Other accounts; 
Percentage of respondents: 5%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

Note: School districts may place funds into more than one account. 
Debt Service Fund was also a response option, but none of the survey 
respondents put DOD Impact Aid Supplemental monies into that fund. 

[End of figure] 

School districts reported using, on average, about 77 percent of their 
general fund for salaries and benefits. The general fund was also used 
to pay for supplies, property services (such as operations, 
maintenance, and repair of district-owned property), and other 
services such as food and transportation (see figure 3). 

Figure 3: School District-Reported General Fund Allocations: 

[Refer to PDF for image: pie-chart] 

Salaries and benefits: 77%; 
Supplies: 7%; 
Purchased property services: 6%; 
Other purchased services (Such as transportation or food services): 5%; 
Other: 5%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

[End of figure] 

DOD Impact Aid Supplemental funds are not required by statute to be 
used for specific purposes or to be targeted directly to military 
dependent students. Further, there are no tracking or reporting 
requirements on the expenditures of funds and, as a result, there is 
no way to determine specifically how the funds are used. However, 
school districts that expend $500,000 or more[Footnote 22] are subject 
to a financial audit in accordance with the Single Audit Act.[Footnote 
23] Fewer than 20 percent of the districts that responded to our 
survey reported using a separate accounting code to track expenditures 
of DOD Impact Aid Supplemental funds. 

School districts that completed our survey had mixed opinions 
regarding how easy or challenging it is or would be to track how they 
spend DOD Impact Aid Supplemental funds. Thirty-nine percent of 
districts receiving these funds said it would be easy for them to 
track the funds' use. For example, some districts already put their 
DOD Impact Aid Supplemental funds into a separate fund or have an 
accounting system that can track spending using a unique code. One 
school district official said in the survey that the district would 
simply designate its DOD Impact Aid Supplemental funds for a 
particular expenditure, such as 25 percent of its total expenditures 
for counseling services, if tracking and reporting were required. 
However, an equal percentage of districts in our survey said that 
tracking exactly how funds are spent would be challenging and time 
consuming because their accounting systems are not set up to do so, 
and their funds are used for multiple programs and needs (see figure 
4). In addition, we heard from several district officials that the 
amount of money received by districts is so small--less than 2 
percent, on average, of a district's total budget--that additional 
resources to account for the funds would not be justified.[Footnote 
24] One district official from Colorado said that DOD Impact Aid 
funding is too small and too unpredictable to dedicate specifically to 
military dependent students or to fund special staff or programs. 

Figure 4: School District-Reported Difficulty in Tracking DOD Impact 
Aid Supplemental Funds: 

[Refer to PDF for image: horizontal bar graph] 

Somewhat or extremely easy: 39%; 
Neither easy nor challenging: 15%; 
Somewhat or extremely challenging: 39%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

[End of figure] 

Officials in four of the seven school districts that we interviewed 
and 19 survey respondents commented on the flexibility afforded by DOD 
Impact Aid funding. Many of these districts appreciated the 
flexibility of these funds because they can spend the money how they 
deem most beneficial for their district. Flexible funding is 
particularly important now, some school officials said, because of 
state cuts to education budgets in recent years. In another 2010 GAO 
survey of school districts on stimulus spending, an estimated one-
third reported budget cuts in the 2009-2010 school year and nearly one 
in four reported cutting jobs, even with American Recovery and 
Reinvestment Act of 2009 funds.[Footnote 25] Several school districts 
we contacted reported using DOD Impact Aid Supplemental funds to pay 
for necessities that would have otherwise been cut due to less funding 
from the state. Fifty-one percent of survey respondents said if they 
did not receive DOD Impact Aid Supplemental funds for the 2010-2011 
school year, they would likely or very likely make cuts or adjustments 
to instructional staff (see figure 5). Forty-six percent reported that 
they would likely or very likely make cuts or adjustments to 
technology expenditures, and 42 percent reported that supplies and 
classroom materials would likely or very likely be cut. One school 
district official said if his district did not receive the funds, it 
would prioritize expenditures and any consideration of possible staff 
reductions would be taken very seriously, but used as a last resort. 
Another school district reported that since this funding is small, a 
one-year loss would impact technology and supplies, but staffing would 
only be affected if the funds were lost going forward. 

Figure 5: School District-Reported Areas of Cuts or Adjustments If DOD 
Impact Aid Supplemental Funding Was Not Received for the 2010-2011 
School Year: 

[Refer to PDF for image: horizontal bar graph] 

Percentage of respondents: 

Area: Instructional staff (Salaries and benefits); 
Unlikely or very unlikely to be cut or adjusted: 24%; 
Likely or very likely to be cut or adjusted: 51%. 

Area: Technology; 
Unlikely or very unlikely to be cut or adjusted: 27%; 
Likely or very likely to be cut or adjusted: 46%. 

Area: Supplies and classroom materials; 
Unlikely or very unlikely to be cut or adjusted: 26%; 
Likely or very likely to be cut or adjusted: 42%. 

Area: Academic programs (art, music); 
Unlikely or very unlikely to be cut or adjusted: 36%; 
Likely or very likely to be cut or adjusted: 31%. 

Area: Professional development of teachers, counselors, staff; 
Unlikely or very unlikely to be cut or adjusted: 36%; 
Likely or very likely to be cut or adjusted: 28%. 

Area: Building improvements/modernization; 
Unlikely or very unlikely to be cut or adjusted: 40%; 
Likely or very likely to be cut or adjusted: 26%. 

Area: Administration (Personnel and overhead); 
Unlikely or very unlikely to be cut or adjusted: 36%; 
Likely or very likely to be cut or adjusted: 26%. 

Area: Extracurricular programs (sports, support groups); 
Unlikely or very unlikely to be cut or adjusted: 41%; 
Likely or very likely to be cut or adjusted: 25%. 

Area: Transportation; 
Unlikely or very unlikely to be cut or adjusted: 44%; 
Likely or very likely to be cut or adjusted: 18%. 

Area: Construction; 
Unlikely or very unlikely to be cut or adjusted: 47%; 
Likely or very likely to be cut or adjusted: 11%. 

Area: Food or food services; 
Unlikely or very unlikely to be cut or adjusted: 58%; 
Likely or very likely to be cut or adjusted: 7%. 

Area: Other; 
Unlikely or very unlikely to be cut or adjusted: 36%; 
Likely or very likely to be cut or adjusted: 13%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

[End of figure] 

When we asked school district officials in our survey if the DOD 
Impact Aid Supplemental funding is effective in improving the quality 
of education provided to military dependent students, 66 percent 
strongly agreed.[Footnote 26] One district official from Texas told us 
that while DOD Impact Aid Supplemental funding is not a significant 
amount of money compared to that of the Education Impact Aid program, 
it is "the icing on the cake" for addressing the unique needs of their 
military dependent students. In addition, several school district 
officials we contacted said the funding is very important and allows 
the district to improve the quality of education. For example, the 
funds enabled one school district to make enhancements to their 
educational programs, offer new programs, and upgrade facilities. 
Sixty-seven percent of the districts responding to our survey strongly 
agreed that DOD Impact Aid Supplemental funding serves its purpose by 
compensating them for some of the tax and other revenues lost due to a 
federal presence in the district.[Footnote 27] Yet, only 16 percent 
strongly or somewhat agreed that the amount of DOD Impact Aid 
Supplemental funding received is adequate. 

No National Data Exist on Military Dependent Students as a Group: 

Further compounding the difficulty of efforts to evaluate the 
effectiveness of DOD Impact Aid funds, we found a lack of national 
data on military dependent students in general. There are no national 
public data on military dependent students' academic progress, 
attendance, or long-term outcomes, such as college attendance or 
workplace readiness. DoDEA officials told us the only data currently 
available on this population come from the Impact Aid forms completed 
by parents, which provide information on whether a student is 
federally connected or not. 

