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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
July 2011:
School Improvement Grants:
Early Implementation Under Way, but Reforms Affected by Short Time
Frames:
GAO-11-741:
Contents:
Letter:
Recommendation for Executive Action:
Agency Comment:
Appendix I: Briefing Slides:
Appendix II: Comments from the Department of Education:
Appendix III: GAO Contact and Staff Acknowledgments:
Abbreviations:
Education: U.S. Department of Education:
ESEA: Elementary and Secondary Education Act:
FY: fiscal year:
Recovery Act: American Recovery and Reinvestment Act of 2009:
SIG: School Improvement Grant:
SY: school year:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 25, 2011:
Congressional Requesters:
The School Improvement Grants (SIG) program, which was created in
2002, funds reforms in the country's lowest-performing schools with
the goal of improving student outcomes, such as standardized test
scores and graduation rates. Congress greatly increased SIG program
funding from $125 million available in fiscal year 2007--the first
year the program was funded--to $3.5 billion in fiscal year 2009 for
the 2010-11 school year. Three billion dollars of this amount was
provided by the American Recovery and Reinvestment Act of 2009
(Recovery Act).[Footnote 1] In addition, $546 million was appropriated
in both fiscal years 2009 and 2010, and $535 million was appropriated
in fiscal year 2011. These funds were provided to states by formula
after the Department of Education (Education) approved state SIG grant
applications.
The funding increases provided by the Recovery Act spurred Education
to make substantive changes to the SIG program. For example, the
persistently lowest-achieving schools receiving SIG funding must now
implement one of four intervention models, each with specific
requirements for reform interventions, such as replacing principals or
turning over school management to a charter organization or other
outside organization.[Footnote 2] Also, after states receive their
grants, states are required to award subgrants to school districts
competitively, rather than by formula. State educational agencies
evaluate grant applications using several criteria, including the
school's proposed intervention model and the district's budget and
reform implementation plan, as well as their capacity to implement the
reforms effectively. Under the SIG program, a school may receive up to
$2 million annually for 3 years to improve student outcomes.
You requested that GAO conduct a broad review of the SIG program.
[Footnote 3] On the basis of your request, this report provides
preliminary information on the following questions:
* How have selected states administered the SIG program for grants
starting in school year (SY) 2010-11?
* What factors influenced the implementation of SIG interventions in
selected schools during SY 2010-11?
* How has Education provided oversight of SIG implementation and
measured performance to date?
To determine how selected states have administered the SIG program, we
selected a sample of six states based on several criteria, including
population size, use of different intervention models, population
density, and the number of districts and schools awarded SIG grants.
Our findings address only the six states we visited and are not
generalizable to all states. In each of the six states--Delaware,
Nebraska, Nevada, Ohio, Rhode Island, and Virginia--we reviewed
documents and interviewed state officials and representatives from one
to three districts with Tier I or II schools receiving SIG funds in
each state. Districts were selected to represent certain
characteristics, such as a range of population density and use of
different intervention models. The documents we reviewed included
state and district SIG applications and documentation of SIG renewal
procedures. In two of these states, Ohio and Virginia, we interviewed
SIG school principals. We also interviewed Education officials with
responsibility for SIG implementation and stakeholders--including
national and local unions, external providers, and others--about their
views on the SIG program. To identify factors that influenced the
implementation of SIG interventions in selected SIG schools, we
reviewed district documentation of SIG implementation efforts and
interviewed district and school officials. We also reviewed federal
laws, regulations, and guidance related to SIG, and interviewed
Education officials and stakeholders. To determine how Education has
provided oversight and performance measurement to date, we reviewed
SIG monitoring protocols and other Education documents, and
interviewed Education and state officials. We determined that the data
we used in the report were sufficiently reliable for the purposes of
the report.
We conducted this performance audit from January to July 2011 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
On July 21, 2011, we briefed committee staff on the preliminary
results of this study, and this report formally conveys the
information provided during this briefing (see appendix I for the
briefing slides). In summary, our nongeneralizable sample and other
evidence suggests the following:
* Among the selected states, some implemented SIG more rigorously than
others. States with selective competitions funded only those district
applications they identified as the strongest, and thus may be
positioned for better student achievement outcomes. In contrast, other
states awarded grants to all eligible Tier I and II schools that
applied. States also varied in how they designed their grant renewal
processes.
