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entitled 'No Child Left Behind Act: Education Should Clarify Guidance 
and Address Potential Compliance Issues for Schools in Corrective 
Action and Restructuring Status' which was released on September 5, 
2007. 

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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

September 2007: 

No Child Left Behind Act: 

Education Should Clarify Guidance and Address Potential Compliance 
Issues for Schools in Corrective Action and Restructuring Status: 

Schools in Corrective Action and Restructuring: 

GAO-07-1035: 

GAO Highlights: 

Highlights of GAO-07-1035, a report to congressional requesters. 

Why GAO Did This Study: 

The No Child Left Behind Act of 2001 (NCLBA) focused national attention 
on improving schools so that all students reach academic proficiency by 
2014. In the 2006-2007 school year, about 4,500 of the 54,000 Title I 
schools failed to make adequate yearly progress (AYP) for 4 or more 
years. Schools that miss AYP for 4 years are identified for corrective 
action, and after 6 years, they must be restructured. GAO examined (1) 
the characteristics of Title I schools in corrective action and 
restructuring; (2) the actions that schools in corrective action and 
restructuring implemented; (3) the assistance those schools received 
from districts and states; and (4) how Education supports states in 
their efforts to assist these schools. GAO administered two Web-based 
surveys to a nationwide sample of schools in corrective action and 
restructuring status and conducted site visits to five states. 

What GAO Found: 

Nationwide, the 2,790 Title I schools that were in corrective action or 
restructuring status in the 2005-2006 school year were more frequently 
located in urban areas and in a few states. These schools served higher 
percentages of minority, poor, and middle-school students than other 
Title I schools, and many report that factors such as neighborhood 
violence and student mobility pose additional challenges to improving 
student academic performance. As state proficiency targets continue to 
increase to 100 percent in 2014, the number of schools in corrective 
action and restructuring may increase. 

A majority of schools in corrective action or restructuring status 
implemented required activities. However, in some cases, schools may 
not be meeting NCLBA requirements. GAO estimates that 6 percent of 
schools did not take any of the required corrective actions and that 
about a third continued corrective actions implemented during earlier 
years of school improvement but did not take a new action after 
entering corrective action status. While this course of action may be 
an appropriate path for some schools to take, the Department of 
Education has not provided guidance to districts delineating when 
continuing a corrective action is appropriate and when it is not. In 
addition, about 40 percent of schools did not take any of the five 
restructuring options required by NCLBA. While states are required to 
report annually to the Department of Education the measures taken by 
schools in improvement status, Education does not require states to 
report on the specific measures taken for each school. 

GAO estimates that 42 percent of the schools in corrective action or 
restructuring did not receive all required types of assistance through 
their school districts, although most received discretionary assistance 
from their state educational agencies. Districts are required to ensure 
that several types of assistance are provided to all schools in 
improvement status, including those in corrective action and 
restructuring status. This assistance includes help in analyzing 
students’ assessment data and revising school budgets so that resources 
are allocated to improvement efforts. NCLBA generally does not require 
states to provide specific kinds of assistance to schools in corrective 
action or restructuring; however, they are required to develop a 
statewide system of support, including school support teams to provide 
technical assistance to schools and districts. Most schools received 
some type of assistance from the state educational agency. 

Education provides technical assistance and research results to states 
primarily through its Comprehensive Centers Program. Education also has 
provided more material in its Web-based clearinghouse to address a 
greater number of topics and is developing an initiative to outline 
practical steps for schools in improvement, including those in 
restructuring. 

What GAO Recommends: 

GAO recommends that the Secretary of Education provide guidance on when 
schools in corrective action may continue previously implemented 
corrective actions rather than implementing new ones; direct states to 
report information on activities taken by each school in corrective 
action or restructuring; and take additional steps to ascertain whether 
states are ensuring that districts provide the required assistance to 
schools. Education agreed with these recommendations. 

[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1035]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cornelia Ashby at (202) 
512-7215 or ashbyc@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Schools in Corrective Action and Restructuring Were More Often Located 
in Urban School Districts and Served Higher Percentages of Minority, 
Poor, and Middle-School Students Than Other Title I Schools: 

Most Schools Used a Corrective Action or Restructuring Option, but Some 
May Not be Meeting NCLBA Requirements: 

Many Schools in Corrective Action and Restructuring Did Not Receive All 
Required Assistance through Their School Districts; However, Most 
Received Assistance from Their State: 

Education Provides Technical Assistance and Research on School 
Improvement, Including Some Specific Information on School 
Restructuring: 

Conclusions: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Objective 1: Analysis of School Characteristics: 

Objectives 2 and 3: Implementation of Corrective Action and 
Restructuring and State and District Assistance: 

Objective 4: Education's Efforts to Support State Implementation: 

Appendix II: Number of Schools in Corrective Action, Planning for 
Restructuring, and Implementing Restructuring, by State in 2005-2006 
and 2006-2007: 

Appendix III: Comments from the Department of Education: 

Appendix IV: GAO Contacts and Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Timeline for Implementing Interventions for Schools That Do 
Not Make Adequate Yearly Progress: 

Table 2: Allowable Activities for Schools in Corrective Action and 
Restructuring: 

Table 3: NCLBA Technical Assistance Districts Are Required to Ensure 
for Schools Identified for Improvement, Including Those in Corrective 
Action and Restructuring: 

Table 4: Education, State, and District Responsibilities for Monitoring 
States, Districts, and Schools Identified for Improvement: 

Table 5: Percentage of Schools in Corrective Action and Restructuring 
and All Other Title I Schools in 2005-2006, by Locale: 

Table 6: Percentage of Schools Nationwide in Corrective Action and 
Restructuring in the Top 5 School Districts in School Year 2005-2006: 

Table 7: Percentage of Students with Selected Characteristics, 
Comparing Schools in Corrective Action and Restructuring with All Other 
Title I Schools, by Locale: 

Table 8: Percentage of Schools in Corrective Action and Restructuring 
Compared to All Other Title I Schools, by Grade Level: 

Table 9: Grade Level Definitions: 

Table 10: School Districts Selected for Site Visits: 

Table 11: Number of Schools in Corrective Action, Planning 
Restructuring, and Implementing Restructuring, by State in 2005-2006 
and 2006-2007: 

Figures: 

Figure 1: Number of Title I Schools Identified for Corrective Action, 
Planning for Restructuring, and Implementing Restructuring in 2005- 
2006: 

Figure 2: Number of Schools in Corrective Action and Restructuring in 
School Year 2005-2006, by State: 

Figure 3: Number of Schools in Corrective Action and Restructuring for 
the 3 Most Recent School Years: 

Figure 4: Change in the Number of Schools in Corrective Action and 
Restructuring from 2005-2006 to 2006-2007, by State: 

Figure 5: Corrective Actions Allowed under NCLBA and Estimated 
Percentage of Schools That Implemented Each Action in 2005-2006: 

Figure 6: Restructuring Options Allowed under NCLBA and Estimated 
Percentage of Schools That Implemented Each Option: 

Figure 7: Among Schools Implementing "Other" Major Restructuring, 
Estimated Percentage of Schools Implementing Various Activities: 

Figure 8: The Estimated Percentage of Schools in Corrective Action and 
Restructuring That Received Each Form of Required Technical Assistance 
through Districts in School Year 2005-2006: 

Figure 9: Estimated Percentage of Schools in Corrective Action and 
Restructuring in 2005-2006 That Received State Assistance: 

Figure 10: Education's Content and Regional Centers: 

Abbreviations: 

AYP: adequate yearly progress: 
CCD: Common Core of Data: 
CSPR: Consolidated State Performance Reports: 
Education: Department of Education: 
ESEA: Elementary and Secondary Education Act of 1965: 
IASA: Improving America's Schools Act of 1994: 
NCLBA: No Child Left Behind Act of 2001: 
SES: supplemental education services: 

United States Government Accountability Office: 

Washington, DC 20548: 

September 5, 2007: 

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

The Honorable Christopher J. Dodd: 
Chairman: 
The Honorable Lamar Alexander: 
Ranking Member: 
Subcommittee on Children and Families: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

Over the past 40 years, the Elementary and Secondary Education Act of 
1965 (ESEA) has authorized billions of dollars in federal grants to 
states and school districts to improve educational opportunities for 
economically disadvantaged students. Despite this investment, the 
academic performance of disadvantaged students is still substantially 
lower than that of more advantaged students. Congress, with the 
enactment of the No Child Left Behind Act of 2001 (NCLBA)[Footnote 1]-
-the most recent reauthorization of ESEA--sought to address this issue 
by holding public schools accountable for the academic performance of 
their students by requiring that all students reach proficiency in 
reading, math, and science by 2014. In particular, districts and 
schools receiving funds under Title I of NCLBA are required to take 
certain actions when students do not make sufficient progress toward 
meeting state proficiency targets.[Footnote 2] However, many Title I 
schools, which comprise over half of all public schools and serve about 
26 million students, continue to struggle to raise student achievement. 
In the 2006-2007 school year, about one-fifth of the 54,000 Title I 
schools had failed to make adequate yearly progress (AYP) for at least 
2 consecutive years, and about 4,500 of these schools had not made AYP 
for 4 or more years. Under NCLBA, when a Title I school does not make 
AYP for 4 years, the school enters corrective action, and the district 
must take a statutorily prescribed action to improve the school, such 
as replacing selected teaching staff. If the school fails to make AYP 
for 6 years, the district is required to restructure the school by 
changing how the school is governed.[Footnote 3] Such changes may 
include closing the school and re-opening it as a charter school or 
turning the operation of the school over to the state educational 
agency. As annual goals leading up to the 2014 deadline continue to 
increase, more schools are expected to enter corrective action and 
restructuring and will be required to take major action to improve. 

