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United States General Accounting Office: 
GAO: 

Report to the Ranking Minority Member, Subcommittee on Oversight of 
Government Management, Restructuring and the District of Columbia, U.S. 
Senate Committee on Government Affairs: 

April 2002: 

Special Education: 

Grant Programs Designed to Serve Children Ages 0-5: 

GAO-02-394: 

Contents: 

Letter: 

Results in Brief: 

Background: 

School-Age and Preschool Grants Are Similar Except for Age Range 
Served; Infant Grants Differ: 

States Receive All Grants and Many Provide Services to 3 through 5 Year-
Olds with School-Age as well as Preschool Grants: 

Grants’ Impact Not Yet Evaluated, and Few Data Are Available on 
Effectiveness of Special Education Programs for Young Children: 

Some Local Coordination and Program Overlap Issues Exist: 

Concluding Observations: 

Agency Comments and Our Response: 

Appendix: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Overview of Three Programs Serving Young Children with 
Disabilities, Fiscal Year 2001: 

Table 2: Overview of Eligibility Criteria, Services Allowed, Goals and 
Performance Objectives for Infant, Preschool, and School-age Grants for 
Children with Disabilities: 

Table 3: Advantages and Disadvantages of Options for Addressing 
Potential Overlap of Preschool and School-age Grants: 

Figure: 

Figure 1: Special Education Funding Sources: 

Abbreviations: 

IDEA: Individuals with Disabilities Education Act: 

LEA: local educational agencies: 

OSEP: Office of Special Education Programs: 

SEA: state educational agency: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

April 25, 2002: 

The Honorable George V. Voinovich: 
Ranking Minority Member: 
Subcommittee on Oversight of Government Management, Restructuring and 
the District of Columbia: 
Committee on Governmental Affairs: 
United States Senate: 

Dear Senator Voinovich: 

In fiscal year 2001, the federal government spent about $7 billion on 
three special education grant programs mandated by the Individuals with 
Disabilities Education Act (IDEA). These grants are Special Education 
Grants to States (School-age Grants), Special Education Preschool 
Grants (Preschool Grants) and Special Education Grants for Infants and 
Families with Disabilities (Infant Grants). This review is one of four 
reports you have requested looking at overlap among early childhood 
education and care programs.[Footnote 1] Our work has shown that if 
such programs are designed to achieve similar outcomes for the same 
target group and are not well-coordinated, the potential exists for 
ineffective service delivery and administrative inefficiencies. 
[Footnote 2] This potential exists for School-age Grants and Preschool 
Grants because School-age Grants serve children ages 3 through 21 and 
Preschool Grants serve children ages 3 through 5. 

These three grant programs are not programs in the typical sense 
because they do not carry out a distinct set of functions through their 
own delivery systems. Instead, the programs serve as funding streams, 
merging with much greater state and local resources to support state 
and local programs. State and local programs supported by the three 
grants served approximately 6.6 million children in fiscal year 2001. 
Of these children, about 830,000 were receiving early intervention and 
special education and related services—231,000 were under 3 years-old 
and 599,000 were age 3 through 5. 

Specifically, you asked us: (1) How similar are the goals/objectives, 
performance measures, eligibility criteria, and the services allowed by 
these programs? (2) Do states and local agencies receive funding from 
more than one of these grants and, if so, do they use the funds to 
provide the same range of services to children in the same age group? 
(3) What is known about the effectiveness of these programs and of the 
early interventions they fund? (4) What opportunities exist for better 
coordination among the programs or consolidation of the programs to 
achieve efficiencies? 

To answer these questions, we reviewed pertinent documents, including 
state monitoring reports issued by the U.S. Department of Education’s 
(Education) Office of Special Education Programs (OSEP), which provided 
detailed information about state and local efforts to implement 
IDEA.[Footnote 3] We examined the grant application process and 
administrative structure for each grant program, conducted interviews 
with special education program officials and representatives from 
special education stakeholder groups (parents and state directors of 
special education), conducted comprehensive state-level interviews in 
four states—Maine, Minnesota, Ohio, and Virginia—and conducted 
structured telephone interviews with officials from 15 states. 
[Footnote 4] We selected the four states for comprehensive interviews 
based, in part, on recommendations from state-level officials and 
others with a direct interest in these programs. We also considered 
variations in how states administer these programs and selected states 
that represented a variety of administrative structures and geographic 
regions. For the telephone interviews, we selected at least 1 state 
from each of Education’s 10 regions. In order to obtain a wide range of 
perspectives on program administration, we also considered which state 
agency had been designated to administer Infant Grants. We performed 
our work from June 2001 through February 2002 in accordance with 
generally accepted government auditing standards. 

Results in Brief: 

School-age and Preschool Grants are similar, except for the age ranges 
of children they serve, while Infant Grants differ from the other two 
grants in goals, performance objectives, performance measures, 
eligibility, and services. School-age and Preschool Grants share the 
common goal of helping states provide access to high-quality education 
for students with disabilities and use a single set of performance 
objectives and performance measures to measure progress towards this 
goal. Both grants pay for the same range of special education and 
related services and require that children must be classified by the 
state as having a disability in order to be eligible for these 
services. The key distinction between the two grants is that School-age 
Grants serve children ages 3 through 21, whereas Preschool Grants 
generally serve children ages 3 through 5. In contrast, the goal of 
Infant Grants is to help states provide a comprehensive system of early 
intervention services to infants, toddlers, and their families to 
enhance the development of infants and toddlers with disabilities and 
those who are at risk of developmental delays. Infant Grants may be 
used to pay for health and family services, such as tube feeding and 
respite care, that are more comprehensive than those provided under the 
other two grants, and for additional services to families that will 
enhance their capacity to meet the special needs of their infants and 
toddlers. To be eligible for services under Infant Grants, children 
must be under age 3 and have a developmental delay or the potential to 
develop one. 