* Local capacity and short time frames affected schools' ability to
implement SIG interventions in many of the states we visited. Local
capacity--such as the ability to attract and retain administrative
staff with school turnaround expertise or high-quality teachers--
influenced implementation, and SIG interventions were often
challenging for low-capacity districts. Education and state officials
told us time frames for planning and implementing interventions were
challenging in SY 2010-11 because, in some cases, state applications--
which were due in February 2010--were not approved by Education until
summer 2010. State and district officials told us that late approval
of applications resulted in some SIG interventions not being
implemented by the start of SY 2010-11. Despite Education's efforts to
address these issues, late approval of state applications has remained
an issue for SY 2011-12. For example, as of late June 2011 six states
had not received approval of their SIG applications. Education
officials told us that in many of these situations, states had
submitted applications late. Although Education officials recognized
the continuing challenges with SIG time frames, they have not yet
identified steps to address these issues.
* Education oversees SIG and plans to collect school performance data.
The agency uses several strategies, such as reviewing state
applications and monitoring, to oversee state and district SIG
implementation. In addition, Education plans to analyze performance
data from SIG schools to identify high-quality practices.
Recommendation for Executive Action:
To provide districts and schools more time to successfully plan and
implement SIG reforms, we are recommending that the Secretary of
Education should do the following:
* Consider options to have SIG grants awarded to districts earlier,
such as using an earlier deadline for state applications or approving
state applications that include timelines for earlier awards to
districts.
Agency Comments and Our Evaluation:
We provided a draft copy of this report to Education for review and
comment. The full text of Education's comments is reprinted in
appendix II.
Education generally agreed with our recommendation to consider options
to have SIG grants awarded to school districts earlier. They said they
are currently reviewing the most recent state application process to
determine how they could facilitate future application reviews.
Education also provided some additional information about challenges
rural school districts face with SIG. Specifically, they provided data
about these districts' ability to apply and be competitive for SIG
funds. We modified the report language to reflect the data they
provided. In addition, Education provided information about recent
steps they have taken to use SIG implementation data to improve their
technical assistance efforts. We modified language in the report as
appropriate. Education also provided us with several technical
comments that we incorporated as appropriate.
We will send copies of this report to relevant congressional
committees, the Secretary of Education, and other interested parties.
In addition, this report will be available at no charge on GAO's
website at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to
this report are listed in appendix III.
Signed by:
George A. Scott:
Director Education, Workforce, and Income Security Issues:
List of Requesters:
The Honorable Thad Cochran:
Vice Chairman:
Committee on Appropriations:
United States Senate:
The Honorable Tom Harkin:
Chairman:
The Honorable Richard C. Shelby:
Ranking Member:
Subcommittee on Labor, Health and Human Services, Education, and
Related Agencies:
Committee on Appropriations:
United States Senate:
[End of section]
Appendix I: Briefing Slides:
School Improvement Grants: Early Implementation Under Way, but Reforms
Affected by Short Time Frames:
Briefing to Congressional Requesters:
July 21, 2011:
Overview:
* Introduction;
* Research Objectives;
* Scope and Methodology;
* Summary of Findings;
* Background;
* Findings;
* Conclusions;
* Recommendations.
Introduction:
School Improvement Grants (SIG) Provide Schools up to $6 Million Each
Over 3 Years to Improve Student Outcomes:
* SIG funds reform efforts in some of country's lowest achieving
schools.
* SIG grants made to states by formula.
* SIG was authorized in 2002 with the reauthorization of the
Elementary and Secondary Education Act of 1965 (ESEA). It was first
funded in 2007 and expanded and modified in 2009 to:
- require state educational agencies to award grants by competition;
- provide each school up to $2 million per year for 3 years;[Footnote
4] and;
- require districts to implement one of four intervention models in
persistently lowest-achieving schools that are funded.
Research Objectives:
1) How have selected states administered SIG for grants starting in
school year (SY) 2010-11?
2) What factors influenced the implementation of SIG interventions in
selected schools during SY 2010-11?
3) How has the Department of Education (Education) provided oversight
of SIG implementation and measured performance to date?
Scope and Methodology:
To address our objectives, we:
* reviewed documents and interviewed state officials and officials in
1 to 3 SIG districts within 6 states (Delaware, Nebraska, Nevada,
Ohio, Rhode Island, Virginia), selected based on population, use of
intervention models, population density, and number of districts and
schools awarded SIG grants;
* reviewed relevant federal laws, regulations, program guidance, and
other documents;
* interviewed officials from Education, national and local unions,
external providers, and other stakeholders.