However, little is known about what specific corrective actions or 
restructuring options schools are currently implementing nationwide, 
the extent to which these actions are associated with making AYP, and 
the support that schools in corrective action and restructuring have 
received from school districts and states as they attempt to improve 
student performance. In order to shed light on these issues and help 
the Congress prepare for reauthorization of the NCLBA, you asked GAO to 
answer the following questions: (1) What are the characteristics of 
Title I schools in corrective action and restructuring? (2) To what 
extent have schools in corrective action and restructuring implemented 
corrective actions or restructuring options? (3) What assistance have 
schools in corrective action and restructuring received from districts 
and states? and (4) How has the Department of Education (Education) 
supported states in their efforts to assist schools in corrective 
action and restructuring status? 

To provide information on these topics, we collected data through 
multiple methods. We obtained data on which schools were in corrective 
action and restructuring for the 2005-2006 school year. States reported 
these data to Education through the Consolidated State Performance 
Report process, which collects annual information from states on ESEA 
programs. We matched data on these schools with additional data in 
Education's Common Core of Data (CCD), conducted descriptive analyses 
of selected characteristics, and compared them to all other Title I 
schools. We also administered two Web-based surveys sent to 470 
principals in a nationwide sample of schools in corrective action and 
restructuring during the 2005-2006 school year. We administered the 
surveys between January and March 2007 and received a combined response 
rate of about 70 percent. Percentage estimates from the surveys have 
margins of error of plus or minus 8 percentage points using a 95 
percent confidence interval, unless otherwise noted. While we did not 
fully validate specific information that school officials reported in 
our survey, we took several steps, including corroborating evidence of 
some schools' improvement status, to ensure that the information 
provided by school officials was sufficiently reliable for the purposes 
of this report. We conducted site visits to 5 states (California, 
Illinois, Maryland, New York, and Pennsylvania) and 10 school districts 
with schools in corrective action, restructuring, or both, as well as 
20 schools in those districts. The states, districts, and schools 
selected for site visits not only provided variation across such 
characteristics as geographic location and district size, but also 
generally resembled all schools in corrective action and restructuring 
in terms of students' racial, ethnic, and economic characteristics. 
Together, schools in these 5 states accounted for over 59 percent of 
schools in corrective action and restructuring nationally in the 2005- 
2006 school year. We also interviewed state officials from several 
states (Idaho, South Dakota, Texas, and Virginia) that had few schools 
in correction action or restructuring to obtain information on how 
their state educational agencies are working with districts on school 
improvement issues. We reviewed relevant federal laws, regulations, and 
agency guidance and interviewed Education officials to obtain 
information about how they monitor and provide assistance to states and 
districts. We also interviewed officials in some of Education's 
comprehensive and regional assistance centers. We analyzed relevant 
Education documents and studies and reports issued by policy and 
research organizations on schools in corrective action and 
restructuring and interviewed staff in many of these organizations. See 
appendix I for detailed information on both surveys as well as our 
other data collection methods. We conducted our work from August 2006 
through August 2007 in accordance with generally accepted government 
auditing standards. 

Results in Brief: 

The 2,790 Title I schools nationwide in corrective action and 
restructuring status in the 2005-2006 school year--comprising about 5 
percent of all Title I schools and serving over 2 million students-- 
were more frequently located in urban school districts and a few states 
and served higher percentages of poor, minority, and middle-school 
students than other Title I schools. Nationwide, almost two-thirds of 
the 1,155 corrective action and 1,635 restructuring schools were in 
urban districts, compared to about one-quarter of other Title I 
schools. Five states--California, Illinois, Michigan, New York, and 
Pennsylvania--collectively had over 60 percent of these schools, but 
less than 30 percent of all Title I schools. When compared to all other 
Title I schools, those in corrective action and restructuring served 
more than twice as many racial or ethnic minority students--96 percent 
compared to 37 percent--and a higher percentage of students who were 
economically disadvantaged--83 percent compared to 54 percent. More 
than twice as many of these schools served middle school students as 
compared to all other Title I schools. Nationwide, the number of 
schools in corrective action and restructuring increased substantially 
to 4,509 in the 2006-2007 school year from 2,790 in the previous year. 
As state proficiency targets continue to increase until they reach 100 
percent by 2014, the number of schools in corrective action and 
restructuring may grow, because many schools now in early stages of 
improvement may continue to struggle to make AYP. 

Though many schools had implemented a corrective action or 
restructuring option, some schools may not be meeting NCLBA 
requirements. Among schools in corrective action status, we estimate 
that 94 percent implemented at least one required corrective action and 
that about three-quarters used more than one corrective action. Hiring 
an outside expert and changing the internal structure of the school 
were the most frequently implemented actions, with each implemented by 
about 60 percent of schools. However, based on our survey, we estimate 
that 6 percent of schools did not take any of the required corrective 
actions. About a third continued corrective actions implemented during 
earlier years of school improvement after entering corrective action 
status. Education officials told us that if a school had previously 
implemented a corrective action, an additional action might not be 
required if the school provided evidence that the intervention is 
producing results that are likely to enable the school to exit 
improvement status. As of July 2007, Education had not developed 
guidance on when continuing prior actions without implementing a new 
one is acceptable. About 60 percent of schools in restructuring 
implemented a restructuring option as required by NCLBA, and the two 
most frequently selected options were "other" major restructuring, such 
as reconfiguring the grade levels served by the school, and replacing 
selected school staff. Yet many schools in restructuring may not have 
undertaken restructuring options as prescribed under NCLBA. States are 
required to report annually to Education on the measures taken to 
address the achievement problems of schools in improvement status, 
including schools in corrective action and restructuring. However, 
Education does not require states to report on the specific measures 
taken for each school, and therefore, the department has limited 
information on whether states have found that some districts may not be 
in compliance with NCLBA requirements. A much higher percentage of 
schools that fully implemented activities, regardless of which activity 
they chose, made AYP compared with those that had not fully implemented 
activities. Nevertheless, we found that no one particular corrective 
action or restructuring option was associated with making AYP, nor was 
the number of activities undertaken associated with AYP. 

We estimate that 42 percent of the schools in corrective action and 
restructuring did not receive all required types of assistance through 
their school district, although most received discretionary assistance 
from their state educational agency. Districts are required to ensure 
that several types of assistance are provided to all schools in 
improvement status, including those in corrective action and 
restructuring. This assistance ranges from analyzing student assessment 
data to revising school budgets so that resources are allocated to 
improvement efforts. NCLBA generally does not require states to provide 
specific kinds of assistance to schools in corrective action and 
restructuring. However states are required to develop a statewide 
system of support, including school support teams that are available to 
provide technical assistance to schools and districts. We estimate that 
most schools received some type of assistance from the state. For 
example, 60 percent of schools received assistance from a state support 
team and almost two-thirds received help from instructional experts or 
highly skilled educators. Additionally, almost half of the schools 
received state funds that were used for school improvement activities 
such as professional development. 

Education provides technical assistance and research primarily through 
its Comprehensive Centers Program. The department replaced its former 
assistance centers and various education consortiums with 16 regional 
centers and 5 content centers to meet the requirements of the Education 
Sciences Reform Act of 2002. These centers are to help low performing 
schools and districts close achievement gaps and meet the goals of 
NCLBA. The centers provide assistance and research to states on 
developing approaches for improving schools. In addition, Education has 
expanded the material in its Web-based What Works Clearinghouse to 
address a greater number of topics and revised its district and school 
improvement guidance by adding more material on school restructuring. 
While the clearinghouse had little information on promising practices 
for schools in corrective action and restructuring, Education is 
developing an initiative targeted to principals, teachers, and other 
educators that is to develop practical steps to improve schools on the 
basis of scientifically based research identified by the clearinghouse 
and may have information on school restructuring by the end of 2007. 

To enhance school efforts to increase student achievement, we recommend 
that Education provide guidance to districts on when schools may 
continue previously implemented corrective actions rather than taking 
new ones. We also recommend that Education obtain more specific 
information from states on the specific improvement activities 
implemented by each school in corrective action and restructuring as 
well as more specific information on compliance issues states 
identified as part of their monitoring activities. Finally, we 
recommend that the department take additional steps through its 
monitoring process to ascertain whether states are ensuring that 
districts provide the assistance required by NCLBA. Education agreed 
with our recommendations and stated it would explore options for 
providing more guidance, gathering additional information from states, 
and improving its monitoring activities. 