Federal agency officials and a military education advocacy group have 
expressed interest in having more data collected about military 
dependent students, as it is for other public school cohorts. ESEA, 
amended and reauthorized by the No Child Left Behind Act of 2001, 
designates four specific groups of students as reportable and 
accountable subgroups: economically disadvantaged, major racial and 
ethnic groups, those with disabilities, and those with limited 
proficiency in English.[Footnote 28] The legislation holds states, 
school districts, and individual schools accountable for the 
achievement of all students, including students in these four 
subgroups. While some senior Education officials have acknowledged the 
importance of obtaining these data for military dependent students, 
they have not yet determined what, if any, concrete actions they will 
take. Similarly, the Military Child Education Coalition, a nonprofit 
organization focused on ensuring quality educational opportunities for 
all military dependent children, is working with DOD and Education to 
explore ways to use existing capacities to create processes for 
collecting and analyzing data on all students of active duty, National 
Guard, and Reserves families. 

While DOD Impact Aid funds are not targeted for use for military 
dependent students only, collecting this information could help serve 
these students better. Senior representatives from Education and the 
Military Child Education Coalition explained that without more 
specific data, educators, base commanders, and community leaders are 
not able to provide military dependent students with appropriate 
resources because they do not have information on their specific 
educational needs or the effectiveness of the schools and programs 
serving them. Further, these data could help military families make 
more informed decisions about where to enroll their children by 
identifying how well specific schools educate military dependent 
students. For example, military families may in some cases choose 
whether to live on or off a base, and may choose which school district 
their children will attend, depending on the quality of the schools. A 
senior Education official also emphasized that this information could 
shed light on practices that work well generally in educating other 
highly mobile students, such as homeless or migrant students. In 
addition, using data on military dependent students in a longitudinal 
database would allow researchers to better understand these students' 
academic achievement and educational outcomes over time and the 
factors that might affect them. 

At the same time, some groups representing school districts have 
expressed concerns about making military dependent students a 
reportable subgroup. These concerns include creating an additional 
reporting burden and new costs for school districts and concerns about 
singling out military dependent students as a unique group. However, 
Education officials did not anticipate excessive cost or burden for 
school districts to collect and report these data. 

Military Dependent Students' Frequent Moves and Educating Military 
Dependents with Special Needs are Primary Challenges for School 
Districts, and Various Strategies Help Address These Challenges: 

Military Dependent Students' Mobility and Students with Special Needs 
Were Primary Educational Challenges Reported by School Districts: 

Officials at three quarters of the school districts responding to our 
survey reported that issues associated with military dependent 
students' frequent moves to new schools were moderately, very, or 
extremely challenging. In addition, 58 percent reported meeting the 
needs of military dependent students with disabilities was moderately, 
very, or extremely challenging. In our survey of these school 
districts, three of the top four challenges reported by districts 
responding to our survey were related to the mobility of military 
families. Mobility increased academic needs due to differences in 
state and district curricula, lack of connectedness with school, and 
behavioral issues in the classroom. Serving students with special 
needs was another important challenge faced by the school districts in 
our survey. These challenges, as well as the emotional toll faced by 
students as a result of frequent moves, were echoed in the interviews 
we held with selected school districts. A smaller percentage of survey 
respondents also reported lack of participation by parents, 
transportation to and on bases, and transitioning of teachers and 
staff who are in military families, among other challenges (see figure 
6). 

Figure 6: School District-Reported Challenges in Educating Military 
Dependent Students: 

[Refer to PDF for image: horizontal bar graph] 

Challenge: Increased academic need (due to differences in district and 
state curricula); 
Slightly or not at all challenging: 20%; 
Moderately challenging: 32%; 
Extremely or very challenging: 41%. 

Challenge: Large percentage of students with special needs; 
Slightly or not at all challenging: 34%; 
Moderately challenging: 22%; 
Extremely or very challenging: 36%. 

Challenge: Lack of connectedness with school (due to frequent moves); 
Slightly or not at all challenging: 33%; 
Moderately challenging: 34%; 
Extremely or very challenging: 24%. 

Challenge: Behavioral issues in classroom (due to frequent 
moves/parent deployment); 
Slightly or not at all challenging: 38%; 
Moderately challenging: 31%; 
Extremely or very challenging: 24%. 

Challenge: Transitioning of teachers and staff (who are in military 
families); 
Slightly or not at all challenging: 46%; 
Moderately challenging: 27%; 
Extremely or very challenging: 13%. 

Challenge: Large percentage of low-income students; 
Slightly or not at all challenging: 50%; 
Moderately challenging: 23%; 
Extremely or very challenging: 15%. 

Challenge: Lack of participation by parents; 
Slightly or not at all challenging: 56%; 
Moderately challenging: 17%; 
Extremely or very challenging: 17%. 

Challenge: Transportation (i.e., buses traveling on military bases); 
Slightly or not at all challenging: 65%; 
Moderately challenging: 10%; 
Extremely or very challenging: 13%. 

Challenge: Other challenges[A]; 
Slightly or not at all challenging: 14%; 
Moderately challenging: 5%; 
Extremely or very challenging: 19%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

[A] Among the school districts that provided details about other 
challenges in educating military dependent students, three reported 
students' emotional suffering, often due to parental deployment, as a 
challenge. 

[End of figure] 

Student Mobility: 

Key issues associated with the mobility of military dependent students 
identified by school districts we contacted were different state and 
district academic curricula and standards, lack of student and family 
connectedness to school, and behavioral and emotional issues of 
students, most often related to a parent's deployment or absence. 

Different Academic Curricula and Standards: 

The largest challenge reported by school districts in our survey was 
the increased academic need of children in military families who 
transfer to a school with different curricula or academic standards 
than those in their previous school and thus need additional support. 
Forty-one percent of school districts rated increased academic needs 
due to differences in curricula between districts and/or states as 
extremely or very challenging, and 32 percent said it was moderately 
challenging. States use different curricula and have different 
graduation and academic standards and assessment practices, sometimes 
making it difficult for a receiving school to integrate new students. 
For example, one school district official we interviewed noted the 
state requires 25 classes to graduate from high school, whereas other 
states require only 20 classes, which has created challenges for 
incoming juniors and seniors. These inter-district differences can 
extend to the placement of students in special education or gifted 
programs. A school district official in one state, for example, told 
us that some students who received special education services in their 
previous state no longer qualified for these services. While the 
district works to provide adequate supports within the classroom, the 
official said it is sometimes difficult to explain to students and 
their families why they no longer qualify for services to which they 
are accustomed. These challenges are compounded when the records from 
the sending district do not arrive on time or are incomplete--an issue 
identified as a challenge by some districts. 

In addition, mobility often results in classes with a high degree of 
student turnover each year, creating an extra burden on teachers to 
orient new students to class material, assess their academic 
abilities, and provide extra support, as needed. Officials at five of 
the schools we interviewed told us that each year at least one-third 
of their student population turns over. A principal of an elementary 
school in Colorado told us only one out of 57 fifth graders has been 
with the school since kindergarten. Because this turnover takes place 
throughout the school year, teachers must spend time continually 
absorbing and integrating new students into their classrooms, which 
reduces the time available for instruction. 

We found very few generalizable studies that systematically examined 
the academic and behavioral effects of mobility for military students 
specifically. National student level achievement data on military 
dependent students are also not available, so it is difficult to link 
achievement and mobility. However, we recently reported that mobility 
is one of several interrelated factors, including socio-economic 
status and lack of parental education, which have a negative effect on 
academic achievement.[Footnote 29] In addition, some of the studies we 
reviewed found that the effect of mobility on achievement also varied 
depending on such factors as the student's race or ethnicity, special 
needs, grade level, frequency of school change, and characteristics of 
the school change--whether it was between or within school districts, 
or to an urban district from a suburban or rural one. 