Our findings address only the 6 selected states and are not
generalizable to all states.
We determined that the data were sufficiently reliable for the
purposes of the report.
We conducted our review between January and July 2011 in accordance
with generally accepted government auditing standards.
Summary of Findings:
* Among Selected States, Some Implemented SIG More Rigorously Than
Others.
* Limited Capacity, Challenges in Rural Areas, and Short Time Frames
Affected School Reform.
* Education Uses a Variety of Strategies to Oversee SIG and Plans
Additional Data Collection.
Background: SIG Has Been Funded Through Regular Appropriations
and the Recovery Act:
Figure: Refer to PDF for image: horizontal bar graph]
Fiscal year: 2009;
Funding distribution to schools: Funds that schools began receiving in
SY 2010-11:
From the Recovery Act: $3 billion;
From regular appropriations: $546 million.
Total: $3.546 billion.
Fiscal year: 2010;
Funding distribution to schools:
Funds that additional schools will begin receiving in SY 2011-12: $546
million.
Fiscal year: 2011;
Funding distribution to schools:
Funds that Education plans to award to states for SY 2012-13: $535
million.
Source: U.S. Department of Education website and guidance.
[End of figure]
States Are Required to Competitively Award Grants to Districts:
States identify and prioritize eligible schools into 3 tiers:
* Tier I schools: receive priority for SIG funding; are state's lowest-
achieving 5 percent of Title I schools (or 5 lowest-achieving schools,
whichever number is greater) in improvement status;[Footnote 5]
* Tier II schools: secondary schools eligible for, but not receiving,
Title I funds with equivalently poor performance as Tier I schools; and
* Tier III schools: Title I schools in improvement status that are not
Tier I or Tier II schools.
States are required to manage district competitions for SIG funds in
which they evaluate school district applications based on factors such
as the district's capacity to implement reforms.
To receive funding, districts must, among other things, identify which
of four intervention models (Transformation, Turnaround, Restart,
Closure) they will implement in each Tier I and II school.
Education, States, Districts, and Schools Have Key Roles in SIG Award
and Implementation Process:
[Figure: Refer to PDF for image: illustration]
Education: Reviews and approves each state's procedures for awarding
and monitoring grants to districts;
State: State educational agencies review district applications and
competitively award grants;
Districts and schools: Districts apply to state to receive a SIG award.
Education: Education provides technical assistance to states and
monitors implementation in select states each year;
State: State provides technical assistance and monitors grant
implementation;
Districts and schools: Selected districts and schools implement 3-year
grants.
State: State decides whether to renew grants at the end of each year,
using process approved by Education;
Districts and schools: Renewal for Year 1, Year 2, Year 3.
Source: GAO analysis.
[End of figure]
Table: Transformation Model Requires Replacing the Principal and
Extending Learning Time[A]:
Teachers and school leaders:
* Replace principal;
* Implement new evaluation system:
- Developed with staff;
- Uses student growth as significant criteria;
* Identify and reward staff who are increasing student incomes;
support and then remove those who are not;
* Implement strategies to recruit, place and retain staff;
Time and support:
* Provide increased learning time for staff and students;
* Provide ongoing mechanism for community and family engagement;
* Partner to provide social-emotional and community-oriented services
and supports;
Instructional and support strategies:
* Select and implement an instructional model based on student needs;
* Provide job-embedded professional development designed to build
capacity and support staff;
* Ensure continuous use of data to inform and differentiate
instruction;
Governance:
* Provide school with sufficient operating flexibility to implement
reform;
* Ensure ongoing technical assistance.
Source: U.S. Department of Education.
[A] In some cases, Education allows flexibility where a district has
implemented in whole or in part one of the requirements of the model
within the last 2 years.
[End of table]
Table: Turnaround Model Requires Rehiring No More Than 50 Percent of
Staff[A]
Teachers and school leaders:
* Use locally adopted "turnaround" competencies to review and select
staff;
* Rehire no more than 50 percent of existing staff;
* Replace principal;
* Implement strategies to recruit, place and retain staff;
Time and support:
* Provide increased learning time for staff and students;
* Provide social-emotional and community-oriented services and
supports;
Instructional and support strategies:
• Select and implement an instructional model based on student needs;
* Provide job-embedded professional development designed to build
capacity and support staff;
* Ensure continuous use of data to inform and differentiate instruction
Governance:
* Implement new school governance structure;
* Grant operating flexibility to school leader.
Source: U.S. Department of Education.