Background: 

Under NCLBA, states are required to establish performance goals and 
hold their Title I schools accountable for students' performance by 
determining whether or not schools have made AYP. Schools that have not 
met their state's performance goals for 2 or more consecutive years are 
identified for improvement and must implement certain activities that 
are meant to improve student academic achievement. Districts and states 
play a role in this process by providing technical assistance to 
schools. In addition, states are responsible for monitoring district 
and school compliance with NCLBA. Education provides states and 
districts with guidance on school improvement and monitors states for 
compliance with NCLBA requirements. 

States and Districts Are Held Accountable for the Performance of Their 
Schools and Must Take Action to Improve Student Achievement When 
Schools Do Not Make AYP for 2 or More Years: 

Prior to NCLBA, the Congress attempted to hold states accountable for 
the annual performance of their schools by requiring them to collect 
assessment data, develop criteria to determine whether schools and 
districts were performing satisfactorily, and conduct student 
assessments. The 1994 reauthorization of ESEA--Improving America's 
Schools Act (IASA)--required that schools be designated for improvement 
for failure to make AYP for 2 consecutive years and that districts take 
corrective action as a final intervention for schools that repeatedly 
missed AYP.[Footnote 4] However, under IASA states assessed AYP in 
different ways and used different measures to evaluate school 
performance. NCLBA added several new provisions to address these 
differences and to strengthen accountability. These provisions include: 

* The requirement that states develop plans that include academic 
standards and establish performance goals for meeting AYP that would 
lead to 100 percent of their students being proficient in reading, 
mathematics, and science by 2014.[Footnote 5] To measure their 
progress, states were required to establish academic proficiency goals 
for making AYP and to administer an annual assessment to students in 
most grade levels.[Footnote 6] In addition, each school's assessment 
data must be disaggregated in order to compare the achievement levels 
of students within certain designated groups with the state's 
proficiency targets. These student groups include the economically 
disadvantaged, major racial and ethnic groups, students with 
disabilities, and those with limited English proficiency, and each of 
these groups generally must make AYP in order for the school to make 
AYP. 

* A timeline for implementing specific interventions based on the 
number of years the school missed AYP.[Footnote 7] For a school that 
fails to meet AYP for 2 consecutive years, districts must offer 
students in these schools the opportunity to transfer to a higher- 
performing public school in the district, and after the third year, 
they must also offer supplemental education services (SES), such as 
tutoring. In addition, the school must also develop an improvement plan 
in consultation with the district, school staff, parents, and outside 
experts. These plans, which are subject to district approval, must 
incorporate strategies to address the specific academic issues that 
caused the school to be identified for improvement. Under NCLBA, if a 
school fails to make AYP for 4 consecutive years, it is required to 
implement one of the corrective actions identified in the legislation. 
In addition, a new intervention to change the governance of schools-- 
school restructuring--was introduced for schools that miss AYP for 5 or 
more years. (See table 1.) Districts are responsible for selecting and 
implementing the corrective actions and restructuring options for these 
schools. Schools exit improvement status if they make AYP for 2 
consecutive years. 

Table 1: Timeline for Implementing Interventions for Schools That Do 
Not Make Adequate Yearly Progress: 

Adequate yearly progress: First year missed; 
School status in the next year: Not Applicable; 
NCLBA interventions for Title I schools: None. 

Adequate yearly progress: Second year missed; 
School status in the next year: Needs Improvement (First Year of 
Improvement); 
NCLBA interventions for Title I schools: Required to offer public 
school choice[A]. 

Adequate yearly progress: Third year missed; 
School status in the next year: Needs Improvement (Second Year of 
Improvement); 
NCLBA interventions for Title I schools: Required to offer public 
school choice and SES. 

Adequate yearly progress: Fourth year missed; 
School status in the next year: Corrective Action (Third Year of 
Improvement); 
NCLBA interventions for Title I schools: Implement certain corrective 
actions and offer public school choice and SES. 

Adequate yearly progress: Fifth year missed; 
School status in the next year: Planning for Restructuring (Fourth Year 
of Improvement); 
NCLBA interventions for Title I schools: Plan for a change in 
governance and offer public school choice and SES[B]. 

Adequate yearly progress: Sixth year missed; 
School status in the next year: Implementation of Restructuring (Fifth 
Year of Improvement); 
NCLBA interventions for Title I schools: Implement a change in 
governance and offer public school choice and SES. 

Source: GAO analysis of NCLBA and Education's regulations. 

[A] At this stage, the school must also develop the school improvement 
plan. 

[B] While NCLBA does not require that corrective actions must be 
continued after a school enters restructuring, Education officials 
noted that in practice, many schools continue corrective actions after 
entering restructuring status. 

[End of table] 

Schools in corrective action must implement at least one of six 
activities such as replacing selected school staff or implementing a 
new curriculum.[Footnote 8] Schools that do not make AYP after 5 years 
must plan for restructuring, which means that the district must decide 
how to change the school's governance. Restructuring, the most severe 
of the NCLBA interventions, requires that the school implement a major 
change to how the school is operated, such as reorganizing into a 
public charter school or contracting with an outside organization such 
as a private management company to operate the school.[Footnote 9] If 
the school does not make AYP during the planning phase, the school 
enters restructuring. The corrective action and restructuring 
activities allowed under NCLBA are shown below in table 2. NCLBA does 
not address actions that districts must take after implementing 
restructuring and the school continues to fail to make AYP. Education 
officials said that they have encouraged states and districts to 
continue to try different interventions with these schools. 

Table 2: Allowable Activities for Schools in Corrective Action and 
Restructuring: 

Corrective actions: The district must implement at least one of the 
following actions: 

* Replace the school staff who are relevant to the failure to make AYP; 
* Institute and fully implement a new curriculum; 
* Significantly decrease management authority at the school level; 
* Appoint an outside expert to advise the school on its progress toward 
making adequate yearly progress; 
* Extend the school year or the school day; 
* Restructure the internal organizational structure of the school; 
Restructuring options: The district must implement at least one of the 
following options: 
* Reopen the school as a charter school; 
* Replace all or most of the school staff (which may include the 
principal) who are relevant to the failure to make AYP; 
* Contract with another organization or company to operate the school; 
* Turn the operation of the school over to the state; 
* Implement any other major restructuring of the school's governance, 
such as: 
- Expand or narrow the grades served;; 
- Close the school and re-open it as a theme school (for example, a 
math and science academy). 

Source: GAO analysis of NCLBA (20 U.S.C. § 6316(b)(7) and (8)) and 
Education's guidance. 

[End of table] 

Both Districts and States Provide Technical Assistance to Schools in 
Improvement: 

The school district bears the primary responsibility for ensuring that 
its schools in improvement, including those in corrective action and 
restructuring, receive technical assistance, although the state also 
plays a role in providing assistance. The purpose of the district's 
assistance is to strengthen and improve the school's instructional 
program by helping the school address the issues that caused it to make 
inadequate progress in student achievement.[Footnote 10] Specifically, 
the district must ensure that each school identified for improvement 
receives assistance based on scientifically based research in three 
areas: analysis of student assessment data, identifying and 
implementing instructional strategies, and analysis of the school 
budget, as shown in table 3 below.[Footnote 11] 

Table 3: NCLBA Technical Assistance Districts Are Required to Ensure 
for Schools Identified for Improvement, Including Those in Corrective 
Action and Restructuring: 

Data analysis; 
The district must ensure that school staff receive assistance in 
analyzing student assessment data to identify and develop solutions in 
areas such as: 
* Instructional deficiencies; 
* Parental involvement and professional development requirements. 

Identification and implementation of strategies; 
The district must ensure that the school receives help to identify and 
implement: 
* Instructional strategies and methods that are grounded in 
scientifically based research and address specific issues that cause 
the school to be identified for improvement; 
* Professional development relevant to implementation of such 
strategies and methods. 

Budget analysis; 
The district must ensure that the school is provided with: 
* Assistance in analyzing and revising its budget to fund activities 
most likely to increase student achievement. 

Source: GAO analysis of NCLBA. 

[End of table] 

The state educational agencies are also responsible for making several 
forms of technical assistance available to schools in improvement and 
overseeing the improvement activities of districts. States generally 
are required to reserve and allocate 4 percent of the state's total 
Title I allocation for school improvement activities, with 95 percent 
of these funds going directly to the districts. States are to 
prioritize their assistance to districts that, among other things, 
serve the lowest achieving schools, such as those in corrective action 
and restructuring. They also are required to develop and sustain a 
statewide system of support that provides technical assistance to 
schools, with a priority given to those in improvement status. In 
addition, in developing the statewide system of support, the state 
agency must: 

* Establish school support teams to work in schools throughout the 
state that are identified for improvement. The purpose of these teams 
is to assist schools to strengthen their instructional programs and 
must include individuals who are knowledgeable about scientifically 
based research and practice and its potential for improving teaching 
and learning. 