Lack of Connectedness with School: 

Military dependent students' lack of connectedness with their school 
due to frequent moves was reported as extremely or very challenging by 
24 percent of school districts in our survey, and moderately 
challenging by 34 percent. Frequent moves make it difficult, for 
example, for students to get involved with extracurricular activities 
or sports if they move after the tryout season. Officials we 
interviewed from one school in Texas said they allowed children to try 
out for extracurricular activities by sending a video before they 
arrived, and another allowed newly arrived military dependent students 
to try out for teams mid-season. Students are not guaranteed their 
same position (e.g., quarterback) which can be disappointing, but they 
will be given an opportunity to try out for the team. Officials also 
said limited child care options and lack of transportation to the 
military base limit students' ability to attend after-school events. 
School liaison officers in another school district similarly 
attributed the lack of public transportation on base to families 
feeling isolated and having difficulty attending extracurricular 
activities. Officials in 23 percent of districts responding to our 
survey reported transportation was at least moderately challenging. 
Related to a student's lack of connectedness is lack of parental 
involvement. School principals we interviewed in Colorado said 
military parents tend to avoid school involvement partly because they 
anticipate leaving in a few years. The lack of parental involvement is 
particularly troubling for district officials because they feel that 
parents need to be part of the school community for success in 
educating their students. 

Finally, related to mobility, 13 percent of survey respondents 
reported that transitioning of teachers and staff from military 
families who work at schools when military families are reassigned was 
extremely or very challenging, and 27 percent reported this was 
moderately challenging. Officials in two school districts told us that 
hiring military spouses is advantageous because they have first hand 
experience with military issues and can relate well to military 
dependent students. However, when the military spouses leave the 
school district it creates more inconsistency in the education of 
military dependent students. 

Behavioral and Emotional Issues: 

Officials in 24 percent of school districts in our survey said 
behavioral issues in the classroom, such as aggression--which may be 
attributable to frequent moves and parent deployment--were extremely 
or very challenging, and 31 percent said they were moderately 
challenging. Officials we interviewed in six of the seven districts 
said there is an emotional toll faced by students as a result of 
frequent school transfers. In one school district in Virginia, 
approximately 60 percent of students who started at a school are no 
longer there at graduation. Officials in this district found that 
frequent moves are a significant hindrance to the academic and 
emotional success of military dependent students. Some officials said 
mobility-related emotional issues tend to be more challenging for high 
school students, who may have more trouble fitting in and meeting 
academic requirements for graduation. The students we spoke with at 
one high school, many of whom were military dependents and had moved 
frequently, agreed that transitioning to new schools was most 
difficult during high school because social groups are already firmly 
established. 

School district officials we interviewed also identified emotional and 
behavioral challenges connected to parent deployment, absence, and in 
some cases, the death of a parent. In particular, officials we 
interviewed at two school districts near Army bases noted an increase 
in emotional and behavioral issues, including student truancy and 
tardiness, in recent years. Specifically, school officials near Army 
bases in Colorado and Missouri agreed that students' misbehavior and 
acting out has increased in recent years and is currently at chronic 
levels. One superintendent noted that her county has lost more than 
300 soldiers in the Afghanistan and Iraq conflicts. A school counselor 
added that reintegration when the absent parent returns can also be 
stressful as families re-establish rules and dynamics. Some districts 
noted that the leave soldiers take upon return from deployment 
resulted in long student absences. While district officials we spoke 
with wanted to be accommodating to reunited families, they noted that 
these student absences were taking an academic toll. Officials in 
these two districts said that teachers have found themselves 
fulfilling the role of social worker for military dependent students, 
a position they felt underqualified to fill. 

A 2010 study examining the well-being and deployment difficulties of 
more than a thousand families with military children aged 11-17 found 
they tended to have more emotional difficulties compared to national 
samples.[Footnote 30] The study found that older children had a 
greater number of school, family, and peer-related difficulties during 
deployment, and girls of all ages reported more challenges during both 
deployment and deployed-parent reintegration. Both the length of 
parental deployment and poor mental health of the nondeployed 
caregiver were significantly associated with a greater number of 
challenges for children both during deployment and deployed-parent 
reintegration. 

Serving Students with Special Needs: 

Fifty-eight percent of survey respondents cited serving students with 
special needs as extremely or very challenging (36 percent) or 
moderately challenging (22 percent). We heard similar views in our 
interviews. For example, a special education director in one district 
we visited said that the difficulties most military dependent students 
face in transitioning frequently to and from schools are exacerbated 
for special education students given their greater instructional and 
other needs. Serving students with disabilities in public schools is a 
challenge for many school districts nationwide because these students 
are increasingly taught in mainstream classrooms. In 2009 we found 
that state and local school district officials believed classroom 
teachers were generally unprepared for teaching students with 
disabilities and a number of state and district officials wanted a 
stronger focus in teacher preparation programs on instruction of 
children with disabilities.[Footnote 31] 

DOD Impact Aid's Children with Severe Disabilities program reimburses 
school districts serving military dependent students with severe 
disabilities, but a number of school districts we contacted said the 
application for reimbursement is burdensome, in some cases taking 
numerous hours for school districts to complete. According to a DoDEA 
official, approximately 10 percent of the school districts that serve 
two or more military dependent children with special needs and 
establish that they meet the cost criteria submit an application each 
year. In accordance with statutory requirements, payment calculations 
require, among other things, determinations of average per pupil 
expenditure in the state as well as nationally.[Footnote 32] According 
to some school districts, calculations and application requirements 
are time consuming and require them to list specific costs expended on 
services for each eligible child. One director of special education 
told us that the process of applying for the Children with Severe 
Disabilities reimbursement takes about 80-90 hours of staff time. She 
explained that collecting the information requires obtaining data from 
occupational and physical therapists, and from other offices including 
transportation and special education. When there is staff turnover 
among any of these contacts, the process takes even longer. Officials 
from two districts we interviewed said the amount of the reimbursement 
was very small compared to the difficulty with completing the 
application. Officials in 10 of the 39 school districts responding to 
the survey that have received these funds said the application is 
difficult to complete in an open-ended survey question. DoDEA 
officials told us they are aware that the application can be difficult 
to complete, and one official was concerned that some districts that 
could benefit from the funds may not apply for them given the burden 
of the application. In response, DoDEA plans to issue more guidance in 
the form of frequently asked questions for the next application 
process in spring 2011. Officials plan to base this guidance on 
questions the department has received from applicants over the last 
several years. They also plan to develop a webinar to walk applicants 
through the application process for the next round. 

Schools Adopted Various Strategies to Address Challenges, Including 
Counseling, Use of Technology, and Flexible Academic Requirements: 

Additional counseling, use of technology, and flexibility on academic 
requirements were the strategies identified by most survey respondents 
that assist them in serving the unique needs of their military 
dependent students. In addition, school district officials we 
interviewed reported using a range of other related strategies, 
including providing literacy coaches, encouraging peer-to-peer support 
and other support groups, and reaching out to military installations 
for assistance (see figure 7). However, because most school districts 
receiving DOD Impact Aid Supplemental funds deposit the funds in the 
district's general fund and do not separately track their spending, we 
could not assess the extent to which any of these strategies were 
funded through DOD Impact Aid Supplemental funds rather than other 
funding sources. Some of the strategies school officials described are 
funded by other DOD programs or nonmilitary sources. 

Figure 7: School District-Reported Strategies Used to Support Military 
Dependent Students: 

[Refer to PDF for image: horizontal bar graph] 

Percentage of respondents using strategy or program: 

Strategy: Additional counseling by school personnel: 80%. 

Strategy: Online grades, coursework, attendance (accessible to 
parent(s) at home or deployed): 80%. 

Strategy: Flexible and/or individualized approach to academic 
requirements: 74%. 

Strategy: Literacy coaches and specialists: 72%. 

Strategy: Peer-to-peer support (i.e., Student2Student): 65%. 