States receive funds from all three grants, and some states reported 
they use funds from both School-age and Preschool Grants to provide the 
same range of services to children aged 3 through 5. Although states 
receive funds from all three grants, local agencies may receive funds 
from only one grant, or from as many as three. Overlap can occur only 
between School-age Grants and Preschool Grants, which fund the same 
range of services for children ages 3 through 5. Eighteen of the 19 
states we talked with reported that the range of services they provide 
to children ages 3 through 5 using funds from School-age Grants, such 
as counseling, speech pathology services, and physical therapy, is the 
same as those they provide using funds from Preschool Grants. None of 
these states could tell us how much of their School-age Grants they use 
to pay for services for children ages 3 through 5, and federal 
regulations do not require them to report this information. In general, 
states could not provide us with this information because they account 
for expenditures by budget function, such as salaries or 
transportation, and not by individual services provided or ages of 
children receiving services. 

Little is known about the long-term effectiveness of these programs and 
the early childhood interventions they fund. No evaluations of these 
programs have been conducted that attempt to isolate the impact of 
these three federal grant programs from the impact of other funding 
sources. Education has three large studies under way that will have 
some information on the outcomes for children who are enrolled in 
special education preschool programs, but not on these programs’ 
specific contributions to these outcomes. In addition, two state 
evaluations that we reviewed described positive outcomes for children 
who participated in preschool special education programs but could not 
attribute these outcomes solely to program participation. These 
evaluations show that about half the children who received preschool 
services (mainly speech and language therapy) no longer needed them 
when they reached school age. 

We found some opportunities for better coordination of these grant 
programs, but program officials told us that consolidating School-age 
and Preschool Grants would not result in additional administrative 
efficiencies. The lack of coordination that we did find existed at the 
state and local level in situations where a child turned 3 before the 
school year began, causing a gap between the services provided with 
Infant Grants and those provided with School-age and Preschool Grants. 
This occurred despite federal rules that allow funds from Infant Grants 
to be used after the third birthday to pay for a free appropriate 
public education until the beginning of the following school year and 
required written plans for each child, to show how the transition 
between the two programs will be managed. We were unable to determine 
whether the overlap in age groups served by School-age and Preschool 
Grants indicates poor coordination, because most of the states and 
localities that we contacted do not track the sources of funds for 
services for specific ages of children. Although consolidating these 
two grants would eliminate the potential for poor coordination between 
two separate grants by eliminating one of them, it is not clear that 
this would result in increased program efficiency. At the federal 
level, Education is already administering School-age and Preschool 
Grants as if they were one program. State and local officials indicated 
that although there are potential advantages and disadvantages to 
consolidating the programs, overall, consolidation would probably not 
result in a significant reduction in administrative burden. 

Background: 

The 50 states and the District of Columbia spent an estimated $50 
billion on special education for children from birth through age 21 in 
school year 1999-00. About 12 percent of this amount came from federal 
funds, specifically IDEA grants (10 percent) and Medicaid funds (2 
percent).[Footnote 5] (See fig. 1.) In addition to federal funds, other 
sources are used to support the provision of special education and 
related services for children with disabilities, such as state general 
and special education funds, local funds, and private insurance. 

Figure 1: Special Education Funding Sources: 

[Refer to PDF for image] 

This figure is a pie-chart depicting the following data: 

Special Education Funding Sources: 
State, local and private funds: 88%; 
Federal funds: 12% (School-age grants, Preschool grants, Medicaid). 

Source: Chambers, Jay G., et al., What Are We Spending on Special 
Education Services in the United States, 1999-2000? Advance Report #1, 
Special Education Expenditure Project (SEEP), American Institutes for 
Research, 2002. 

[End of figure] 

Under IDEA, three grants can fund services to children under age 6. 
School-age Grants provide money to states to help them serve all 
eligible children, ranging in age from 3 through 21.[Footnote 6] 
Preschool Grants provide money to states to help serve 3 through 5-year-
olds with disabilities and require states to have policies and 
procedures that assure a free appropriate public education for all 3 
through 5-year-olds with disabilities as a condition for receiving 
other IDEA funds for this age range. Infant Grants provide money to 
states to serve children under age 3 who have developmental delays or a 
condition that will probably result in a developmental delay, or at a 
state’s discretion, who are otherwise at risk of developmental delays. 
[Footnote 7] Unlike the other two grants, Infant Grants provide 
services to both children and their families, primarily in settings 
that are not school-based. (See table 1.) 

Table 1: Overview of Three Programs Serving Young Children with 
Disabilities, Fiscal Year 2001: 

Program[A]: School-age Grants; 
FY 2001 appropriation: $6.3 billion; 
Number of children served: 5,782,000 ages 6 through 21; 
Comments: Established in 1965 under the Elementary and Secondary 
Education Act and State Schools Act. 