* Designate and use distinguished teachers and principals who are 
chosen from Title I schools and have been especially successful in 
improving academic achievement. 

* Devise additional approaches to improve student performance, for 
example, by drawing on the expertise of other entities, such as 
institutions of higher education, educational service agencies, or 
private providers of scientifically based technical assistance. 

Education Provides Assistance to States and Districts and Monitors for 
Compliance: 

Education provides assistance to states in implementing NCLBA and 
monitors states for compliance. Specifically, Education provides 
assistance to states and districts in several ways such as issuing 
regulations, providing guidance and policy letters, and through its 
comprehensive centers. For example, the department published 
nonregulatory guidance that was specific to schools in improvement and 
provided information on the actions that districts and states must take 
to reform their schools in compliance with NCLBA.[Footnote 12] To help 
build the capacity of states to meet NCLBA goals, Education awarded 
almost $57 million in fiscal year 2006 to the 21 comprehensive centers. 
These include 16 regional centers established to provide technical 
assistance to states within defined geographic areas. In addition, 
Education established five content centers that work closely with the 
regional centers to provide technical assistance to states on school 
improvement. One content center focuses on school improvement issues. 

Education monitors each state agency to determine, among other issues, 
whether the state is ensuring that districts are implementing NCLBA 
requirements for school improvement. Education, the state agency, and 
districts all play a role in ensuring that schools are meeting NCLBA 
requirements. Their monitoring responsibilities are presented in table 
4. 

Table 4: Education, State, and District Responsibilities for Monitoring 
States, Districts, and Schools Identified for Improvement: 

Stakeholder: Education; 
Roles and responsibilities: Monitor states to assess the extent to 
which states provide leadership and guidance for districts and schools 
in implementing policies and procedures that comply with NCLBA. 

Stakeholder: State educational agency; 
Roles and responsibilities: Monitor districts to ensure they are: 
* Meeting NCLBA requirements for such things as school choice, 
providing SES, and providing technical assistance to schools identified 
for improvement;; 
* Providing guidance to their Title I schools to ensure they are 
complying with NCLBA program requirements; 
and; 
* Ensuring that schools identified for improvement, corrective action, 
or restructuring implement required activities. 

Stakeholder: School district; 
Roles and responsibilities: Monitor Title I schools identified for 
improvement for developing the school improvement plan and 
implementation of school improvement activities, including parental 
involvement activities. 

Source: GAO analysis of NCLBA and Education's monitoring plan for Title 
I programs. 

[End of table] 

Education monitors states in two ways: (1) routinely gathers and 
analyzes data collected from Web-based searches and documents, such as 
Consolidated State Performance Reports,[Footnote 13] and (2) on-site 
visits at least once every 3 years to monitor state compliance with 
Title I. During these site visits, states are monitored to ensure that 
they are complying with Title I program requirements, which includes 
providing the necessary guidance and support to schools that are in 
improvement, including those in corrective action and restructuring. In 
addition, according to Education's monitoring guidelines, Education 
officials visit selected districts in each state and ask for evidence 
on how schools are implementing required actions and meeting 
timeframes. Once the review is complete, Education issues a report to 
the state containing findings, recommendations, and required actions 
needed to address identified problems. A state is generally given 30 
business days to respond to the findings and required actions and also 
to provide a timeline for addressing each issue. A state with 
significant findings may have conditions attached to its Title I Grant 
and if it fails to adequately address the identified deficiencies, the 
Secretary generally may withhold the state's Title I funds that are 
used for state administration until all requirements have been 
satisfied. 

Schools in Corrective Action and Restructuring Were More Often Located 
in Urban School Districts and Served Higher Percentages of Minority, 
Poor, and Middle-School Students Than Other Title I Schools: 

Schools in corrective action and restructuring status in the 2005-2006 
school year were more frequently located in urban school districts and 
a few states and served higher percentages of minority, poor, and 
middle-school students than other Title I schools.[Footnote 14] In the 
2005-2006 school year, 2,790 Title I schools were in corrective action, 
planning for restructuring, or implementing restructuring (see fig. 1). 
These schools comprised about 5 percent of all Title I schools and 
served over 2 million students. Data for the 2006-2007 school year show 
that the numbers of schools in corrective action and restructuring are 
growing, a trend that is likely to continue. 

Figure 1: Number of Title I Schools Identified for Corrective Action, 
Planning for Restructuring, and Implementing Restructuring in 2005- 
2006: 

[See PDF for image] 

Source: GAO analysis of Education data. 

[End of figure] 

Schools in Corrective Action and Restructuring Were Concentrated in 
Urban Areas and a Few States: 

Schools in corrective action and restructuring were predominantly 
located in urban areas, especially compared to all other Title I 
schools, as shown in table 5. 

Table 5: Percentage of Schools in Corrective Action and Restructuring 
and All Other Title I Schools in 2005-2006, by Locale: 

Locale: Urban; 
Schools in corrective action and restructuring: 63; 
All other Title I schools: 27. 

Locale: Suburban; 
Schools in corrective action and restructuring: 22; 
All other Title I schools: 26. 

Locale: Town/Rural; 
Schools in corrective action and restructuring: 15; 
All other Title I schools: 44. 

Source: GAO analysis of data provided by Education. 

Note: Locale data for 3 percent of all other Title I schools were 
missing. 

[End of figure] 

Examples of urban areas with relatively higher numbers of schools in 
corrective action and restructuring include Chicago, Detroit, Los 
Angeles, New York, and Philadelphia. Nationwide, school districts in 
these 5 cities alone contained over 25 percent of all schools in 
corrective action and restructuring, as shown in Table 6. By 
comparison, these 5 districts contained less than 4 percent of all 
other Title I schools. 

Table 6: Percentage of Schools Nationwide in Corrective Action and 
Restructuring in the Top 5 School Districts in School Year 2005-2006: 

School district: City of Chicago; 
Schools in corrective action and restructuring: 10. 

School district: New York City; 
Schools in corrective action and restructuring: 7. 

School district: Los Angeles Unified; 
Schools in corrective action and restructuring: 3. 

School district: Philadelphia City; 
Schools in corrective action and restructuring: 3. 

School district: Detroit City; 
Schools in corrective action and restructuring: 2. 

Source: GAO analysis of data provided by Education. 

Note: Three other school districts (local educational agencies) each 
had 2 percent of the total of schools in corrective action and 
restructuring: Hawaii Department of Education (56 schools), the 
District of Columbia Public Schools (45 schools), and Baltimore City 
Public Schools (42 schools). The Hawaii Department of Education and the 
District of Columbia Public Schools each serves simultaneously as a 
state educational agency and a local educational agency (school 
district). New York City reported its number of schools by regions 
within the school district. For our report, we summed across regions 
within New York City to arrive at one number for the district as a 
whole. 

[End of table] 

Consequently, schools in corrective action and restructuring were 
concentrated in a few states. Five states--Illinois, New York, 
California, Pennsylvania and Michigan--collectively had over 60 percent 
of these schools, but less than 30 percent of all Title I schools 
nationwide. In contrast, a majority of states had 20 or fewer schools 
in corrective action and restructuring, as shown in figure 2. 

Figure 2: Number of Schools in Corrective Action and Restructuring in 
School Year 2005-2006, by State: 

[See PDF for image] 

Source: GAO analysis of Education data; (Map), Map Resources. 

[End of figure] 

In general, states with large numbers of schools identified for 
improvement when NCLBA was passed had more schools in corrective action 
and restructuring in the 2005-2006 school year than those with few 
schools in improvement in 2001.[Footnote 15] Prior to NCLBA, states had 
identified schools for improvement, and when NCLBA was passed in the 
2001-2002 school year, it generally required states to maintain the 
prior improvement status of schools.[Footnote 16] Consequently, many 
schools that were in earlier stages of improvement in school year 2001- 
2002 entered corrective action and restructuring in subsequent years. 

Schools in Corrective Action and Restructuring Served a Higher 
Percentage of Minority, Economically Disadvantaged, and Middle School 
Students, Compared to All Other Title I Schools: 

Schools in corrective action and restructuring also had a much higher 
percentage of racial or ethnic minority students compared to all other 
Title I schools (96 percent compared to 37 percent) and also enrolled a 
higher percentage of economically disadvantaged students (83 percent 
compared to 54 percent).[Footnote 17] These differences varied 
substantially when the location of the school is accounted for, as seen 
in table 7. 

Table 7: Percentage of Students with Selected Characteristics, 
Comparing Schools in Corrective Action and Restructuring with All Other 
Title I Schools, by Locale: 

Locale: Urban; 
Schools in corrective action and restructuring: Minority status: 98; 
All other Title I schools: Minority status: 84. 

Locale: Suburban; 
Schools in corrective action and restructuring: Minority status: 93; 
All other Title I schools: Minority status: 34. 