Strategy: Counseling and support from installation representatives 
(i.e., school liaison officers): 64%. 

Strategy: Involvement of military members from nearby installations 
(i.e., Adopt a School): 61%. 

Strategy: Support groups (for children of deployed parents): 58%. 

Strategy: Interstate Compact on Educational Opportunity for Military 
Children: 51%. 

Strategy: Additional support staff to integrate new students 
throughout the school year: 43%. 

Strategy: Military and deployment focused bulletin boards: 33%. 

Strategy: Webcam interaction with deployed parent(s): 30%. 

Strategy: Live streaming of graduation for deployed parent(s): 30%. 

Strategy: Other: 19%. 

Source: GAO survey of school districts that received DOD Impact Aid 
Supplemental funds in any year from 2001 through 2009. 

[End of figure] 

Additional Counseling: 

Eighty percent of school districts in our survey reported using 
additional counseling as a key strategy to address the emotional needs 
of military dependent students, and many provided services such as 
deployment support groups and student peer support groups. One 
district hired a full-time psychologist to address the emotional and 
social needs of students due to both frequent school moves and 
recurring deployments of parents. Counseling and support often extend 
to other members of the family who are also struggling to cope with a 
deployed parent. For example, a home liaison in one district told us 
she holds training sessions on discipline with the at-home parent. 
Military parents we interviewed at one school district explained that 
sometimes the stigma associated with mental health services deterred 
military families from seeking help on base, raising the importance of 
supports at schools. Officials we interviewed at several school 
districts said they provided extra training for teachers and 
counselors on issues specific to military dependent students. In 
Texas, all counselors in one district received training in how to 
respond to needs of these students and their families in transitioning 
to a new area and how to help students cope with the loss of a parent. 

Officials in six of the seven school districts we interviewed told us 
they provided deployment support groups, typically led by school 
counselors, to provide military dependent students an opportunity to 
share feelings and solutions. Sixty-five percent of the schools in our 
survey offered peer-to-peer support programs. For example, "Student 2 
Student" is a peer program promoted by the Military Child Education 
Coalition in which a team of volunteer students, supervised by a 
school counselor, teacher, or other school staff, assists both 
incoming and outgoing students to cope with or prepare for changes in 
academics and relationships. Further, 33 percent of survey respondents 
reported using military or deployment-focused bulletin boards to 
provide support for military dependent students. For example, one 
school we visited posted a "heroes wall," which contained pictures and 
text the children created about their parent who was deployed. School 
district officials also highlighted the involvement of members of the 
military in supporting military dependent students. Sixty-one percent 
of districts responding to our survey said they involve members of 
nearby installations, and 64 percent reported taking advantage of 
counseling and other support offered by base representatives. For 
example, volunteers from one local installation provided one-on-one 
tutoring and military members attended physical education classes to 
help promote wellness and inspire the students to achieve a higher 
level of physical fitness. 

Use of Technology: 

The use of technology, such as online grades, coursework, and 
attendance records, which is accessible to parents at home or 
deployed, was used by 80 percent of the school districts in our survey 
to help bridge the gap between students and deployed parents. For 
example, a Texas school district highlighted its use of an online 
resource that lets students take assessments aligned to state 
standards and directs them to individualized tutorials to improve 
skills. In addition, parents can monitor their child's progress online 
at home or abroad. According to one school district official, families 
in his district have reported that this program has been a "blessing" 
in helping their children academically. Thirty percent of school 
districts in our survey reported streaming live graduation ceremonies. 
The principal of one school, which sends videotaped graduation 
ceremonies to deployed parents, said the video includes a special 
ceremony for these students and interviews with graduates and their 
families. Thirty percent of districts also reported in our survey 
providing Web-camera interactions with deployed parents. 

Flexible Courses and Credits: 

To address academic standards, which differ among districts, 74 
percent of districts in our survey reported being flexible or taking 
an individualized approach to academic requirements. This may include 
being flexible on testing, course credits, or other requirements to 
meet the needs of incoming military dependent students. Districts in 
Virginia and Colorado made adjustments to requirements for courses and 
standardized testing based on requirements at the previously attended 
school and the point in the school year, for example, allowing seniors 
to use their previous school's graduation requirements. 

Some schools hired extra teachers and staff to help facilitate the 
transition for students. One school district in Colorado created a 
position called an "integrationist" whose sole job was to ease the 
transition of the many transferring military dependent students by 
gathering academic, extracurricular, and personal information about 
them before they arrived to the district, then helping them get into 
the appropriate classes and extracurricular activities. Due to the 
constant influx of new military dependent students, an elementary 
school in Virginia hired extra reading support specialists to work 
individually with children who enter the school with poor reading 
skills. Seventy-two percent of school districts we surveyed reported 
using literacy coaches to assist military dependent students. Military 
parents we interviewed in Virginia noted that of everything the school 
did for military children, this extra and individualized academic 
support was the most appreciated. 

About half the districts in our survey highlighted their state's 
participation in the Interstate Compact on Educational Opportunity for 
Military Children as an effective strategy to address some of the 
challenges related to mobility and academics. As of October 2010, 35 
states had signed this agreement, which sets forth expectations for 
participating states to address key transition issues encountered by 
military families, including enrollment, placement, attendance, 
eligibility, and graduation.[Footnote 33] For example, the compact 
states that school districts will either waive specific courses 
required for graduation if similar course work has been satisfactorily 
completed in another district or will provide reasonable justification 
for denial. Officials we interviewed in all five states also mentioned 
their state's participation in the compact as a strategy to assist 
with issues related to transition of military dependent students. 

DOD and Education's Collaborative Practices Have Assisted Military 
Dependent Students, Their Schools, and Families: 

DOD and Education have developed and implemented practices that 
facilitate their collaboration on efforts to assist military dependent 
students, their schools, and families. In our previous work, we have 
identified practices that help enhance and sustain interagency 
collaboration. These practices include articulating common objectives 
and resources, agreeing on compatible operating procedures and 
responsibilities, and reinforcing accountability through monitoring. 
[Footnote 34] The agencies have worked together, for example, to 
distribute guidance to schools on best practices for addressing 
military dependent students' needs and to assist school districts 
located in areas experiencing influxes of military families. 

DOD and Education officials have a history of collaborating on 
education issues for children of military families through the Impact 
Aid programs and formalized and broadened these efforts with a 
memorandum of understanding (MOU) they signed in June 2008. The MOU 
identifies five focus areas for collaboration: 

1. Quality education. Share educational best practices at schools 
serving military dependent students, and implement policies to support 
those with special needs. 

2. Student transition and deployment. Encourage school district and 
state policies that minimize the impact of military dependent 
students' frequent moves and parental deployments. 

3. Data. Consider approaches for the collection, disaggregation, and 
analysis of education data on military dependent students. 

4. Communication and outreach. Devise joint communication strategies 
to reach parents, educators, students, and military leaders about 
resources available from DOD and Education. 

5. Resources. Support school districts affected by military growth 
through the DOD and Education Impact Aid programs, as well as other 
programs. 