[A] In some cases, Education allows flexibility where a district has
implemented in whole or in part one of the requirements of the model
within the last 2 years.
[End of table]
Restart and Closure Model Requirements:
Restart:
District must reopen school under management of external provider
(charter school operator, charter management organization, or
education management organization).
School Closure:
District must close school and enroll students in higher achieving
schools within reasonable proximity.
Figure: Most Funded Tier I and II SIG Schools Implemented
Transformation Model in SY 2010-11:
[Refer to PDF for image: pie-chart]
Transformation: 74%: 603 schools;
Turnaround: 20%: 168 schools;
Restart: 4%: 33 schools;
Closure: 2%: 16 schools.
Note: These data include complete information from all states but
Hawaii and Rhode Island. Districts with nine or more Tier I and Tier
II schools may not implement the Transformation Model in more than 50
percent of their schools.
Source: U.S. Department of Education, Baseline Analyses of SIG
Applications and SIG-Eligible and SIG Awarded Schools, May 2011.
[End of figure]
Figure: Most Schools Receiving SIG Funds Were In Large- or Middle-
Sized Cities in SY 2010-11:
[Refer to PDF for image: 2 pie-charts]
SIG schools:
Large or middle-sized city: 53%;
Urban fringe or large town: 24%;
Small town and rural area: 23%.
All schools:
Large or middle-sized city: 26%;
Urban fringe or large town: 42%;
Small town and rural area: 32%.
Source: U.S. Department of Education, Baseline Analyses of SIG
Applications and SIG-Eligible and SIG-Awarded Schools, May 2011.
[End of figure]
Grant Renewal Requires Meeting Certain Targets or Showing Other Signs
of Progress:
According to Education, the core element for determining SIG grant
renewal is annual reading and math achievement goals set by school
districts subject to approval by states.
Education's guidance says that if a school meets its annual goals,
then the state must renew the school's SIG grant.
If schools do not meet one or more annual goals, states have
flexibility in setting criteria for making renewal decisions and may
consider factors such as:
* schools' progress in meeting annual goals;
* fidelity with which school is implementing intervention model; and;
* schools' progress in meeting leading indicators.[Footnote 6]
Finding 1: States' SIG Management:
Among Selected States, Some Implemented SIG More Rigorously Than
Others:
* Some states used a selective award process, while others approved
all Tier I and II applications.
* State oversight of and assistance to districts and schools varied.
* External providers played a key role in some states' implementation
plans.
* States used federal flexibility in designing grant renewal processes.
Page 16
Some States Used a Selective Award Process, While Others Approved All
Tier I and II Applications:
Some states were more selective than others in approving district
applications. For Tier I and II schools in the 6 states we met with:
* one state-—Delaware—funded 1/5 of schools that applied;
* two states-—Nebraska and Ohio-—funded 60-75 percent of schools that
applied; and;
* three states-—Virginia, Nevada, and Rhode Island-—funded all
eligible Tier I and II schools that applied.[Footnote 7]
States with selective competitions funded only applications they
considered the strongest, and thus may be positioned for better
student achievement outcomes.
* For example, in Delaware, officials told us they only funded
districts with highly innovative proposals that demonstrated capacity
to implement proposed reforms.
In contrast, Nevada and Ohio state officials noted variation in the
quality of approved applications, and officials from some states said
there were a few districts that received SIG grants that were not
ready to implement reforms.
Table:
Selected state: Delaware;
Total FY 2009 award amount[A]: $10.6 million;
Number of funded districts serving Tier I and II schools: 22;
Number of funded Tier I and II schools: 2;
Number of Tier I schools and II schools in district with applications
rejected by state: 8;
Number of Tier I and II schools selecting each model:
Turnaround: 0;
Transformation: 2;
Restart: 0;
Closure: 0.
Selected state: Nebraska;
Total FY 2009 award amount[A]: $17.5 million;
Number of funded districts serving Tier I and II schools: 6;
Number of funded Tier I and II schools: 7;
Number of Tier I schools and II schools in districts with applications
rejected by state: 4;
Number of Tier I and II schools selecting each model:
Turnaround: 0;
Transformation: 7;
Restart: 0;
Closure: 0.
Selected state: Nevada;
Total FY 2009 award amount[A]: $23.4 million;
Number of funded districts serving Tier I and II schools: 3;
Number of funded Tier I and II schools: 10;
Number of Tier I schools and II schools in districts with applications
rejected by state: 0;
Number of Tier I and II schools selecting each model:
Turnaround: 3;
Transformation: 7;
Restart: 0;
Closure: 0.