Locale: Rural/Town; 
Schools in corrective action and restructuring: Minority status: 93; 
All other Title I schools: Minority status: 11. 

Locale: Urban; 
Schools in corrective action and restructuring: Poverty status: 83; 
All other Title I schools: Minority status: 70. 

Locale: Suburban; 
Schools in corrective action and restructuring: Poverty status: 81; 
All other Title I schools: Minority status: 45. 

Locale: Rural/Town; 
Schools in corrective action and restructuring: Poverty status: 83; 
All other Title I schools: Minority status: 49. 

Source: GAO analysis of data provided by Education. 

Note: The table shows the percentage of students who are members of 
racial or ethnic minority groups or who qualified for free-or reduced- 
priced meals in the median schools (by locale) when all schools were 
ranked by the percent of those characteristics in the schools. 

[End of table] 

Schools in corrective action and restructuring varied in terms of the 
grade level of students that they served. Compared with all other Title 
I schools, middle schools were considerably over-represented among 
schools in corrective action and restructuring while primary schools 
were underrepresented, as seen in table 8.[Footnote 18] 

Table 8: Percentage of Schools in Corrective Action and Restructuring 
Compared to All Other Title I Schools, by Grade Level: 

Grade level: Primary; 
Schools in corrective action and restructuring: 52; 
All other Title I schools: 70. 

Grade level: Middle; 
Schools in corrective action and restructuring: 32; 
All other Title I schools: 15. 

Grade level: High; 
Schools in corrective action and restructuring: 12; 
All other Title I schools: 10. 

Grade level: Other; 
Schools in corrective action and restructuring: 4; 
All other Title I schools: 5. 

Source: GAO analysis of data provided by Education. 

Note: For the purposes of our analysis, we used the definitions of 
primary, middle, and high schools provided in the CCD, as described in 
appendix I of this report. 

[End of table] 

Several factors might explain why middle schools are over-represented. 
Evidence from the National Assessment of Educational Progress-- 
especially for many of the urban school districts with numerous schools 
in corrective action or restructuring--shows that the percentage of 
students who score at a proficient level or above in math is generally 
lower in middle schools than in elementary schools.[Footnote 19] Other 
factors may also include being less qualified than their peers in 
elementary or middle schools, teachers in middle schools, and social 
and emotional challenges associated with students as they make the 
transition into middle schools.[Footnote 20] Yet another reason may be 
that because of NCLBA provisions about the minimum number of students 
in a school that would comprise a designated student subgroup, middle 
schools typically have to make AYP for more student subgroups than 
elementary schools.[Footnote 21] 

The Number of Schools in Corrective Action and Restructuring Has 
Increased Considerably from Last Year and May Continue to Do So: 

Data for the 2006-2007 school year showed that the number of schools in 
corrective action and restructuring has increased. In 2006-2007, there 
were 4,509 schools in corrective action and restructuring compared to 
2,790 the year before, an increase of over 60 percent, and more than 
twice as many schools compared to just 2 years earlier. (See fig. 3.) 

Figure 3: Number of Schools in Corrective Action and Restructuring for 
the 3 Most Recent School Years: 

[See PDF for image] 

Source: GAO analysis of Education data. 

Note: For the 2004-2005 school year, we used data from the National 
Assessment of Title I: Interim Report which had only one category for 
schools in restructuring and did not distinguish between schools 
planning for restructuring and those implementing restructuring. Also, 
this report, which was not updated, included data from some states that 
had not completed decisions for schools appealing their improvement 
status, resulting in fewer schools ultimately identified than was 
reported. 

[End of figure] 

Additionally, 41 states had more schools in corrective action and 
restructuring whereas only 8 states had fewer.[Footnote 22] (See fig. 4 
and see app. II for a comprehensive list of the number of schools in 
corrective action and restructuring in each state.) Most notably, in 
2006-2007, the state of Florida had 574 schools in those categories 
compared to only 32 such schools in 2005-2006. According to a Florida 
state official, this increase is attributable to the fact that many 
schools have been struggling to meet the increasing proficiency 
targets. Other states with large increases include California (increase 
of 376 schools) and Massachusetts (increase of 118 schools). A few 
states, such as Michigan, had fewer schools in corrective action and 
restructuring in 2006-2007 compared to the prior year. In Michigan's 
case, it is not clear whether the decrease was related to state or 
district reform efforts, changes in criteria making it easier for 
schools to make AYP, or some combination of these factors.[Footnote 23] 

Figure 4: Change in the Number of Schools in Corrective Action and 
Restructuring from 2005-2006 to 2006-2007, by State: 

[See PDF for image] 

Source: GAO analysis of Education data, (Map) Map Resources. 

[End of figure] 

The general trend toward higher numbers of schools in corrective action 
and restructuring may continue. As of the 2006-2007 school year, more 
schools were identified for improvement than at any time since such 
data were tracked under IASA. As proficiency targets continue to 
increase up to 100 percent by 2014, many schools identified for 
improvement may not make AYP. Consequently, if these schools cannot 
meet the increasing proficiency targets, they will enter corrective 
action and ultimately restructuring. 

Most Schools Used a Corrective Action or Restructuring Option, but Some 
May Not be Meeting NCLBA Requirements: 

Our survey results indicated that a majority of schools in corrective 
action and restructuring implemented required activities; however, in 
some cases schools may not be in compliance with NCLBA 
requirements.[Footnote 24] Although many schools in corrective action 
implemented multiple corrective actions, some did not take any 
corrective action. A majority of restructuring schools implemented a 
required restructuring option, but based on our survey results, about 
40 percent of schools did not take any of the 5 restructuring options 
required by NCLBA, one of which is a broad category referred to as 
"other" major restructuring. Although there was no relationship between 
any of the specific activities and whether a school made AYP, a higher 
percentage of schools that fully implemented improvement activities 
made AYP compared with those that had not fully implemented activities. 

Among Schools in Corrective Action, Almost All Took at Least One 
Corrective Action, but Some May Not Have Taken an Action As Required by 
NCLBA: 

Among schools in corrective action status, we estimate that 94 percent 
implemented at least one corrective action from those specifically 
identified by NCLBA, and about three-quarters had used more than one 
corrective action. Hiring an outside expert and changing the internal 
structure of the school were the most frequent actions, with each 
implemented by about 60 percent of schools. Outside experts are used to 
advise the school on its progress toward making adequate yearly 
progress. Among schools that changed their internal structures, about 
85 percent increased small group work and about 75 percent reorganized 
the school schedule to increase opportunities for professional 
development. Many schools also reduced class size, created small 
learning communities, and implemented team teaching as part of the 
changes to the organizational structure. In addition to hiring outside 
experts and changing internal structure, about 40 percent of schools 
changed the curriculum. A smaller percentage of schools implemented 
certain forms of corrective actions such as extending the school year 
or day or decreasing management authority at the school level. Some 
officials explained that extending the school year or day would be 
costly to the district because teacher salaries may have to increase to 
compensate for the additional instructional time. For the majority of 
schools, district officials played a significant role in determining 
the action taken. Figure 5 shows the allowed corrective actions and the 
percentage of schools implementing each action. 

Figure 5: Corrective Actions Allowed under NCLBA and Estimated 
Percentage of Schools That Implemented Each Action in 2005-2006: 

[See PDF for image] 

Source: GAO survey. 

Note: These sum to more than 100 percent because some schools 
implemented more than one action. 

[End of figure] 

Based on our survey, we estimate that 6 percent of schools in 
corrective action status did not take corrective actions. For example, 
in one school we visited, the principal told us that the school had not 
implemented any changes during its year in corrective action. He told 
us that the district provided no input on the required actions and that 
the state educational agency approved the school improvement plan 
without comment. 

About a third of schools that went into corrective action in 2005-2006 
did not take a new corrective action in that year. These schools took 
corrective action in earlier years of improvement and did not implement 
any further corrective actions after entering corrective action status. 
For example, some schools indicated that the school used an outside 
expert or implemented a new curriculum in previous school years and had 
not implemented any additional corrective actions the year in which the 
school entered corrective action status. Education officials told us 
that if a school implemented a corrective action in earlier stages of 
improvement (year 1 or 2 of improvement), an additional corrective 
action might not be required. They explained that whether a district 
must take additional actions depends in part on whether the school is 
showing improvement in student achievement. If the school showed 
evidence that the intervention is producing results that are likely to 
enable the school to exit improvement status, an additional corrective 
action might not be necessary. On the other hand, Education officials 
noted that if the data indicates that the previous corrective actions 
have not addressed the school's achievement problems they would expect 
the district to take additional corrective action. While it may be 
appropriate in some cases for schools to continue implementing the same 
actions, Education officials acknowledged that they have not provided 
written guidance on when continuing prior actions without implementing 
a new one would be acceptable. 