Program[A]: Preschool Grants; 
FY 2001 appropriation: $390 million; 
Number of children served: 599,000 ages 3 through 5[B]; 
Comments: Established in 1975 as an incentive program to encourage 
states to serve 3 through 5 year-olds. 

Program[A]: Infant Grants; 
FY 2001 appropriation: $384 million
Number of children served: 231,000; 
Comments: Established in 1986, but not implemented in all states until 
1994. 

[A] School-age and Preschool Grants are authorized under IDEA Part B 
and are formally known as Section 611 grants and Section 619 grants, 
respectively. Infant Grants are authorized under IDEA Part C. 

[B] This includes children served under both School-age and Preschool 
Grants. 

Source: GAO analysis. 

[End of table] 

Program overlap occurs when programs have the same goals, the same 
activities or strategies to achieve them, or the same targeted 
recipients. As noted in a House Government Reform and Oversight 
Committee report, “A certain amount of redundancy is understandable and 
can be beneficial if it occurs by design as part of a management 
strategy to foster competition, provide better service delivery to 
customer groups, or provide emergency backup.” [Footnote 8] Because 
both School-age and Preschool grants can be used to serve the same 
target recipients, children with disabilities ages 3 through 5, they 
can be characterized as overlapping. However, this overlap does not 
necessarily lead to duplication of services, which involves providing 
identical services to identical target groups.[Footnote 9] 

Education allocates funds from School-age, Preschool, and Infant Grants 
to all states, the District of Columbia, and Puerto Rico, based on 
federal formulas. At the state level, School-age and Preschool Grants 
are administered by the state educational agency (SEA), and Infant 
Grants are administered by a designated lead agency, most frequently 
the state’s department of health or human services. A fixed portion of 
School-age and Preschool grants may be retained for state-level 
activities and program administration, although the majority of funds 
from these grants are passed through SEAs to local educational agencies 
(LEAs), generally school districts, according to a federally mandated 
formula. Infant Grants may be distributed to local public and private 
agencies by designated state lead agencies using state-developed 
criteria. 

Education’s OSEP monitors activities funded by these grants and the 
extent to which states comply with IDEA in a process known as 
continuous improvement monitoring. Several states are selected each 
year for in-depth monitoring, including on-site data collection, based 
on various factors, such as when they were last monitored, information 
from grant applications, and information on each state’s status in 
achieving improved results and compliance. 

School-Age and Preschool Grants Are Similar Except for Age Range 
Served; Infant Grants Differ: 

School-age and Preschool Grants share the same goal, performance 
objectives, and performance measures; fund the same range of services; 
and have similar eligibility requirements except for the age-range 
served, while Infant Grants differ from these grants in almost all 
respects. (See table 2.) 

Table 2: Overview of Eligibility Criteria, Services Allowed, Goals and 
Performance Objectives for Infant, Preschool, and School-age Grants for 
Children with Disabilities: 

Programs: Infant Grants, Ages 0 to 3: 
Criteria for service eligibility: Infants and toddlers who are 
developmentally delayed or have a condition that will probably result 
in a developmental delay or who are otherwise at risk of developmental 
delay; 
Services allowed: 
* Family training, counseling, and home visits; 
* Nursing, health, and nutrition services; 
* Service coordination; 
* Medical services for diagnostic or evaluation purposes; 
* Occupational and physical therapy; 
* Psychological and social work services; 
* Vision, orientation, and mobility services; 
* Speech-language pathology services; 
* Devices to assist the disabled in daily living and audiology 
services; 
* Transportation services; 
* Age appropriate special education instruction; 
* Early identification and assessment services; 
Goals: To enhance family and child outcomes through early intervention 
services and to have states provide a comprehensive system of early 
intervention services for infants and toddlers with disabilities and 
their families; 
Performance Objectives: 
* To provide services in settings, such as home or day care, that meet 
children’s individual needs; 
* To enhance children’s functional development. 

Programs: Preschool Grants, Ages 3 through 5: 
Criteria for service eligibility: Child with a disability (3 through 
21), or with developmental delay (3 to 9 only) who, as a result, needs 
special education and related services; 
Services allowed: 
* Student counseling and training, including rehabilitation counseling; 
* School health services; 
* Recreation services; 
* Medical services for diagnostic or evaluation purposes; 
* Occupational and physical therapy; 
* Psychological and social work services; 
* Vision, orientation, and mobility services; 
* Speech-language pathology services; 
* Devices to assist the disabled in daily living and audiology 
services; 
* Transportation services; 
* Age appropriate special education instruction; 
* Early identification and assessment services; 
Goals: To improve results for children with disabilities by assisting 
state and local educational agencies to provide children with 
disabilities access to high-quality education that will help them meet 
challenging standards and prepare them for employment and independent 
living; 
Performance Objectives: 
* Preschool children enter school ready to learn; 
* Better identify and serve children eligible for special education 
before age 8; 
* Children have access to the general curriculum and assessments; 
* Students receive adequate support to complete high school and 
transition successfully after high school; 
* States address professional development. 