To address these five areas, DOD and Education outlined 13 specific 
objectives in the MOU, including coordinating the DOD and Education 
Impact Aid programs. (See appendix III for a complete list of the 
objectives.) DOD and Education have carried out a number of 
collaborative activities within the five focus areas. For example, to 
address the area of resources, DOD and Education have collaborated to 
respond to the challenges from the 2005 military base closure and 
realignment actions that the BRAC Commission reported will result in 
55 major closures and realignments by September 2011.[Footnote 35] 
These actions, once completed, would relocate large numbers of 
military families, which in turn will affect an increasing number of 
school districts. Officials from both agencies have made eight joint 
site visits, beginning in 2008, to high-growth military installations 
to better understand the specific education issues arising from 
mission changes and growth. The officials shared their findings with 
cognizant federal agencies, affected state and local governments and 
school districts, and made recommendations for how the districts can 
best prepare for influxes of military dependent students. These 
recommendations included improving coordination between districts and 
federal agencies to better estimate military dependent student growth 
in a district. DOD and Education are also collaborating on a study 
mandated in the National Defense Authorization Act for Fiscal Year 
2010 that required DOD, in consultation with Education, to examine, 
among other things, the educational options available to military 
dependent children who attend schools in need of improvement as 
defined under ESEA. The study was also required to address the 
challenges military parents face in securing quality schooling for 
their children when the schools they attend are identified as needing 
improvement.[Footnote 36] 

To address student transitions and parental deployment, DOD and 
Education issued guidance to school districts about best practices to 
minimize the impact on military dependent students' attendance records 
and academics when they are absent upon a parent's return from 
deployment. Further, DOD, in cooperation with Education, published a 
book for military families and military and school leaders called 
"Students at the Center," which provides information on resources and 
best practices for meeting the needs of military dependent children. 

DOD and Education have also taken steps to improve interagency 
communication and develop compatible operating procedures and 
responsibilities--key elements of effective collaboration identified 
in our prior work. An MOU working group meets monthly and is in the 
process of writing protocols for communication between the agencies. 
In addition, a military liaison position was established at Education 
in 2008 to serve as the primary contact between the agencies for 
coordinating program development, management, and outreach related to 
improving the academic condition of military dependent children. A 
senior DoDEA official said this new position has been beneficial 
because it provides a single point of contact. Education officials 
told us the working group's efforts have increased communication with 
DOD and have led to a better understanding of the needs of children in 
families from all military branches. DOD officials also highlighted 
increased interest by Education officials to visit military 
installations. DOD officials said that prior to the MOU, they had 
working relationships only with officials from Education's Impact Aid 
office; they now have relationships with officials in other offices in 
Education, such as its Office of Special Education and Rehabilitative 
Services and its Office of Elementary and Secondary Education. As a 
result, DOD officials have worked with representatives from those 
offices on several efforts. For example, according to a DOD official, 
Education officials provided technical support to DOD by reviewing 
school districts' applications for the 2009 DoDEA grants, and the 
working group has hosted guest speakers from both Education and DOD. 
In addition, an official from Education's Office of Safe and Drug-Free 
Schools spoke to the group about how its grant programs can assist 
military dependent students, and an official from DOD's Office of the 
Deputy Under Secretary of Defense for Military Community and Family 
Policy spoke to the group about progress on the Interstate Compact. 

In May 2010, the White House announced a Presidential Study Directive 
on Military Family Policy, which requested that executive agencies 
develop a coordinated governmentwide approach to support and engage 
military families. According to senior Education officials, the 
directive has led Education to place an even greater priority on its 
collaborative efforts with DOD. The directive has provided another 
framework under which DOD and Education have worked together to 
improve the quality of education for military dependent children. 
Education developed a work plan that details initiatives the agency 
will undertake to address the goals of the directive. Specifically, 
senior Education officials have also visited military communities and 
schools to raise awareness of the challenges military dependent 
children face and the contributions their families make to the 
country. In addition, Education proposed that priority be given to its 
competitive grant proposals that could benefit military dependent 
students. 

The working group monitors its progress through a strategic plan 
developed in 2010 that aligns the MOU's five focus areas for 
collaboration with initiatives the working group has accomplished or 
plans to carry out. Our prior work has found monitoring to be a key 
practice for effective interagency collaboration because it allows 
agencies to obtain feedback and improve effectiveness. DOD and 
Education officials told us the strategic plan helps them to examine 
and prioritize their areas of collaboration to plan for future 
efforts, and reflect on the extent to which they are meeting the 
original intent of the MOU. For example, to address the focus area of 
student transition and deployment, working group members outlined 
plans in their strategic plan for a resource guide about best 
practices for school attendance. As a result of their work, they 
contributed to a pamphlet, published by the Military Child Education 
Coalition in 2010, called "Military-Connected Students and Public 
School Attendance Policies" that is meant to assist school 
administrators, base commanders, and parents. Specifically, the 
pamphlet includes examples of districts around the country upholding 
their attendance policies while ensuring military dependents receive a 
quality education when absent from school. In addition, for transition 
and deployment, working group members plan to look at installations 
with the highest deployment rates to explore options to mitigate the 
effects of daily attendance requirements for military dependent 
students affected by deployments. 

Conclusions: 

Support for military families, including the education of military 
dependents, has received even greater attention with the May 2010 
announcement of the Presidential Study Directive on Military Family 
Policy. In response, DOD and Education further increased their 
collaboration to provide a quality education and support to military 
dependent children through a variety of activities in addition to DOD 
Impact Aid. Programs such as DOD Impact Aid provide funding to assist 
school districts with a significant percentage of military dependents, 
but the outcomes and effectiveness of their activities are difficult 
to assess. This is due in part to the structure of the DOD Impact Aid 
program, which does not require any reporting on the use of the funds. 
Further, DOD, Education, states, and other parties concerned about the 
education of military dependents lack appropriate data to monitor the 
progress of military dependent students and the effectiveness of the 
schools and programs serving them. Currently, school districts and 
states are not required to collect academic achievement data for 
military dependent students, as they are for certain other groups of 
students, including economically disadvantaged students and students 
with disabilities. Without these data, stakeholders lack critical 
information that could help them better understand the specific needs 
of these students and their educational outcomes over time. 

Recommendation for Executive Action: 

To better understand the needs of military students and the 
effectiveness of strategies to assist them, we recommend the Secretary 
of Education, in collaboration with the Secretary of Defense, 
determine whether to require school districts to identify military 
dependent students as a distinct subgroup for reporting on their 
academic outcomes, such as test scores and high school graduation 
rates. This should include determining whether the Department of 
Education needs to obtain any additional legislative authority for 
this requirement, and seeking it from Congress, if necessary. 

Agency Comments and Our Evaluation: 

We provided a draft of the report to the Departments of Education and 
Defense for review and comment. Education agreed with our 
recommendation and stated that the agency proposed improving the 
collection of data on military dependent students in the upcoming 
reauthorization of ESEA. This proposal is discussed in the 
Administration's January 2011 report, Strengthening Our Military 
Families: Meeting America's Commitment. According to Education, under 
the Administration's proposal, states and school districts that 
receive funds under ESEA Title I, Part A would be required to report 
state-, district-, and school-level aggregate data on the academic 
achievement of military dependent students. DoDEA provided oral 
concurrence with our recommendation. 

Education and DOD both provided technical comments, which have been 
incorporated in the report as appropriate. Education's comments are 
reproduced in appendix IV. 

We are sending copies of this report to the appropriate congressional 
committees, the Secretary of Education, the Secretary of Defense, and 
other interested parties. The report also is available at no charge on 
the GAO Web site at [hyperlink, http://www.gao.gov. 

If you or your staff members 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 major 
contributions to this report are listed in appendix V. 

Signed by: 

George A. Scott: 
Director: 
Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our review focused on (1) what is known about the use and 
effectiveness of Department of Defense (DOD) Impact Aid funds, (2) the 
challenges faced by school districts in serving military dependent 
students and strategies they have in place to address these 
challenges, and (3) how DOD and the Department of Education 
(Education) have coordinated their assistance to districts. 

Survey of School Districts that Received DOD Impact Aid Supplemental 
Funds from 2001 to 2009: 

We designed and implemented a Web-based survey to gather information 
on the use and effectiveness of DOD Impact Aid funds and the 
challenges faced by school districts in serving military dependent 
students. The survey also included questions regarding DOD Impact Aid 
for Children with Severe Disabilities and DOD Impact Aid for Base 
Realignment and Closure. We sent this survey to the 154 school 
districts that have received DOD Impact Aid Supplemental funds in any 
year from 2001 to 2009, the years covered in the mandate. We obtained 
the list of DOD Impact Aid recipients from Education and verified the 
recipients with a list provided by DOD Education Activity (DoDEA). Our 
survey was directed to the school district official identified as the 
point of contact for DOD Impact Aid by DoDEA officials. Most of these 
school district officials were superintendents, assistant 
superintendents, directors of business or finance, or other business 
office employees. 