Department officials told us that while they had conducted Title I 
monitoring in every state, they had not found compliance issues 
specifically related to corrective action from their monitoring visits. 
States are required to conduct annual reviews of district progress in 
part to ensure that districts are carrying out their responsibilities, 
one of which is taking at least one corrective action when necessary. 
However, states generally do not report to Education district 
noncompliance, such as failure to take corrective actions as required. 
Under NCLBA, states are required to annually submit to Education and 
make widely available the measures taken to address the achievement 
problems of schools in improvement status, including schools in 
corrective action. However, Education does not require states to report 
on the measures taken for each school. Instead, Education requires 
states to provide a brief summary of the measures taken across the 
state. Consequently, Education lacks information on which action was 
taken by each school, whether schools are taking actions at all, and 
whether or not states have taken any actions against schools or 
districts for failure to comply with NCLBA. 

Among Schools in Restructuring, Almost Two-Thirds Implemented a 
Restructuring Option; However, Many Schools May Not Be in Compliance 
with NCLBA Requirements: 

We estimate that a majority of schools in restructuring had implemented 
at least one of the five restructuring options allowed by 
NCLBA.[Footnote 25] According to NCLBA, each of these options is to 
result in a major change to the school's governance. As figure 6 shows, 
about 40 percent of the schools implemented the "other" major 
restructuring of the school's governance, which can include such 
actions as expanding or narrowing the grades served or creating smaller 
learning communities within the school.[Footnote 26] We estimate that 
27 percent of schools replaced all or most of the staff related to the 
school's performance issues. 

Figure 6: Restructuring Options Allowed under NCLBA and Estimated 
Percentage of Schools That Implemented Each Option: 

[See PDF for image] 

Source: GAO survey. 

[End of figure] 

Of the 40 percent of schools that selected "other" major restructuring 
of the school's governance, 44 percent created smaller learning 
communities--an approach taken by some of the schools we 
visited.[Footnote 27] For example, one middle school we visited created 
"academies" within the school. Each academy had its own theme, and 
students stay within the academy as they are promoted from grade to 
grade. Another 37 percent of schools that chose the "other" option 
narrowed or expanded the range of grades served within the school, for 
example, changing a kindergarten-through-grade-five elementary school 
to a kindergarten-through-grade-eight school. In one district we 
visited, officials reported that a kindergarten-through-grade-eight 
model creates a more positive learning environment than middle schools 
do as it creates a sense of family and relationships in schools. Figure 
7 shows the various types of restructuring activities taken by schools 
implementing "other" major restructuring.[Footnote 28] 

Figure 7: Among Schools Implementing "Other" Major Restructuring, 
Estimated Percentage of Schools Implementing Various Activities: 

[See PDF for image] 

Source: GAO survey. 

[End of figure] 

In addition to the "other" major restructuring option, in an estimated 
27 percent of restructuring schools, all or most of the staff 
(primarily teachers and principals) who were relevant to the failure to 
make AYP were replaced. The schools we visited that replaced staff 
varied in terms of whether teachers, principals, or both were replaced. 
Our survey indicated that for many of these schools, it was difficult 
or very difficult to recruit new teachers as replacements. 

Very few schools in restructuring had contracted with an entity, such 
as a private management organization, become a charter school, or been 
taken over by the state. Some states may not have authorized all 
restructuring options under state law or policy, which may explain why 
fewer schools have taken these options. For example, according to a 
recent report, while some states have policies that permit districts to 
turn schools over to private management or to reopen schools as charter 
schools, others do not.[Footnote 29] In three of the five states we 
visited, state officials reported that their state educational agencies 
currently do not take over schools.[Footnote 30] In one of these 
states, turning over school management to the state agency is 
permissible under state policy, but officials told us that the state 
does not have the capacity or expertise to do so.[Footnote 31] The 
amount of time it takes to plan for such a change may also be a factor 
in why these options are not often selected. For example, a district 
official reported that the district did not have sufficient time during 
the restructuring planning process to seriously consider reopening as a 
charter school, contracting with a private management company, or 
turning the operation of the school over to the state. In about 70 
percent of schools, the district played a significant role in 
determining the restructuring option taken. 

Although a majority of schools implemented a restructuring option, 
about 40 percent of the schools that were in restructuring did not take 
any of the 5 restructuring options prescribed under NCLBA, according to 
our survey results. Several principals of schools that had not 
restructured did not know why an option was not taken. In other cases, 
principals believed that the school board or district had decided not 
to restructure. In addition, one of the surveyed schools and some 
school and district officials we visited did not believe restructuring 
was necessary when student achievement was improving. For example, 
officials at one of the schools we visited that was planning for 
restructuring indicated that the district and school administration had 
determined that no changes were needed because they were confident that 
the actions already taken were helping students. 

Nonetheless, about half of the schools that did not take one of the 
five restructuring options engaged in a variety of school improvement 
efforts. Some of these efforts may fall under the "other" major 
restructuring option, while others do not appear to be consistent with 
NCLBA requirements for restructuring. For example, one school 
implemented a new curriculum as a restructuring option, while at 
another school extra funding was used for small group instruction and 
after-school programs, both of which more closely resemble corrective 
action under NCLBA. In addition, in two districts we visited, officials 
allowed schools that were improving to continue efforts started under 
prior stages of improvement. However, we could not determine based on 
the information reported by survey respondents whether these activities 
would be considered restructuring under NCLBA. Further, several 
Education officials we spoke with could not determine whether or not 
the actions schools reported taking were in compliance without more 
information from the schools, such as other on-going districts efforts. 

Similar to our finding that many schools may not be implementing a 
restructuring option, Education's 2006 interim report on Title I stated 
that very few schools in restructuring status implemented a 
restructuring option prescribed by NCLBA, though many implemented 
actions NCLBA specifies for the corrective action stage of school 
improvement.[Footnote 32] Despite these findings, department officials 
told us that they did not have any monitoring findings related to 
restructuring requirements, nor did they know whether any states had 
found districts that had not implemented restructuring requirements, 
although they did find deficiencies in some districts' review of school 
improvement plans. 

Education's monitoring tools and reporting requirements do not fully 
address issues of compliance. While Education's state monitoring tool 
includes questions about how states monitor the implementation of 
school improvement plans, Education officials acknowledged that the 
department may be able to strengthen its monitoring tool to determine 
whether state oversight of districts is adequate to ensure compliance. 
Also, since states are not required to report district noncompliance to 
Education and Education does not require states to report on the 
specific corrective actions and restructuring options taken to address 
the achievement problems of each school, federal officials have limited 
information on areas in which there are compliance issues as well as 
the extent to which districts are complying. 

A Higher Percent of Schools That Fully Implemented Improvement 
Activities Made AYP: 

We estimate that over a third of schools that fully implemented a 
corrective action or restructuring option made AYP, as opposed to 16 
percent of schools that had mostly or partially implemented improvement 
activities.[Footnote 33] Several officials noted, and research shows, 
that school improvement efforts take more than a year to affect student 
achievement, so it is possible that these activities will help these 
schools make AYP over the next several years. Many district and school 
officials we interviewed told us that implementing a new curriculum 
takes time and that other improvement efforts can take several years to 
fully implement and to see results. Other factors also can affect 
school improvement efforts. For example, among the schools that made 
AYP, 76 percent of principals believed teacher quality helped or 
greatly helped school improvement activities in their school, opposed 
to only 53 percent among schools that had not made AYP.[Footnote 34] In 
addition to teacher quality, around 80 percent of school officials 
believed that instructional support and resources, such as teacher 
aides and computers, helped or greatly helped their school improvement 
efforts. Schools lacking such support may find implementation of 
corrective action and restructuring more challenging. 

Based on our survey results, none of the specific corrective actions or 
restructuring options was associated with making AYP, nor was making 
AYP associated with the number of activities undertaken, and these 
findings are consistent with recent research on school 
improvement.[Footnote 35] Many school officials believed that other 
factors affected student achievement and therefore, the schools' 
ability to make AYP. About 80 percent of school principals believed 
that community poverty impeded student achievement, while two-thirds 
believed community violence impeded achievement. We found similar views 
during our site visits.[Footnote 36] For example, at two schools we 
visited, officials noted that the presence of gangs in the neighborhood 
affected student achievement, and teachers at one school commented that 
it was unsafe for students to visit the community library after dark. 
Several school and district officials observed that poverty affected 
students' academic efforts. School officials noted that many poor 
students cannot stay late at school because they have family 
obligations, such as taking care of younger children. In addition, 
about two-thirds of school principals believed that student mobility 
(moving from one school to another) impeded student achievement, and 
several officials said that districtwide or statewide curricula had 
been implemented, in part, to address widespread student mobility by 
establishing a consistent instructional approach across schools. 
Moreover, we estimate that nearly half of school officials believed 
that low student attendance impeded student achievement at their 
school. This finding was more prevalent among schools that had not made 
AYP compared to schools that had made AYP. Finally, several activities 
were undertaken by very few schools, such as state takeover or 
extending the school year, so these activities' association with AYP 
could not be accurately assessed in this study. 