Selected state: Ohio;
Total FY 2009 award amount[A]: $132.4 million;
Number of funded districts serving Tier I and II schools: 10;
Number of funded Tier I and II schools: 35;
Number of Tier I schools and II schools in districts with applications
rejected by state: 14;
Number of Tier I and II schools selecting each model:
Turnaround: 8;
Transformation: 27;
Restart: 0;
Closure: 0.
Selected state: Rhode Island;
Total FY 2009 award amount[A]: $12.5 million;
Number of funded districts serving Tier I and II schools: 2;
Number of funded Tier I and II schools: 5;
Number of Tier I schools and II schools in districts with applications
rejected by state: 0;
Number of Tier I and II schools selecting each model:
Turnaround: 0;
Transformation: 5;
Restart: 0;
Closure: 0.
Selected state: Virginia;
Total FY 2009 award amount[A]: $59.8 million;
Number of funded districts serving Tier I and II schools: 13;
Number of funded Tier I and II schools: 18;
Number of Tier I schools and II schools in districts with applications
rejected by state: 0;
Number of Tier I and II schools selecting each model:
Turnaround: 0;
Transformation: 11;
Restart: 5;
Closure: 2.
Source: GAO analysis of state and Education data on SY 2010-11.
[A] Total award amount includes 3-year funding for all schools (Tier
I, II, and III), administrative funds for the state and districts, and
carryover funds.
[End of table]
State Oversight of and Assistance to Districts and Schools Varied:
Some states provided greater levels of monitoring and oversight:
* Ohio hired transformation specialists to be in the field providing
guidance and oversight to each school on a weekly basis.
* Nebraska and Virginia required each school to designate a point
person responsible for coordinating regularly with the state.
In contrast, due to resource constraints, Rhode Island officials
focused oversight on the district application process and districts
relied on Education guidance about SIG implementation.
Some states added requirements to Education's guidance to conform with
their own SIG policies and program requirements.
* Examples of additional requirements include requiring a district
liaison to work with the state and requiring school and district
officials to attend certain conferences.
External Providers Played a Key Role in Some States' Implementation
Plans:
Some states relied on state-approved external providers to implement
key elements of SIG.[Footnote 8]
* Virginia required all Tier I and II schools to contract with one of
four state-approved external providers or demonstrate a rigorous
review process and select an external provider.
* Ohio had about 70 state-approved providers.
Delaware, Nebraska, and Nevada do not have approved provider lists,
although in some cases, schools did work with external providers.
States Used Federal Flexibility in Designing Grant Renewal Processes:
Education reviewed state renewal processes in state applications and
allowed states considerable flexibility in identifying criteria for
renewing schools' SIG grants.
For example, Nebraska officials said they planned to examine outcomes
of annual goals and progress on leading indicators. In addition, state
officials told us they would base SIG renewal decisions on how schools
have used SIG funds and would consider not renewing funding for
underperforming schools after one year.
In contrast, Nevada officials told us they plan to renew all schools
receiving FY 2009 funds for 1 year because of the time needed to
implement reforms, and will consider not renewing schools after 2
years if they do not make sufficient progress.
* The approved Nevada state SIG applications for FY 2009 and 2010 say
that the state plans to review schools based on achievement of annual
goals and other factors, such as fidelity of implementation.
Finding 2: Factors Affecting Reform:
Limited Capacity, Challenges in Rural Areas, and Short Time Frames
Affected School Reform:
* Local capacity affected schools' implementation of SIG interventions.
* Implementation was particularly challenging in some rural areas.
* Short implementation time frames in some cases did not allow schools
sufficient time to plan and fully implement reforms.
Local Capacity Affected Schools' Implementation of SIG Interventions:
Local capacity-—such as the ability to attract and retain
administrative staff with school turnaround expertise or quality
teachers-—influenced implementation.
* Several state officials and stakeholders said some school districts
had greater capacity than others to implement SIG interventions.
- Seaford, Delaware - district officials created a district-wide
transformational support team composed of district administrators, the
principal, teachers, and consultants that met regularly.
- Columbus, Ohio - district held multiple-day planning sessions to
involve principals and teachers in designing SIG plans.
* Many officials told us teacher and union buy-in facilitated elements
of reform, such as increased learning time and teacher reassignment.