Process for Developing the Survey Instrument: 

To assess the feasibility of conducting a survey for this report, we 
contacted several school districts to determine whether they would be 
able to respond to questions regarding their spending of DOD Impact 
Aid funds. All districts that we spoke with told us they would be able 
and willing to respond to such a survey. We obtained available data 
from both DOD and Education on the school districts that received DOD 
Impact Aid Supplemental funds in any year from 2001 through 2009, as 
well as a contact person for each district. Drawing from the 
provisions in the mandate, information obtained during site visits to 
school districts, and preliminary interviews with DOD, Education, and 
two nonprofit organizations--the Military Impacted Schools Association 
and the Military Child Education Coalition--we developed survey 
questions. We also sought input on our final draft from the two 
nonprofit organizations, as well as internal GAO stakeholders and a 
survey specialist before conducting pretests. We pretested our survey 
draft with school district officials at four districts that received 
DOD Impact Aid funding in any year from 2001 to 2009 to help ensure 
that the questions were clear, the terms used were precise, the 
questions were unbiased, and the questionnaire could be completed in a 
reasonable amount of time. We modified the survey to incorporate the 
feedback from each pretest. 

The survey contained questions on: (1) general school district 
information, (2) spending tracking, and disbursement of DOD Impact Aid 
funds, (3) perceptions of effectiveness of DOD Impact Aid funding 
sources, and (4) challenges faced by districts with respect to 
military dependent students and strategies to address those 
challenges. The survey also contained questions on DOD's monitoring of 
funds, a specific provision in the mandate regarding the conversion of 
military housing to private housing (see appendix II), and DOD and 
Education technical assistance or guidance to school districts. 

Administration Method for Survey: 

We conducted the survey by using a Web-based self-administered 
questionnaire. In the questionnaire, we asked the school district 
officials to be the lead survey respondent and to consult with others 
in the district who may be more knowledgeable on questions related to 
challenges associated with educating military dependent students. We 
collected contact information for these school district officials from 
DoDEA and through searches of these districts' Web sites. We verified 
the contact information by sending notification e-mails and calling 
districts for the correct contact information in cases where the e-
mail was undeliverable. We sent the survey activation e-mail to these 
officials on July 28, 2010, and then asked them to complete the survey 
within 3 weeks. To encourage them to respond, we sent three follow-up 
e-mails over a period of about 4 weeks and extended our survey 
deadline to September 13, 2010. Staff made phone calls over the next 2 
weeks to encourage those who did not respond to complete our 
questionnaire. We closed our survey on September 24, 2010, and 118 
school districts completed the survey for a response rate of 77 
percent.[Footnote 37] 

Efforts to Minimize Nonsampling Errors: 

The practical difficulties of conducting any survey may also introduce 
errors commonly referred to as nonsampling errors. For example, 
difficulties in the way a particular question is interpreted, the 
sources of information that are available to respondents, or the way 
the data were analyzed can introduce unwanted variability into the 
survey results. We took steps in the development of this 
questionnaire, in the data collection, and in the data analysis to 
minimize such errors. Specifically, a survey specialist designed the 
questionnaire in collaboration with two staff members who were 
familiar with the subject matter. Then, as previously mentioned, the 
draft questionnaire was pretested with four school districts to ensure 
that questions were relevant, clearly stated, and easy to comprehend. 
The questionnaire was also reviewed by officials from two military 
education advocacy organizations. Data analysis was conducted by a 
data analyst working directly with the staff who developed the survey. 
When the data were analyzed, a second independent data analyst checked 
all computer programs for accuracy. Since this was a Web-based survey, 
respondents entered their answers directly into the electronic 
questionnaires. This eliminated the need to have the data keyed into 
databases, thus removing an additional source of error. 

Site Visits to Selected States and School Districts: 

To identify the challenges school districts face in educating military 
dependent students and the strategies they have implemented, we 
conducted site visits to four districts in two states (Colorado and 
Virginia) and phone calls with three districts in three states 
(California, Missouri, and Texas). We chose these districts based on 
recommendations from DOD, the Military Impacted Schools Association, 
and the Military Child Education Coalition. We strove to achieve 
diversity in geographic location, school district size, and percent of 
district made up of military dependents from different branches of 
military service. (See table 3 below for more information on the 
districts we interviewed.) The findings from these five states and 
seven districts cannot be projected nationwide, but we believe they 
illustrate valuable perspectives on the challenges of serving military 
dependent students, and assistance from DOD and other sources to help 
address the challenges. During the visits we interviewed 
superintendents, assistant superintendents, budget office officials, 
guidance counselors, and, in some locations, military school liaisons, 
teachers, and students. In one school district, we also met with a 
group of parents. We also toured schools and obtained documents. 
Interviewees provided information on the unique challenges faced by 
military students and families and the strategies schools employ to 
respond to those challenges from their varying perspectives. 

Table 2: School Districts Interviewed in Five Selected States: 

Completed in person: 

District: York, VA; 
Branch of military: Navy and Air Force; 
Region: East; 
Size (in students): 12,800; 
Percent Military Impacted: 37%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $791,861. 

District: Virginia Beach, VA; 
Branch of military: Navy; 
Region: East; 
Size (in students): 71,300; 
Percent Military Impacted: 29%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $2,245,761. 

District: Ft. Carson, CO; 
Branch of military: Army; 
Region: Mountain; 
Size (in students): 6,200; 
Percent Military Impacted: 68%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $884,550. 

District: Falcon, CO; 
Branch of military: Air Force and Army; 
Region: Mountain; 
Size (in students): 12,800; 
Percent Military Impacted: 23%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $211,776. 

Completed via telephone: 

District: Burkburnett, TX; 
Branch of military: Air Force; 
Region: South; 
Size (in students): 3,700; 
Percent Military Impacted: 33%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $249,877. 

District: Waynesville, MO; 
Branch of military: Army; 
Region: South; 
Size (in students): 5,300; 
Percent Military Impacted: 74%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $709,099. 

District: Central Union, CA; 
Branch of military: Navy; 
Region: West; 
Size (in students): 2,000; 
Percent Military Impacted: 64%; 
Fiscal year 2009 DOD Impact Aid Supplemental funding: $407,397. 

Source: GAO based on data from DOD. 

[End of table] 

Literature Review: 

We conducted a review of the literature on military dependent student 
challenges and the strategies schools employ to respond to these 
challenges. We searched for literature using appropriate search terms 
such as "military dependent education" and "public school" in a 
variety of research databases. A social scientist assisted us in 
assessing the reliability and validity of these studies for our 
purposes. In the report, we present some examples from the literature 
to illustrate our findings. In addition, we reviewed prior GAO reports 
on elementary and secondary education, military restructuring, and 
practices that can help to enhance collaboration. 

Interviews with Agency Officials and Other Organizations: 

To review DOD and Education's efforts to implement DOD Impact Aid and 
to collaborate to serve military dependent students, we interviewed 
appropriate officials at DoDEA, and in offices at Education, which 
included the Office of Impact Aid; the Office of Innovation and 
Improvement; the Office of Planning, Evaluation, and Policy 
Development; and the Office of the Secretary, as well as 
representatives from the Military Impacted Schools Association and the 
Military Child Education Coalition, two organizations focused on 
military dependent education. We reviewed relevant federal laws and 
regulations. We also reviewed agency documentation, such as the 
memorandum of understanding (MOU) between DOD and Education, their 
strategic plan for implementing the MOU, and budget documentation for 
the DOD Impact Aid program and other DOD programs. 