Many Schools in Corrective Action and Restructuring Did Not Receive All 
Required Assistance through Their School Districts; However, Most 
Received Assistance from Their State: 

We estimate that more than 40 percent of the schools in corrective 
action and restructuring did not receive all of the required technical 
assistance, such as data analysis and professional development, through 
their school district, but most of the schools received some technical 
assistance from their state. While states generally are not required to 
provide specific kinds of assistance to schools, they are required to 
develop a statewide system of support that is available to schools and 
districts and to provide technical assistance to schools if the 
district fails to do so. Most schools reported receiving technical 
assistance from their state educational agency, such as help from 
instructional experts or highly skilled educators. 

Many Schools in Corrective Action and Restructuring Did Not Receive All 
Required Assistance through Districts: 

We estimate that 42 percent of the schools in corrective action and 
restructuring had not received all of the required assistance in school 
year 2005-2006 while about 56 percent did. Schools most frequently 
received technical assistance related to professional development (92 
percent) and instructional strategies (90 percent). However, only about 
70 percent received assistance with analyzing the school budget to 
ensure that resources were allocated toward improving student 
achievement. We also found, based on our survey results, that 7 out of 
313 schools (about 2 percent) in corrective action and restructuring 
received no assistance. (See fig. 8 for the percentage of schools 
receiving each type of required technical assistance.) 

Figure 8: The Estimated Percentage of Schools in Corrective Action and 
Restructuring That Received Each Form of Required Technical Assistance 
through Districts in School Year 2005-2006: 

[See PDF for image] 

Source: GAO survey. 

[End of figure] 

Education officials noted that through their monitoring site visits 
they found that some districts had not provided all of the assistance 
required. In these instances, Education officials said states could 
withhold Title I funds from the districts that are out of compliance. 
However, Education could not tell us how often states take actions 
against districts for not providing required assistance, because 
according to one Education official, Education did not collect this 
information from states. 

Generally, school officials we met with told us that the district was 
actively involved in providing assistance to their schools. Almost all 
school principals and teachers that we interviewed specifically 
emphasized district efforts to train their administrators and teaching 
staff to analyze and use student testing data to target their 
instruction to areas of academic weakness and to students that needed 
additional assistance. In addition, they said that districts had 
targeted resources to provide professional development and implement 
effective instructional practices. For example, in most districts we 
visited, school officials said that literacy or math coaches had been 
hired to provide staff development or to work with teachers to identify 
instructional practices to improve instruction. Also, in some schools 
we visited, officials told us that districts assisted the schools in 
their efforts to increase parental involvement. For example, in New 
York City, the district helped some schools by approving a parent 
coordinator position to get parents more involved in their schools. 
Officials in some districts also reported reviewing school budgets to 
ensure that resources are allocated to programs that target student 
performance. In regard to budget assistance, district officials in 
Chicago told us that they must approve budgets of all schools in 
restructuring. In addition, principals in two California schools 
reported that the district reviewed their budgets and recommended 
expenditures that targeted school improvement activities. 

Most Schools Received Some Assistance from State Educational Agencies, 
and Almost Half of Schools Received State Funds for School Improvement: 

Most schools received some assistance from their state educational 
agency, and almost half received state funds for school improvement. 
States are required to develop a statewide system of support that is 
available to assist districts. As a part of this system, states must 
create school support teams, which are composed of various 
participants, including highly qualified or distinguished educators, 
such as teachers and principals who can assist the school in 
strengthening its instructional program to improve student achievement. 
We estimate that about 65 percent of schools received assistance from 
their state educational agency in developing the school improvement 
plan, and 60 percent received assistance from a school support team 
(fig. 9). Although state educational agencies generally are not 
required to provide specific kinds of technical assistance to schools 
in corrective action and restructuring, they are required to ensure 
that districts are providing all of the required assistance to schools 
identified for improvement, and if the district has not, state 
educational agencies must step in and provide the assistance. 

An estimated 47 percent of the schools in corrective action and 
restructuring received state funds for school improvement activities in 
addition to federal Title I funds. While state funds were used for many 
different kinds of school improvement activities, more than 75 percent 
of the schools surveyed used the funds for professional development 
activities, classroom support such as instructional and resource 
materials, or both. In addition, officials in four of the five states 
we visited told us that schools received state funds for school 
improvement activities. Maryland provides its schools guidelines on how 
the funds can and cannot be used and the guidelines emphasize that 
whenever possible, the funds should be used to improve instruction, 
such as purchasing textbooks or hiring more school staff. Schools in 
California and New York apply for state funds and must include a plan 
for how the funds will be used. 

Figure 9: Estimated Percentage of Schools in Corrective Action and 
Restructuring in 2005-2006 That Received State Assistance: 

[See PDF for image] 

Source: GAO survey. 

[End of figure] 

Education Provides Technical Assistance and Research on School 
Improvement, Including Some Specific Information on School 
Restructuring: 

Education provides technical assistance and research results to states 
primarily through its Comprehensive Centers Program, consisting of 16 
regional centers and 5 content centers (fig. 10). The department 
replaced its former assistance centers and various education 
consortiums to meet the requirements of the Education Sciences Reform 
Act of 2002.[Footnote 37] The primary task of the content centers is to 
provide knowledge and assistance by experts in school improvement to 
regional centers. The regional centers are to provide technical 
assistance to states on a wide range of topics related to NCLBA, in 
part based on information provided by the content centers. 

Figure 10: Education's Content and Regional Centers: 

[See PDF for image] 

Source: GAO Illustration of Education's Comprehensive Centers Program. 

[End of figure] 

One content center, the Center on Innovation and Improvement, provides 
a variety of services related to school improvement. The center 
developed a guide, Handbook on Restructuring and Substantial School 
Improvement,[Footnote 38] which it has disseminated to regional 
centers, state educational agencies, and other organizations. The 
handbook provides information on using student data to identify a 
restructuring option and focusing instruction on state standards, among 
other topics. Other services include the center's annual 2-day training 
for representatives from the regional centers and additional workshops 
throughout the year on various improvement topics. The center produced 
a series of Web-based seminars during the spring and summer of 2007, 
also based on the handbook, for use by the regional centers. In 
addition, each regional center has developed an annual work plan, 
negotiated with the states for which it is responsible. For example, 
the New York Regional Center provides assistance to the state of New 
York and has negotiated a work plan with several goals related to 
school improvement. One goal is to help the New York State Education 
Department build its school improvement capacity by assisting with 
delivery of research-based professional development related to 
adolescent literacy. 

Education developed the What Works Clearinghouse to review studies of 
educational interventions to determine which studies were conducted 
with a sound methodology and to what extent the interventions are 
effective. The clearinghouse has reviewed studies on topics such as 
preventing dropouts and increasing elementary and middle school 
achievement in mathematics. While these topics are likely to be of 
interest for schools in corrective action and restructuring, the 
clearinghouse has not reviewed studies that specifically deal with 
practices employed by schools in corrective action and restructuring. 
Moreover, several state, district, and school officials we interviewed 
indicated that they needed more information on practices for improving 
schools in corrective action and restructuring. For example, an 
official in one district told us that they had been attempting to 
create their own approaches to improve schools, but said that there was 
insufficient information, from federal or other sources, on improvement 
practices. Recognizing the need for information that may be more suited 
for teachers, principals, and other educators, Education officials 
reported that the department will launch a Web site in September 2007 
related to their initiative, Doing What Works. Through this initiative, 
Education would review studies identified by the clearinghouse and 
develop materials, called "practice guides" for educators. According to 
Education, a practice guide on school restructuring is in development 
and may be available by the end of 2007. 

In addition to the Comprehensive Centers and What Works Clearinghouse 
programs, Education implemented a variety of other initiatives that may 
assist officials in their efforts to improve schools. The department 
revised its guidance in July 2006 to provide more information on school 
restructuring. In addition, Education operates 10 Regional Education 
Laboratories that provide research on a variety of topics. For example, 
the Northwest Regional Education Laboratory is currently examining 
statewide systems of support and the factors that have helped schools 
make AYP. The laboratories are also available to provide assistance to 
any entity, such as school districts or schools, that may request 
information from them. Other resources include the Support for School 
Improvement newsletter, developed by the Council of Chief State School 
Officers and funded in part by Education. The newsletter focuses on 
topics such as school improvement policies and closing achievement gaps 
among student groups. Education also funds a clearinghouse for 
Comprehensive School Reform, which disseminates research on effective 
approaches to school reform through publications such as a recent 
report on what improvement practices might work for schools in 
restructuring.[Footnote 39] 

Conclusions: 

Schools that reach corrective action and restructuring status face many 
challenges in raising the achievement levels of their students. These 
schools typically serve low-income students, and many report that 
factors such as neighborhood violence and student mobility pose 
additional challenges to engaging students and improving their academic 
performance. While most of these schools have implemented activities 
that are required by NCLBA, it is possible that a significant number of 
schools have not. Although Education has made efforts to provide 
guidance to districts on what actions are required and when, the 
department's efforts do not address several specific issues that would 
allow states, districts, and schools to make well informed decisions 
that are in compliance with NCLBA. For example, many schools in 
corrective action continued efforts implemented previously but did not 
implement a new action. While this course of action may be a reasonable 
and appropriate path for some schools to take, Education has not 
provided guidance to districts delineating when continuing a corrective 
action--and not taking an additional one--is appropriate and when it is 
not. Without written guidance, some districts and schools that are not 
demonstrating sustained improvement may continue previous efforts in 
order to avoid having to make more changes. On the other hand, some 
districts may not know they can comply with NCLBA by continuing an 
action that is moving their schools forward and instead may be 
struggling to choose another prescribed activity that is not needed. 