Programs: School-age Grants, Ages 3 through 21: 
Criteria for service eligibility: Child with a disability (3 through 
21), or with developmental delay (3 to 9 only) who, as a result, needs 
special education and related services; 
Services allowed: 
* Student counseling and training, including rehabilitation counseling; 
* School health services; 
* Recreation services; 
* Medical services for diagnostic or evaluation purposes; 
* Occupational and physical therapy; 
* Psychological and social work services; 
* Vision, orientation, and mobility services; 
* Speech-language pathology services; 
* Devices to assist the disabled in daily living and audiology 
services; 
* Transportation services; 
* Age appropriate special education instruction; 
* Early identification and assessment services; 
Goals: To improve results for children with disabilities by assisting 
state and local educational agencies to provide children with 
disabilities access to high-quality education that will help them meet 
challenging standards and prepare them for employment and independent 
living; 
Performance Objectives: 
* Preschool children enter school ready to learn; 
* Better identify and serve children eligible for special education 
before age 8; 
* Children have access to the general curriculum and assessments; 
* Students receive adequate support to complete high school and 
transition successfully after high school; 
* States address professional development. 

Sources: 34 C.F.R. Parts 300 and 303, and U.S. Department of Education 
2000 Performance Report and 2002 Program Annual Plan, Volume 2: 
Individual Programs. 

[End of table] 

School-age and Preschool Grants share the common goal of improving 
results for children with disabilities by assisting state and local 
educational agencies to provide children with disabilities access to 
high-quality education that will help them meet challenging standards 
and prepare them for employment and independent living. The two 
programs use the same set of performance objectives and performance 
measures. For example, one objective of both is that preschool children 
with disabilities receive services that prepare them to enter school 
ready to learn. As a performance measure for this objective, both 
programs use an increase in the percentage of preschool children 
receiving special education services who have readiness skills when 
they reach kindergarten.[Footnote 10] These programs also pay for the 
same range of special education and related services, such as physical 
and occupational therapy and technology to assist the disabled, such as 
voice-activated software. Special education and related services are 
generally provided at school. To be eligible for these services, 
children must be classified by the state as having a disability and as 
a result of the disability need special education and related 
services.[Footnote 11] The key distinction between the two grants is 
that School-age grants serve children ages 3 through 21, whereas 
Preschool Grants serve only children ages 3 through 5. 

The goal, performance objectives, performance measures, eligibility 
criteria, and types of services allowed for Infant Grants differ from 
those for School-age and Preschool Grants. This grant is designed to 
assist states in developing and implementing a statewide, comprehensive 
system to provide early intervention services for infants and toddlers 
with disabilities (and at a state’s discretion those who are at risk of 
experiencing developmental delays) and their families.[Footnote 12] The 
goal of Infant Grants is to enhance children’s functional development 
and increase families’ capacity to increase their children’s 
development using a comprehensive system of early intervention 
services, including health services, such as tube feeding or 
intermittent catheterization, and family training. Objectives are broad 
and each has performance measures. For example, an increase in the 
percentage of all children under age 3 receiving age-appropriate 
services in nonschool settings is a performance measure for the 
objective of providing services at home or in daycare, when 
appropriate. To be eligible for services under Infant Grants, children 
must be under age 3 and have a developmental delay or the potential to 
develop one. Because of the age-specific developmental needs of infants 
and toddlers, health and family services provided under Infant Grants 
are more comprehensive than under the other two grants. These services 
are provided primarily in nonschool settings, generally in the home or 
at a day-care site. 

States Receive All Grants and Many Provide Services to 3 through 5 Year-
Olds with School-Age as well as Preschool Grants: 

All 50 states, the District of Columbia, and Puerto Rico receive grants 
from each of the three programs, which they distribute to various local 
public and private agencies.[Footnote 13] Whether a local agency 
receives funds from any one grant depends on whether it is serving the 
relevant age group. For example, the Roanoke Interagency Coordinating 
Council in Virginia, which serves children from birth through age 2, 
receives Infant Grants but not School-age and Preschool Grants. 
However, many LEAs receive more than one grant. For example, the 
Mapleton Local School District in Ohio received School-age and 
Preschool Grants in School Year 2001-2002, while the South Washington 
County School District in Minnesota received funds from all three 
programs. 

Many states use more than one grant to fund the same range of services 
for 3 through 5 year-olds. Officials in 18 of the states we contacted 
told us they may use School-age Grants to serve 3 through 5 year-
olds—the same group of children served by Preschool Grants. Only one of 
the states we contacted, Alaska, does not permit School-age Grants to 
be used to pay for services for preschoolers. Also, in a survey of SEAs 
conducted by the National Early Childhood Technical Assistance System, 
37 SEAs reported that they use funds from School-age Grants to support 
the provision of special education and related services for preschool 
children with disabilities.[Footnote 14] Since they are not required to 
track such information, none of the 19 states we contacted were able to 
tell us the percentage of School-age Grant funds they used to provide 
services for children aged 3 through 5, although officials in several 
states said that the amount was small. Similarly, 18 of the 19 states 
could not provide us with the percentage of children aged 3 through 5 
who received services provided with School-age Grants.[Footnote 15] 

Many states could not report the extent to which School-age Grants fund 
services for 3 through 5 year-olds because of how expenditures are 
tracked. The states we contacted reported they track expenditures by 
budget functions, such as salaries or transportation, and not by 
individual services provided or ages of children receiving services. 
These states do not require LEAs to report expenditure data in a way 
that would allow them to determine the extent to which School-age 
Grants fund services for 3 through 5 year-olds, nor does IDEA require 
it. Education requires only that states report the number of children 
ages 3 through 5 collectively receiving special education and related 
services under School-age and Preschool Grants. IDEA does not require 
specific information about how many children are served under each. 