- Columbus, Ohio - district and union officials worked together to
give SIG schools priority in staffing by allowing them to hire staff
before other schools.
Some districts faced challenges implementing interventions.
* Cleveland, Ohio school district officials said they did not have
capacity to provide each SIG school the necessary amount of support
for SIG implementation.
* Officials from a rural Virginia district said attracting and
retaining high-quality teachers was very difficult.
According to state and district officials, model selection was often
based on feasibility rather than which reforms were most likely to
improve student outcomes.
* Turnaround Model — challenging in districts that lacked ability to
recruit high-quality teachers.
* Restart Model — challenging in the one state we visited without a
law permitting charter schools.[Footnote 9]
* School Closure — not an option in districts lacking quality schools
within reasonable proximity to displaced students.
Implementation Was Particularly Challenging in Some Rural Areas:
State and local officials from the states we met with told us that
small rural districts often have fewer resources than larger districts
to implement SIG.
Some officials in rural areas felt constrained selecting a model,
particularly:
* in attracting qualified teachers as required in the Turnaround Model;
* in attracting external providers as required in the Restart Model;
and;
* being too far from neighboring schools to allow for School Closure.
State and local officials told us that-—even with higher salaries and
other incentives—-it is difficult to recruit and retain staff in some
rural areas, particularly:
* principals and teachers with school reform experience; and;
* specialized teachers (e.g., math teachers or those with expertise
teaching students with disabilities).
SIG requirements for increased learning time-—which could lead to
students leaving school at different times-—resulted in high
transportation costs for some rural schools with limited
transportation resources.
Short Implementation Time Frames in Some Cases Did Not Allow Schools
Sufficient Time to Plan and Fully Implement Reforms:
In some cases, Education did not approve state SIG applications for SY
2010-11 until summer 2010, although interventions were to begin at
start of school year.
* Half the states we visited received final approval from Education in
June or July 2010.
* States were unable to approve district applications until Education
approved state SIG grants.
* Some districts did not find out how much SIG funding they would
receive until shortly before the start of SY 2010-11, leaving little
time for them to implement SIG reforms before the school year.
Education, state, district, and school officials noted time frames for
SY 2010-11 were challenging for states and districts.
* In some cases, state deadlines to dismiss teachers and principals
passed before district and school officials knew whether they would
receive a SIG grant.[Footnote 10]
* Many teachers and administrators could not be hired until shortly
before or after start of SY 2010-11.
* Some SIG initiatives were delayed and not implemented at the
beginning of SY 2010-11.
To improve time frames for the second year of SIG, SY 2011-12,
Education moved up the deadline for state SIG applications to December
2010—in the prior year, applications were due in February.
In addition, Education is allowing SIG funds for SY 2011-12 to be used
for planning before the start of the school year, which Education
refers to as "pre-implementation."
Even with pre-implementation, Education still needed to approve state
applications before district applications could be approved and
implementation could begin.
Despite Education's efforts, time frames for approving state
applications for funds available starting in SY 2011-12 may again
impact district and school SIG planning and implementation.
* As of June 24, 2011, six states, including the District of Columbia,
were still awaiting approval of their SIG applications. Four of the
six states awaiting approval of their applications submitted them
after the due date.
* Education officials said that states submitting late or incomplete
applications often have not been awarded SIG grants until shortly
before the start of the school year.
* Education officials also said that some states have not managed
timely application processes for districts, resulting in little time
for districts to plan and implement interventions.
Districts in states that receive late approval have little time to
plan and implement reforms.[Footnote 11]
* Some district officials told us that although time frames for grant
approval have improved, they will still be a challenge for SY 2011-12.
Education officials recognized that there are still challenges with
SIG time frames, but have not yet identified additional action steps
to address these issues.
Finding 3: Education Oversight:
Education Uses a Variety of Strategies to Oversee SIG and Plans
Additional Data Collection:
* Education uses a variety of strategies to oversee state and district
implementation.
* Education plans to collect performance data.
Education Uses Variety of Strategies to Oversee State and District
Implementation:
Education reviews and approves state plans for SIG prior to awarding
grants.
Education plans to conduct on-site monitoring of 12 states in 2011.
[Footnote 12] The agency:
* selected states in 2011 using previously-established schedule for
Title I monitoring;
* is currently developing criteria for selecting states to monitor in
future years;
* visited state educational agencies, districts, and schools, meeting
with variety of stakeholders including parents and students; and;
* is working with monitored states to remedy instances of non-
compliance and identify areas where states need technical assistance,
according to Education officials. Education also used monitoring
results and other early information to plan regional conferences in
spring 2011.