[End of section] 

Appendix II: Information on Additional Mandate Provisions: 

The National Defense Authorization Act for Fiscal Year 2010 mandated 
us to examine 17 separate provisions in various Defense Authorization 
Acts from fiscal years 2001 to 2009.[Footnote 38] We addressed all but 
three of the provisions in the main body of the report.[Footnote 39] 
Here we provide our findings on the remaining three provisions of the 
mandate. 

Grant program for repair, renovations, and maintenance. The 2001 
Defense Authorization Act authorized a grant program for repair, 
renovations, and maintenance of certain school facilities. Funding was 
to come from appropriations made for "Quality of Life Enhancements, 
Defense-Wide." In fiscal year 2001, $10.5 million was authorized and 
appropriated for that appropriations category. DOD allocated these 
funds, but could not provide more details about the use of these 
funds.[Footnote 40] 

Continuing Impact Aid after deployment or death of a parent or 
guardian. This special rule was enacted to cover school years 2004-
2005 and 2005-2006 so that Impact Aid would not be reduced in those 
districts where a local educational agency would normally lose funding 
as a result of the deployment or death of a parent or legal guardian 
on active duty. Children who resided on federal property and whose 
parents or legal guardians were deployed or died during that period 
were still counted for funding purposes.[Footnote 41] School district 
officials told us they have had no difficulties counting students 
whose parents or guardians had been deployed or who had died. An 
official from the Military Impacted Schools Association explained that 
this rule adequately addressed any problems experienced in the past. 

Extending eligibility for Impact Aid where military housing is 
converted to private housing. This provision, enacted in fiscal year 
2003, extends eligibility for a limited period of time to heavily 
impacted school districts that received a basic support payment in the 
prior fiscal year, but would subsequently be deemed ineligible as a 
result of the conversion of military to private housing. The provision 
extends eligibility during the period of conversion.[Footnote 42] 
School districts we interviewed and an official from the Military 
Impacted Schools Association did not mention any issues with regard to 
this provision. 

[End of section] 

Appendix III: The 13 Objectives from Education and DOD's MOU: 

Education and DOD's MOU identified 13 objectives to guide their 
collaborative efforts. 

1. Promote and enhance policies that will improve military children's 
education and overall well-being. 

2. Advance the quality of educational opportunities for all military 
children. 

3. Provide research-based academic, social-emotional and behavioral 
supports to facilitate seamless transitions for military children. 

4. Provide leadership and advocacy programs to help military students 
cope with issues surrounding deployments. 

5. Support foreign language education, including programs for 
strategic languages. 

6. Assist military parents to be informed advocates of quality 
education choices. 

7. Explore legislative options to address transition issues for 
military children. 

8. Extend opportunities for student learning through support of online 
or virtual and other research-based models. 

9. Provide research-based teacher and administrator professional 
development programs. 

10. Forge effective partnerships with schools and districts. 

11. Coordinate the DOD and Education Impact Aid programs. 

12. Communicate with military families and organizations to show 
appreciation for their contributions. 

13. Increase awareness of resources and tools available from Education 
and DOD. 

[End of section] 

Appendix IV: Comments from the Department of Education: 

United States Department of Education: 
Office of Innovation and Improvement: 
400 Maryland Avenue, SW: 
Washington, DC 20202: 

January 27. 2011: 

Mr. George A. Scott: 
Director, Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Scott: 

I am writing in response to the recommendation made in the Government 
Accountability Office (GAO) draft report, "Military Dependent 
Students: Better Information Needed to Assess Student Performance" 
(GAO-11-231). I appreciate the opportunity to comment on the draft 
report on behalf of the Department of Education. 

We appreciate GAO's thorough review of the unique needs of military 
dependent students and the steps the Department of Education and the 
Department of Defense have taken to better serve them. The Department 
shares the concern, outlined in the report, that some military 
students may struggle academically as a result of varied academic 
standards from state to state and a lack of connection to the school 
community resulting from their mobility. Further, while many students 
adapt amazingly well given the challenges facing military families, 
both mobility and the stress of parent deployment may lead to higher 
rates of emotional difficulties. 

The report had one recommendation for the Secretary of Education, 
which we have excerpted below with our response. 

Recommendation: To better understand the needy of military students 
and the effectiveness of strategies to assist them, we recommend the 
Secretary of Education, in collaboration with the Secretary of 
Defense, determine whether to require school districts to identify 
military dependent students as a distinct subgroup for reporting on 
their academic outcomes, such as test scores and high school 
graduation rates. This should include determining whether the 
Department of Education needs to obtain any additional legislative 
awhority for this requirement, and seeking it from Congress, if 
necessary. 

Response: The Department agrees that better data on the student 
achievement of military dependent students would be beneficial in 
better serving this unique student population. In the recently 
released report, Strengthening Our Military, Families: Meeting 
America's Commitment, the Administration proposed improving the 
collection of those data through the reauthorization of the Elementary 
and Secondary Education Act of 1965 (ESEA). Under the Administration's
proposal, states and school districts that receive funds under ESF,A 
Title 1, Part A would be required to report state-, district-, and 
school-level aggregate data on the academic achievement of military 
dependent students. As with requirements in current law related to 
reporting of student academic achievement data by gender and migrant 
status, these data would be publicly reported but would not be used 
for Title I accountability purposes. 

We appreciate the opportunity to review the draft report and comment 
on the recommendations. I am also enclosing one technical comment. 

Sincerely, 

Signed by: 

James H. Shelton, III: 
Assistant Deputy Secretary for Innovation and Improvement: 

Enclosure: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George A. Scott, (202) 512-7215 or scottg@gao.gov: 

Staff Acknowledgments: 

Individuals making key contributions to this report include: Beth 
Sirois (Assistant Director), Kate Blumenreich (Analyst-in-Charge), 
Griffin Glatt-Dowd, and Karen Febey. Blake Ainsworth, Susan Aschoff, 
Cornelia Ashby, James Bennett, Michele Fejfar, Cathy Hurley, Julian 
Klazkin, Sheila McCoy, Kelly Rubin, and Kim Siegal also provided 
valuable assistance. 

[End of section] 

Footnotes: 

[1] In addition, military dependent students also include dependents 
of civilian employees of the Department of Defense. 

[2] Funding is provided to local educational agencies, which we refer 
to as school districts for the purposes of this report. 

[3] Pub. L. No. 111-84, § 538, 123 Stat. 2190, 2294-95. 

[4] These three research objectives cover all but three of the 
required components of the mandated audit. Appendix II provides our 
findings on the remaining components of the mandate. 

[5] DOD, Educator's Guide to the Military Child During Deployment. 

[6] 20 U.S.C. §§ 7701 et seq. 

[7] ESEA Title VIII authorizes several types of Impact Aid payments. 
These include payments relating to federal acquisition of real 
property, payments for education of federally connected children, and 
payments for construction and maintenance of school facilities. 20 
U.S.C. §§ 7702, 7703, 7707, 7708. 

[8] Federally connected children include children who have a parent on 
active duty in the uniformed services, reside on federal property with 
a parent who is an accredited foreign military officer, reside on 
Indian lands, reside in low-rent housing, or reside on federal 
property with a parent employed on federal property situated in whole 
or part in the local school district. 20 U.S.C. § 7703(a)(1). Every 
student in the U.S. public school system is asked to take home an 
Impact Aid form that their parents or guardians are to use to identify 
them as federally connected or not. School districts send this 
information to Education, which determines Education and DOD Impact 
Aid formula amounts. School districts must have at least 400 federally 
connected children, or such children must represent at least three 
percent of the district's average daily attendance, for the district 
to be eligible for Education Impact Aid funding. 20 U.S.C. § 
7703(b)(1)(B). 

[9] 20 U.S.C. § 7703b(a)(2). The requirement, added in 2006, is 20 
percent "as rounded to the nearest whole percent." Therefore, the 
actual requirement could be as low as 19.5 percent. 

[10] DOD could not provide us with the amount awarded in fiscal year 
2001. 