Grants’ Impact Not Yet Evaluated, and Few Data Are Available on 
Effectiveness of Special Education Programs for Young Children: 

The effectiveness of these grant programs has not yet been evaluated, 
in part, because federal special education funds are only one source 
used to pay for services for this age group. Rather than functioning as 
operating programs, these grants add to the stream of funds supporting 
on-going state and local programs.[Footnote 16] Therefore, it is 
difficult to isolate the impact of federal funding for special 
education from the impact of other funding sources.[Footnote 17] 
Instead, studies have tended to focus on how IDEA is being implemented 
and on the overall progress of children who receive special education 
services, without directly attributing these outcomes to the receipt of 
particular services.[Footnote 18] 

In the 1997 amendments to IDEA, Congress mandated a full, national 
assessment to determine the progress in the implementation of IDEA, 
including the effectiveness of state and local efforts to provide a 
free public education appropriate for the needs of students with 
disabilities and to provide early intervention services to infants and 
toddlers. In response to this mandate, OSEP has contracted with several 
research organizations to complete a number of studies. None of these 
studies will attempt to isolate the contribution of IDEA grants from 
the effects of state and local efforts to improve outcomes for young 
children; Congress did not prescribe such a stringent assessment of 
program effectiveness. 

Instead, three of these studies contracted by OSEP are outcome 
evaluations, focused on describing the short-term and long-term 
outcomes for young children enrolled in programs supported, in part, by 
these grants. The National Early Intervention Longitudinal Study will 
follow children entering early intervention services supported by 
Infant Grants. The Pre-Elementary Education Longitudinal Study will 
follow children who received preschool special education services 
through their experience in preschool and early elementary school. The 
Special Education Elementary Longitudinal Study is documenting the 
experience of children enrolled in special education as they move from 
elementary school to middle and high school. The results from these 
studies will not be available for several years, although OSEP has 
issued initial reports describing the demographic characteristics of 
some study participants, their families, and schools. 

In addition to these evaluations describing children’s outcomes, OSEP 
has contracted a study examining how these programs are implemented. 
The Special Education Expenditure Project is intended to answer a 
variety of questions on the characteristics of expenditures on programs 
and services for preschool special education students. The first in an 
anticipated series of reports derived from this project was issued in 
March 2002 and provides an overview of special education spending in 
school year 1999-2000 in the 50 states and the District of Columbia. 
[Footnote 19] This report presents aggregate data on how much is spent 
nationally and how these funds are allocated among broad program areas. 
In particular, the report notes that preschool programs account for 
about 9 percent of special education expenditures overall and that 8 
percent ($4.1 billion) was spent on preschool programs operated within 
public schools and 1 percent ($263 million) was spent on preschool 
programs operated outside public schools. 

In addition to the efforts now underway to evaluate outcomes and 
expenditures on services for young children enrolled in programs 
supported by IDEA grants, we found studies from two states—Delaware and 
Pennsylvania—on the outcomes of children in special education preschool 
programs. The Delaware study found that nearly half of the children who 
participated in Preschool Grants-supported programs in Delaware between 
1997 and 1999 were able to transition into the regular education 
program by the time they were 6 and 7 years-old. The Delaware study 
also found that children who participated in preschool special 
education had significantly higher grades in kindergarten and first 
grade than children with disabilities who did not and that the gap in 
grades grew between kindergarten and first grade. The researchers 
responsible for the Delaware study attributed the higher grades to the 
children’s participation in programs supported by Preschool Grants. The 
Pennsylvania study found that fewer than half of the preschoolers who 
participated in early intervention services in Pennsylvania between 
1991 and 1995 were participating in school-age special education 
programs between 1996 and 1997, leading researchers to suggest that 
preschool early intervention services may have helped reduce the 
severity of the developmental delay for some participating children. 

Some Local Coordination and Program Overlap Issues Exist: 
We found some opportunities for better local coordination between 
programs funded with Infant Grants and preschool programs, but we were 
unable to determine the extent to which overlap between School-age and 
Preschool Grants may result in service duplication. We found evidence 
of problems with the transition of 3 year-olds between local programs 
funded with Infant Grants and preschool programs in 8 of 13 states for 
which OSEP issued monitoring reports in the last 2 years. While we 
could not ascertain whether overlap between School-age and Preschool 
Grants results in service duplication, program officials indicated that 
the overlap between School-age and Preschool Grants does not result in 
administrative inefficiencies. 