Education has begun an "Implementation Initiative" in which nine
volunteer states receive on-site technical assistance and visit other
states for peer-to-peer information sharing.
* Officials said this also provides an informal avenue for Education
to assess quality of states' implementation.
In addition, Education posts approved state SIG applications on its
Web site to allow oversight and accountability to external
stakeholders.
Education Plans to Collect Performance Data:
Education officials said they plan to analyze annual data on SIG
schools' performance and identify good state practices.
* These data include performance data for SIG schools' reading and
math achievement goals and leading indicators.
* Education expects to receive performance data from SY 201011 midway
through SY 2011-12.
Education's Institute of Education Sciences also has three studies
under way to gather information about the results of SIG:
* multi-year review of case study states' SIG implementation;
* impact study of Recovery Act programs, including SIG; and;
* evaluation of Race to the Top and SIG implementation.
Conclusions:
District and school accountability for academic progress through the
grant renewal process is a key component of SIG, and Education's
guidance provides states with flexibility in designing renewal
processes. As states implement these processes, it will be important
for states to use renewal criteria that capture whether schools'
intervention efforts have the potential for academic progress.
The SIG application process has not allowed some districts and schools
the time needed to adequately plan and start implementing reforms
before the start of the school year.
Education's recent efforts to address these challenges improved
SIG application process time frames. However, some states' SIG
applications were still not approved as of late June 2011, when
implementation was set to begin in the 2011-12 school year.
Unless Education takes steps to ensure that districts and schools have
sufficient time to implement SIG grants, short time frames may impede
districts' and schools' ability to improve.
While Education has a number of strategies to oversee states' SIG
implementation and collect information, it will be important for
Education to also use forthcoming annual performance data to identify
challenges and target assistance to states and districts.
Success of such efforts will be important, particularly due to
capacity challenges in some states, districts, and schools.
Recommendations:
To provide districts and schools more time to plan and implement SIG
reforms, the Secretary of Education should consider options to have
SIG grants awarded to districts earlier, such as:
* using an earlier deadline for state applications; or;
* approving state applications with timelines that allow for earlier
awards to districts.
[End of section]
Appendix II: Comments from the Department of Education:
United States Department Of Education:
Office Of Elementary And Secondary Education:
400 Maryland Ave., SW:
Washington, D.C. 20202:
July 20, 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, "School Improvement Grants:
Early Implementation Underway, but Reforms Hindered by Short
Timeframes." (GAO-11-741) I appreciate the opportunity to comment on
the draft report on behalf of the Department of Education.
We appreciate the time that your office devoted to reviewing the
administration, implementation, and oversight of the School
Improvement Grants (SIG) program. The views of our grantees are
important to us in understanding the impact of the SIG program and its
overall goal of turning around our nation's persistently lowest
achieving schools.
There are some discussions in the report that the Department believes
could benefit from additional clarification. We discuss each of these
areas below. In addition, we are enclosing suggested technical edits
to the report.
GAO Recommendation: To provide districts and schools more time to
successfully plan and implement SIG reforms, we are recommending that
the Secretary of Education should consider options to have SIG grants
awarded to districts earlier, such as using an earlier deadline for
state applications or creating deadlines for slate approval of district
applications.
Timeline: With regard to GAO's conclusion that LEAs and schools need
more time to plan and implement reforms, we were pleased to see that
the report points out that the Department recognizes that the timeline
for SIG implementation was challenging-—particularly for the fiscal
year (FY) 2009 cohort. There were many factors contributing to
The Department of Education's mission is to promote student
achievement and preparation for global competitiveness by
fostering educational excellence and ensuring equal access.
the delay in making SIG grant awards — some under the Department's
control and others under states' control.
The Department's top priority was to approve high-quality state
applications aligned with the SIG requirements. Given the SIG
program's dramatic revamping in FY 2009, states and districts needed
additional support in understanding and complying with the new
requirements. The Department provided extensive technical assistance
to states before and throughout the application process to assist
states with understanding the new requirements and providing detailed
feedback on the portions of their application that were not
approvable. The back-and-forth with states took some time given the
new requirements.