[11] 20 U.S.C. § 7703a. According to the application for this program, 
children with severe disabilities means children with disabilities 
who, because of the intensity of their physical, mental, or emotional 
problems, need highly specialized education, social, psychological, 
and medical services in order to maximize their full potential for 
useful and meaningful participation in society and self-fulfillment. 
The term includes children with severe emotional disturbances, autism, 
severe and profound mental retardation, and those who have two or more 
serious disabilities such as blindness, deafness, and cerebral palsy. 

[12] Education provides DOD with information on the school districts 
that have at least two military dependent students with severe 
disabilities and DOD notifies school districts of their eligibility to 
apply for Children with Severe Disability funds. 

[13] Payments were authorized for this program beginning in fiscal 
year 2002. Floyd D. Spence National Defense Authorization Act for 
Fiscal Year 2001. Pub. L. No. 106-398, appendix § 363, 114 Stat. 1654, 
1654A-77,78. 

[14] See Duncan Hunter National Defense Authorization Act for Fiscal 
Year 2009, Pub. L. No. 110-417, § 553, 122 Stat. 4356, 4469. 

[15] The Air Force does not have budgetary data available because the 
School Liaison Officer program was funded at the local level through 
the installations until fiscal year 2011. 

[16] This program was established in accordance with the John Warner 
National Defense Authorization Act for Fiscal Year 2007, Pub. L. No. 
109-364, § 575, 120 Stat. 2083, 2227-29, which authorized DOD to 
establish a 3 year pilot program to promote early childhood education 
for dependent children affected by military deployment or relocation 
of military units. 

[17] 20 U.S.C. §§ 6311-39. 

[18] 20 U.S.C. §§ 1400-1491o. 

[19] Nine school districts responding to our survey reported receiving 
DOD Impact Aid assistance for significant enrollment changes due to 
BRAC. Most explained that they spent these funds on general education 
expenses, including instructional staff, facilities, and classroom 
materials. 

[20] Special revenue funds include proceeds that are restricted to 
certain uses by statute. 

[21] The number of school districts responding to each item varied. 

[22] In fiscal year 2009, 22 of the 110 school districts that received 
DOD Impact Aid Supplemental funding were awarded more than $500,000. 

[23] Congress passed the Single Audit Act, as amended, 31 U.S.C. ch. 
75, to promote, among other things, sound financial management, 
including effective internal controls, regarding federal awards 
administered by nonfederal entities. The Single Audit Act requires 
states, local governments, and nonprofit organizations expending 
$500,000 or more in federal awards in a year to obtain an audit in 
accordance with the requirements set forth in the act. We have 
previously reported on a number of concerns with the Single Audit 
process and, accordingly, have issued recommendations to the Office of 
Management and Budget in this area. See GAO, Recovery Act: 
Opportunities to Improve Management and Strengthen Accountability over 
States' and Localities' Uses of Funds, [hyperlink, 
http://www.gao.gov/products/GAO-10-999], (Washington, D.C.: Sept. 20, 
2010) and Single Audit: Opportunities Exist to Improve the Single 
Audit Process and Oversight, [hyperlink, 
http://www.gao.gov/products/GAO-09-307R] (Washington, D.C.: Mar. 13, 
2009). 

[24] For smaller districts (those with fewer than 8,000 students), DOD 
Impact Aid Supplemental funds made up, on average, 2.1 percent of 
their overall 2009-2010 budget, whereas the funds made up, on average, 
0.4 percent of the overall 2009-2010 budget for larger districts 
(those with 8,000 or more students). 

[25] See American Recovery and Reinvestment Act of 2009, Pub. L. No. 
111-5, 123 Stat. 115. For more information, see [hyperlink, 
http://www.gao.gov/products/GAO-10-999]. 

[26] Of the remaining 34 percent of school district officials 
responding, 16 percent somewhat agreed, 7 percent neither agreed nor 
disagreed, 1 percent strongly disagreed, and 10 percent either did not 
know or did not answer. 

[27] Of the remaining 33 percent of school district officials 
responding, 13 percent somewhat agreed, 7 percent neither agreed nor 
disagreed, 5 percent somewhat disagreed, and 9 percent either did not 
know or did not answer. These results exceed 100 percent due to 
rounding. 

[28] The No Child Left Behind Act of 2001 (Pub. L. No. 107-110, 115 
Stat. 1425 (2002)) introduced the requirement that states develop 
plans that include academic standards and establish performance goals 
for making adequate yearly progress that would lead to 100 percent of 
their students being proficient in reading, mathematics, and science 
by 2014. Each school's assessment data must be disaggregated in order 
to compare the achievement levels of students within certain 
designated groups-economically disadvantaged students, major racial 
and ethnic groups, students with disabilities, and English language 
learners-with the state's proficiency targets. Each of these groups 
generally must make adequate yearly progress in order for the school 
to make adequate yearly progress. See 20 U.S.C. § 6311(b)(2)(C)(v)(II). 

[29] GAO, K-12 Education: Many Challenges Arise in Educating Students 
Who Change Schools Frequently, [hyperlink, 
http://www.gao.gov/products/GAO-11-40] (Washington, D.C.: Nov. 18, 
2010). 

[30] Anita Chandra, Sandraluz Lara-Cinisomo, Lisa H. Jaycox, Terri 
Tanielian, Rachel M. Burns, Teague Ruder, and Bing Han (RAND Corp.), 
"Children on the Homefront: The Experience of Children From Military 
Families," Pediatrics, vol. 125, no. 1 (January 2010): 13-22. 

[31] GAO, Teacher Preparation: Multiple Federal Education Offices 
Support Teacher Preparation for Instructing Students with Disabilities 
and English Language Learners, but Systematic Departmentwide 
Coordination Could Enhance this Assistance, [hyperlink, 
http://www.gao.gov/products/GAO-09-573] (Washington, D.C.: July 20, 
2009). 

[32] 20 U.S.C. § 7703a. 

[33] The Interstate Compact on Educational Opportunity for Military 
Children was developed in 2008 by DOD with the assistance of the 
Council of State Governments. The council is a region-based forum that 
fosters the exchange of ideas to help state officials shape public 
policy. 

[34] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005). 

[35] Beginning in fiscal year 2007, DOD was required to submit a 
report each year to Congress detailing its plans to assist school 
districts experiencing a growth in military dependent student 
enrollment due to base realignment or closures. DOD provided us with 
four reports submitted to Congress between fiscal years 2007-2010 that 
provide the required information. See John Warner National Defense 
Authorization Act for Fiscal Year 2007, Pub. L. No. 109-364, § 574, 
120 Stat. 2083, 2226-27. 

[36] Pub. L. No. 111-84, § 537(a), 123 Stat. 2190, 2293-4. 

[37] Ten school districts reported that they did not receive DOD 
Impact Aid Supplemental funding in any year from 2001 through 2009 and 
were removed from data analysis. 

[38] Pub. L. No. 111-84, § 538, 123 Stat. 2190, 2294-95. 

[39] Of the provisions of the mandate, one was a duplicate of another 
and two others covered the same program extension, but during 
different years. Where appropriate, we grouped them together resulting 
in three provisions that we did not address. 

[40] See Department of Defense Appropriations Act, 2001, Pub. L. No. 
106-259, 114 Stat. 656, 664; and National Defense Authorization Act of 
2001, Pub. L. No. 106-398, § 364, 114 Stat. 1654, 1654A-52,53, 78-80. 

[41] See National Defense Authorization Act for Fiscal Year 2006, § 
574, 119 Stat. 3136, 3273-3274; and Ronald W. Reagan National Defense 
Authorization Act for Fiscal Year 2005, § 558, 118 Stat. 1811, 1916. 

[42] See Bob Stump National Defense Authorization Act for Fiscal Year 
2003, Pub. L. No. 107-314, § 344, 116 Stat. 2458, 2515-2516. 

[End of section] 

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