Some Coordination Problems Identified in the Transition from Infant 
Grants Programs: 

We found some lack of coordination between local programs funded by 
Infant Grants and preschool programs, which can be funded by Preschool 
or School-age Grants, in several states. Service gaps between programs 
funded by Infant Grants and preschool programs can occur for children 
who turn 3 before the beginning of the school year in which they can 
start attending preschool. IDEA has addressed this problem by allowing 
Infant Grants to be used after the third birthday to pay a free 
appropriate public education until the beginning of the next school 
year. Also, federal rules require that states develop written 
transition plans for each child to show how the transition between the 
two programs will be managed, and Education monitors and enforces these 
rules. Specifically, the designated lead agency for the Infant Grants 
must discuss with and train parents regarding future placements for 
their child and have developed procedures to help the child adjust to a 
new setting. To further coordinate this transition, the Infant Grants 
statute requires that the lead agency, with the approval of the family, 
must convene a conference among the Infant Grants lead agency, the 
family, and the LEA at least 90 days before the child is eligible for 
preschool services. In addition to the Infant Grants transition 
requirements, the School-age Grants statute requires LEAs to 
participate in transition planning conferences arranged by the lead 
agency. Children should begin receiving services no later than their 
third birthday. 

In 2000 and 2001, OSEP identified problems in the transition from 
programs funded by Infant Grants into preschool programs in 8 of the 13 
states that it monitored for compliance with IDEA. OSEP monitoring 
reports cited a range of problems related to transitions from programs 
funded with Infant Grants into preschool that resulted in gaps in 
services for preschoolers. Some of the problems cited include: not 
holding transition planning conferences within 90 days of a child’s 
third birthday (6 states); the failure of local educational agency 
representatives to attend these conferences, despite being invited to 
do so (3 states); and providing inadequate information about the 
transition process to parents (2 states). The lack of adequate 
information resulted in confusion and unwillingness to cooperate with 
service coordinators’ requests on the part of some parents and forced 
other parents to seek out preschool services on their own. In response 
to these problems, OSEP has required corrective action plans for each 
of the 8 states to address areas of noncompliance with IDEA related to 
the transition from programs funded by Infant Grants into preschool 
programs. 

In addition to the problems cited in OSEP’s monitoring reports, we 
found some further evidence of problems when children leave Infant 
Grants programs in our site visit to Ohio. One state official told us 
that children and families may not receive needed services when they 
transition from the state’s Infant Grants programs into preschool 
because preschool programs have more stringent eligibility criteria and 
lack the family focus of early intervention programs funded by Infant 
Grants. Also, a representative of the Ohio Coalition for the Education 
of Children with Disabilities told us that some school districts did 
not understand that they are legally required to provide services for 
preschool children with disabilities. 

These problems were not evident in the other states we visited. 
Officials in Maine, Minnesota, and Virginia did not report a lack of 
coordination between programs funded by Infant Grants and preschool 
programs in those states. Transition issues for these programs appear 
to have been eliminated in Maine and Minnesota because each state 
operates a single program to provide early intervention and special 
education services for children from birth through age 5. In those 
states, programs funded with Infant Grants and preschool programs are 
both operated through a single agency, rather than through two 
agencies, as is the case with most of states.[Footnote 20] In Virginia, 
transition issues have been minimized because the state requires public 
education for children with disabilities beginning at age 2—a year 
earlier than is required under federal law. More than two-thirds of 
children receiving early intervention services in Virginia transition 
into public preschool programs as soon as they become eligible. 

Overlap in Ages Served by School-age and Preschool Grants Might Result 
in Duplication: 

Because of overlap between School-age and Preschool Grants, which can 
both serve children ages 3 through 5, there is some potential for 
service duplication if the two programs do not coordinate at the local 
level. We were unable to further evaluate the extent to which 
coordination problems may exist because there were no data available 
that would allow us to do so, in that states are not required to 
distinguish between funding sources when reporting the ages of children 
served by School-age and Preschool Grants. Officials from the 4 states 
where we conducted comprehensive interviews did not report any 
coordination problems for these programs and were not able to provide 
evidence about whether or not service duplication occurs. At the 
federal level, there is no administrative overlap between School-age 
and Preschool Grants because Education already administers these grants 
as if they were one program. For example, Education requires a single 
application for both programs and applies a single set of goals, 
performance objectives, performance measures, and reporting 
requirements to both programs. 

Overlap between School-age and Preschool Grants could be addressed in a 
number of ways, according to our analysis. Narrowing the age range 
served by School-age Grants to ages 6 through 21 or consolidating the 
two grants into a single grant, either with or without a reserved 
amount of funds for preschool services, could eliminate overlap between 
these programs. However, advantages and disadvantages exist for each 
option. (See table 3). 

Table 3: Advantages and Disadvantages of Options for Addressing 
Potential Overlap of Preschool and School-age Grants: 

Option: 1. Narrow age range for School-age Grants to 6 through 21; 
Advantages: 
* Eliminates possibility of service duplication; 
* Simplifies tracking of funds spent on 3 through 5 year-olds; 
* Preserves targeted funds for 3 through 5 year-olds; 
Disadvantages: 
* States lose some flexibility (the ability to supplement Preschool 
Grant funds with School-age Grant funds when serving preschoolers). 

Option: 2. Consolidate School-Age and Preschool Grants into one Grant 
(no reserved funds for preschool services); 
Advantages: 
* Eliminates possibility of service duplication[A]; 
* Simplifies tracking of funds spent on 3 through 5 year-olds; 
* Increases the amount of flexible funds for states; 
Disadvantages: 
* No funds are targeted for preschool services; 
* Possible reduction in services for 3 through 5 year-olds. 