To better address timeliness in FY 2010, the Department improved the
SIG application to make it a user-friendly fill-in form and allowed
states to "cut and paste" sections from their FY 2009 application. The
Department also released the application two months earlier than in FY
2009. Even with these improvements, there was widespread staff
turnover in many state educational agencies at the time the
application was released, which contributed significantly to delays in
states' submitting and securing approval of their application. This
being said, we are in the process of reviewing the FY 2010 application
process to determine what additional steps the Department could take
to facilitate future reviews and to support effective SIG
implementation.
In addition, we would like to respond to two additional points in the
report.
Rural Challenges: The report states that "some rural districts have
inadequate resources which makes it difficult to compete for funding
with districts able to hire professional grant writers." (p. 25) The
Department has been actively tracking the data available on SIG
schools and has learned that, while rural schools represent only 16
percent of the schools that were eligible to apply for SIG, they
represent 24 percent of the schools that actually received the funds.
These data suggest that rural schools did indeed have the resources to
apply and be competitive for SIG funds. We are pleased that this is
the case and will continuo to work with rural schools to ensure they
are able to compete on a level field for SIG and other grant programs.
Using Data to Inform Decision Making: The report notes that "it will
be important for Education to use these data [it currently is
collecting on SIG implementation] to identify challenges and target
assistance to states and districts,...particularly due to capacity
challenges in some states, districts and schools." (p. 35) The
Department would like to note that it has actively used SIG
implementation data to inform technical assistance. For example, in
the spring of 2011, the Department hosted four regional capacity-
building conferences to support grantees in implementing SIG in their
schools. The topics for these conferences were selected based on data
we gathered from monitoring, technical assistance calls with states,
the SIG evaluation study baseline report, the Department's
comprehensive centers, and in-person meetings with grantees. There
were over 1,200 attendees among all the conferences, representing
state, district, and school staff. The Department is using the survey
data from these conferences to inform future technical assistance.
We appreciate the opportunity to review the draft report and comment
on the recommendation.
Sincerely,
Signed by:
Michael Yudin:
Deputy Assistant Secretary for Policy and Strategic Initiatives:
Enclosure
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
George Scott at (202) 512-7215 or scottg@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, the following staff members
made important contributions to this report: Elizabeth Sirois,
Assistant Director; Scott Spicer, Analyst-in-Charge; Melissa King;
Salvatore Sorbello; and Barbara Steel-Lowney. In addition, Jean
McSween, James Rebbe, Tom James, and Kathleen Van Gelder provided
guidance on the study.
[End of section]
Footnotes:
[1] Pub. L. No. 111-5, 123 Stat. 115.
[2] Among other actions, the four models include the following
requirements: (1) the "transformation model" requires schools to
replace the principal, provide increased learning time, and implement
a staff evaluation system that incorporates measurements of student
outcomes; (2) the "turnaround model" requires schools to replace the
principal and at least 50 percent of the teachers; (3) the "restart
model" requires the school to close and reopen under a charter school
operator, charter management organization or an educational management
organization; and (4) the "closure model" requires that the school
closes and previously enrolled students move to schools that are
higher achieving.
[3] We plan to issue another report on SIG in 2012 that will include
additional information on SIG implementation in school year (SY) 2011-
12.
[4] The maximum award amount applies only to SIG funds obligated after
October 1, 2010.
[5] Under Title I, Part A of ESEA, as amended, states set academic
targets and measure schools' progress in meeting them. Schools in
improvement status have missed academic targets for at least 2
consecutive years. The definitions of Tier I and Tier II schools also
include high schools that have a graduation rate of less than 60
percent over a number of years.
[6] The nine required leading indicators are: number of minutes within
school year; student participation rate on state assessments; dropout
rate; student attendance rate; teacher attendance rate; number and
percent of students completing advanced coursework; discipline
incidents; truancy; and distribution of teachers on district
evaluation system.
[7] In a recent Center on Education Policy survey, 22 of 43 state
respondents (including the District of Columbia) indicated that 75
percent or more of schools in districts that applied for SIG grants
actually received or will receive funds.
[8] The roles of external providers varied, but could include managing
school operations, providing professional development, or conducting
data analysis, among other possible functions.
[9] One of the six states we met with-—Nebraska—-did not have a law
permitting charter schools.
[10] Officials from all of the states we met with told us they have
laws regulating teacher or principal dismissal notification dates.
[11] According to specialists in school reform, schools should have at
least 4-6 months planning time, so that an assessment of school needs
can be conducted in the prior school year, better informing SIG
planning efforts.
[12] As of June 27, 2011, Education had completed and published
monitoring reports for four states (California, Indiana, Nevada, and
Pennsylvania).
[End of section]
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