Option: 3. Consolidate School-Age and Preschool Grants into one Grant 
(with reserved funds for preschool services); 
Advantages: 
* Eliminates possibility of service duplication[A]; 
* Simplifies tracking of funds spent on 3 through 5 year-olds; 
* Preserves targeted funds for 3 through 5 year-olds; 
Disadvantages: 
* States may lose some flexibility (if the law prescribes fixed 
allocations of funds for particular age ranges). 

Option: 4. No change; 
Advantages: 
* Preserves targeted funds for 3 through 5 year-olds; 
* Does not introduce new administrative requirements; 
Disadvantages: 
* Continued possibility of service duplication. 

[A] This would not apply to states that currently administer the 
programs as one, such as Maine and Minnesota. 

Source: GAO analysis. 

[End of table] 

The first three options would ensure that children ages 3 through 5 are 
eligible for services under only one program. The first option, 
narrowing the age range for School-age Grants, has the advantage of 
preserving targeted funds to serve preschoolers by continuing Preschool 
Grants. However, under this option, states would lose the flexibility 
that they now have to devote a greater share of federal special 
education funds to serving preschoolers, if that is their priority. 

The second option, consolidating School-age and Preschool Grants into a 
single grant, has several advantages. It would eliminate potential 
overlap for 3 through 5 year-olds, make it easier to track funds spent 
on preschoolers, and may increase the ability of local school districts 
to target federal special education funds to children of any age, 
depending on local needs. However the last advantage could also be seen 
as a disadvantage, potentially reducing services for preschoolers in 
those local school districts where they are not considered to be as 
high a priority as services for older children. State administrators 
and parents told us they are concerned this option would eliminate 
safeguards for targeted preschool funding and may lead to a reduction 
in services for children ages 3 through 5, although states have been 
required to provide special education services to children ages 3 
through 5 since 1992 in order to be eligible for Preschool Grants and 
other IDEA funds targeted to children ages 3 through 5 with 
disabilities. State officials told us that serving preschoolers, 
whether in special education or otherwise, is not a priority for all 
local school districts, and expenditures of funds for 3 through 5 year-
olds would have to compete with the needs of older special education 
students. School districts generally do not provide regular education 
services to children ages 3 through 4. Moreover, as of November 2001, 
39 states require kindergarten be offered to 5 year-olds, but only 12 
require pupil attendance.[Footnote 21] 

The third option, consolidating School-age and Preschool Grants into a 
single grant, but reserving some funds for preschool services also 
would eliminate potential overlap of IDEA grants for 3 through 5 year-
olds. However, this option has the advantage of preserving minimum 
spending levels for preschoolers by including a set-aside provision in 
the grant legislation. Depending on how the legislation is written, a 
potential disadvantage to this option would be the loss of some 
flexibility in how states may allocate funds for preschoolers and other 
ages of children. This would occur if the legislation prescribes fixed 
levels of spending for both age ranges. Nevertheless, some of the 
officials and other interested parties that we contacted indicated 
that, if the programs were to be consolidated, they would prefer 
including a set-aside provision. Although there are potential 
advantages to eliminating program overlap, overall, changes to the 
current structure of federal grants for special education would 
probably not result in a significant reduction in administrative burden 
at the state and local levels. Retaining the current structure would 
preserve targeted funds for preschoolers and not introduce different 
administrative requirements, but the possibility of service duplication 
would continue. Many of the state and local administrators with whom we 
spoke indicated they do not see the need for any changes in the current 
structure of these grants. In addition, Education officials have noted 
a growing level of support for early intervention programs among 
lawmakers, program administrators and child advocates, which, in their 
opinion, justifies maintaining separate grants to support these 
programs. 

Concluding Observations: 

The Department of Education has recognized that there is some potential 
for a gap in services for 3 year-olds as they move from programs funded 
by Infants Grants into preschool programs and requires that states and 
local agencies minimize these service gaps by following federal 
requirements for program coordination and transition planning. However, 
we have seen evidence that in at least a few localities, states have 
failed to ensure that federal regulations are being followed. Education 
has addressed known transition problems by requiring these states to 
develop and implement corrective action plans that will bring them into 
compliance with IDEA. 

Although there is overlap between School-age and Preschool Grants 
because both allow for services to 3 through 5 year-olds, it is not 
clear whether this overlap presents problems of service duplication or 
unnecessary administrative burden that would indicate the need to 
change how the grants are structured. Program experts and federal, 
state, and local administrators that we interviewed did not report any 
problems and there were no data available that would allow us to 
determine the extent to which program overlap resulted in coordination 
or administrative problems. 

Agency Comments and Our Response: 

We provided the Department of Education an opportunity to comment on a 
draft of this report and received technical comments which we have 
incorporated into this report as appropriate. 

We are sending copies of this report to the Chairman of your 
subcommittee, the Secretary of Education, and appropriate congressional 
committees. Copies will also be made available to other interested 
parties upon request. If you have questions regarding this report, 
please call me at (202) 512-7215 or Eleanor Johnson, assistant 
director, at (202) 512-7209. Other contributors are listed in the 
appendix. 

Sincerely yours, 

Signed by: 

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

[End of section] 

Appendix: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Regina Santucci (202) 512-6317, email: santuccir@gao.gov. 

Staff Acknowledgments: 

In addition to those above, Elspeth Grindstaff, Patrick DiBattista and 
Jon Barker made major contributions to this report. 

[End of section] 

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[End of section] 

Footnotes: 

[1] See: U.S. General Accounting Office, Early Education and Care: 
Overlap Indicates Need to Assess Crosscutting Programs, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO/HEHS-00-78] (Washington, D.C.: 
Apr. 28, 2000); Bilingual Education: Four Overlapping Programs Could Be 
Consolidated, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-01-657] 
(Washington, D.C.: May 14, 2001); and Head Start and Even Start: 
Greater Collaboration Needed on Measures of Adult Education and 
Literacy, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-02-348] 
(Washington, D.C.: Mar. 29, 2002). 

[2] U.S. General Accounting Office, Managing for Results: Using the 
Results Act to Address Mission Fragmentation and Program Overlap, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-97-146] 
(Washington, D.C.: Aug. 29, 1997). 

[3] Each year, OSEP monitors the implementation of IDEA in selected 
states. We reviewed the latest reports, published in 2001 (monitoring 
reports for Colorado, Florida, Louisiana, Maryland, New York, New 
Jersey, and Ohio) and 2000 (monitoring reports for Arizona, Arkansas, 
Massachusetts, Montana, Nebraska, and Wisconsin). We also reviewed 
older reports for Maine, Minnesota and Virginia. 

[4] Alaska, Arkansas, Arizona, California, Colorado, Delaware, Florida, 
Illinois, Nebraska, New Hampshire, New Jersey, New York, Oklahoma, 
Pennsylvania, and Rhode Island. 

[5] Chambers, Jay G., et al., What Are We Spending on Special Education 
Services in the United States, 1999-2000? Advance Report #1, Special 
Education Expenditure Project (SEEP) (Palo Alto, CA: American 
Institutes for Research, 2002). This amount does not include other 
possible federal funding sources for special education such as Title I 
of the Elementary and Secondary Education Act, Head Start, 
Developmental Disabilities Grants, and Special Education Grants for 
Infants and Families. 

[6] However, states are not required to serve children with 
disabilities ages 3 through 5 or 18 through 21 if these services are 
not consistent with state law or practice or the order of any court. 

[7] Currently 9 states—California, Hawaii, Indiana, Massachusetts, 
Nevada, New Hampshire, New Mexico, North Carolina and West 
Virginia—serve children whom they consider to be at risk. The precise 
definition of “at-risk” varies by state. 

[8] H. Rpt. No. 104-861, p. 6. 

[9] [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-97-146] and 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/HEHS-00-78]. 

[10] Readiness skills include those skills that are presumed to enable 
a child to be successful in kindergarten. Such skills include knowing 
that print reads from left to right, recognizing letters and beginning 
sounds, reading numerals, recognizing shapes, and being able to count 
to 10. 

[11] States, at their discretion, may also use the two grants to 
provide services to children ages 3 through 9 experiencing 
developmental delays as defined by the State and measured by 
appropriate instruments and procedures. (20 U.S.C. Sec. 1401(3)(B)(i).) 

[12] Early intervention services are designed to meet the developmental 
needs of an infant or toddler with a disability in any one or more of 
the following areas: physical development, cognitive development, 
communication development, social or emotional development, or adaptive 
development. (20 U.S.C. Sec. 1432 (4).) 

[13] The 50 states, the District of Columbia, American Samoa, Guam, 
Northern Mariana Islands, Puerto Rico, Virgin Islands, and the Indian 
Tribes receive School-age Grants and Infant Grants. The Freely 
Associated States (Micronesia, Marshall Islands, and Palau) are only 
eligible for School-Age Grants under a special competition. Recipients 
of Preschool Grants include the 50 states, the District of Columbia, 
and Puerto Rico. 

[14] Shelley deFosset, Section 619 Profile, 10th Edition (Chapel Hill, 
N.C.: National Early Childhood Technical Assistance System (NECTAS), 
2001.) 

[15] Arkansas reported that 59 percent of children aged 3 through 5 
received special education and related services provided in part with 
School-Age Grants. 

[16] U.S. General Accounting Office, Grant Programs: Design Features 
Shape Flexibility, Accountability and Performance Information, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/GGD-98-137] 
(Washington, D.C.: Jun. 22, 1998). 

[17] U.S. General Accounting Office, Education for Disadvantaged 
Children: Research Purpose and Design Features Affect Conclusions Drawn 
from Key Studies, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/HEHS-00-168] (Washington, D.C.: Aug. 31, 2000). 

[18] U.S. General Accounting Office, Early Childhood Programs: The Use 
of Impact Evaluations to Assess Program Effects, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-01-542] (Washington: D.C.: Apr. 
16, 2001). 

[19] Chambers, Jay G., et al., What Are We Spending on Special 
Education Services in the United States, 1999-2000? Advance Report #1, 
Special Education Expenditure Project (SEEP) (Palo Alto, CA: American 
Institutes for Research, 2002). 

[20] Maine and Minnesota are among the 14 states that have chosen to 
administer Infant Grants through their state educational agencies, 
which also administer Preschool Grants. The remaining states and the 
District of Columbia administer Infant Grants’ programs through their 
departments of health or human services. 

[21] Education Commission of the States, State Notes: State Statutes 
Regarding Kindergarten (Denver, CO: 2001). 

[End of section] 

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