While Education monitors states to ensure compliance with NCBLA--and 
has found deficiencies in some districts' reviews of schools' 
improvement plans--department officials told us that they were unaware 
that some districts may not be implementing the required corrective 
action and restructuring activities because they do not collect that 
specific information. Collecting information on the activities of 
schools in corrective action and restructuring and on compliance issues 
identified by states would better position Education to target its 
guidance and monitoring on areas of greatest need. 

Finally, our review indicates that many schools may not be receiving 
all the types of assistance that they are supposed to receive through 
their districts. However, Education officials told us that they have 
not found any instances in which schools in corrective action and 
restructuring have not received required assistance, and officials 
noted that Education does not track the extent to which states also 
have found such incidences. Schools that are not receiving this 
assistance might not be able to make the kinds of dramatic improvement 
needed for their students, in part because they may not be receiving 
the resources to improve as envisioned by NCLBA. 

Recommendations: 

The Secretary of Education should: 

* Ensure that guidance is provided to states and districts about when 
it may be appropriate to allow schools to continue corrective action 
implemented in earlier years of improvement and not take a new activity 
as the school moves into corrective action status. 

* Obtain more specific information from states on district 
implementation, such as the primary activity that each school in 
corrective action and restructuring is implementing as well as more 
specific information on compliance issues states have identified as 
part of their monitoring activities. This information should be 
analyzed to identify areas where further federal guidance is needed and 
to ensure that areas of noncompliance are being addressed by states. 

* Take additional steps through Education's monitoring process to 
ascertain whether states are ensuring that districts provide the 
assistance required by NCLBA. 

Agency Comments and Our Evaluation: 

Education provided us with written comments on a draft of this report. 
Education agreed with our three recommendations to provide more 
guidance to states and districts, obtain more information on district 
implementation of corrective action and restructuring activities, and 
take additional steps to determine whether districts are providing 
assistance required by NCLBA. Specifically, Education agreed to explore 
options for sharing guidance on when schools may continue a corrective 
action while not taking a new one and commented that it will explore 
sharing guidance that address other issues related to schools in 
corrective action and restructuring that it has asked states to 
identify. While Education noted that it is generally informed on the 
actions taken in schools in corrective action and restructuring, it 
agreed that more information is needed from states on district 
implementation of corrective action and restructuring activities and 
that it will consider options for gathering additional evidence on how 
states ensure that districts are complying with corrective action and 
restructuring requirements. Finally, Education agreed to consider ways 
for revising its monitoring procedures in order to obtain more 
information on how states determine whether districts are providing 
technical assistance to these schools, the types of assistance they 
provide, and the actions states take to address areas of noncompliance. 
See appendix III for Education's comments. Education also provided us 
with a few technical comments that we incorporated. 

We are sending copies of this report to the Secretary of Education and 
other interested parties. We will also make copies available to others 
upon request. In addition, the report will be made available at no 
charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

Please contact me at (202) 512-7215 if you or your staff have any 
questions about this report. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Major contributions to this report are listed in 
appendix IV.

Signed by:  

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

[End of section] 

Appendix I: Scope and Methodology: 

To address the objectives of this study, we used a variety of methods. 
To obtain a national perspective, we conducted descriptive analyses of 
characteristics of schools in corrective action and restructuring and 
compared them to all other Title I schools nationwide. We selected a 
nationally representative sample of these schools and conducted two Web-
based surveys--one of principals whose schools were in corrective 
action and another for schools implementing restructuring--to obtain 
information on implementation of corrective action and restructuring 
and school district and state assistance to such schools. We also 
conducted site visits during which we interviewed state, district, and 
school officials representing 5 states and 10 school districts within 
these states, and we conducted phone interviews with state officials 
from 4 other states. We spoke with officials at Education involved in 
oversight and implementation of corrective action and restructuring in 
schools and reviewed Education's data on schools identified for 
improvement. We also interviewed several experts in the field of school 
improvement. We reviewed federal laws, regulations, and agency 
guidance. We conducted our work from August 2006 through August 2007 in 
accordance with generally accepted government auditing standards. 

Objective 1: Analysis of School Characteristics: 

To address the first objective, we obtained lists of schools in 
corrective action, planning for restructuring, and implementing 
restructuring status and their school districts from Education. States 
submitted these lists to Education through the No Child Left Behind Act 
(NCLBA) Consolidated State Performance Reports (CSPR) for school year 
2004-2005, which contained each school's improvement status for the 
2005-2006 school year, among other data. Because states provided the 
names of schools in corrective action and restructuring in their 2004- 
2005 CSPRs, these schools comprised the national population of such 
schools. In some cases, states used different labels for identifying 
schools in corrective action and restructuring. For example, one state 
identified schools in corrective action by labeling them as "Year 3" 
schools. When states used terms other than corrective action and 
restructuring to indicate schools' improvement status, we contacted 
state officials to clarify the label the state used. Education also 
provided us with numbers of schools in corrective action and 
restructuring for the 2006-2007 school year, which we compared to 
numbers from prior years. On the basis of our review of the data on 
improvement status for school years 2005-2006 and 2006-2007, we 
determined these sources to be sufficient for the purposes of our work. 
We used the lists of schools in corrective action and restructuring for 
the 2005-2006 school year to develop our survey samples and for 
comparisons with other Title I schools not identified as needing 
improvement. 

Also in the CSPR, states provided each school's nationally unique 
identification number, allowing us to link data on these schools with 
data provided in Education's Common Core of Data (CCD). The CCD is a 
database of Education's National Center for Education Statistics, which 
annually collects data from state educational agencies about all public 
schools, public school districts, and state educational agencies in the 
United States. At the time we began our analysis, the latest CCD data 
available were from the 2004-2005 school year. Although we based our 
analysis on schools in corrective action and restructuring in 2005- 
2006, the characteristics were based on one year prior. Upon linking 
schools identified in the CSPR to those in the CCD, we obtained data on 
the following characteristics: 

* locale: whether the school was located was in an urban, suburban, or 
rural area or town; 

* minority status: the percent of students in the school classified as 
American Indian/Alaskan Native, Asian/Pacific Islander, Black/Non- 
Hispanic, or Hispanic; 

* poverty status: the percent of students in the school who qualified 
for free-or reduced-priced meals; and: 

* grade levels served: whether primary, middle, or high school grades. 
To define these levels, we used the definitions provided in the CCD, as 
listed in table 9. 

Table 9: Grade Level Definitions: 

Grade level served: Primary; 
Low grade: Pre-kindergarten to 3; 
High grade: Up to 8. 

Grade level served: Middle; 
Low grade: 4 to 7; 
High grade: 4 to 9. 

Grade level served: High; 
Low grade: 7 to 12; 
High grade: 12. 

Source: Common Core of Data. 

[End of table] 

Schools that did not fit these grade-level configurations were 
classified as "other," meaning any other combination, from the low 
grades of prekindergarten, kindergarten or first grade up to twelfth 
grade, consistent with the CCD definition. 

We compared the percentage of schools in corrective action and 
restructuring with all other Title I schools within each category of 
the characteristics of locale and grade levels served. For minority 
status and poverty status, we compared schools in corrective action and 
restructuring with all other Title I schools by comparing the 
characteristics of the median school within each group.[Footnote 40] 
The median is the school in the middle of a list of schools when they 
are listed from highest to lowest along any given characteristic, such 
that one-half of the schools are listed above and the other half are 
listed below that school. For example, when all corrective action and 
restructuring schools were listed from highest to lowest in terms of 
poverty status, the school in the middle of that list had a poverty 
rate of 96 percent. In contrast, when all other Title I schools were 
listed from highest to lowest, the school in the middle of that list 
had a poverty rate of 37 percent. We chose to use the median school 
instead of calculating the average for all schools or all students, 
because so many schools had high rates of poverty and minority student 
representation, that the median more accurately characterized the 
typical school in our dataset than did the average. 

We performed a series of tests and took additional steps as needed to 
assess the reliability of the data used. For the lists of schools 
obtained in the CSPR and the CCD, we checked to ensure that data were 
consistent, that subtotals added to overall totals and that data 
provided for 1 year bore a reasonable relationship to the next year's 
data and to data reported elsewhere, including state education reports. 
We also spoke with Education officials about their follow-up efforts to 
verify the data. At the time of our review, Education reported that the 
2004-2005 data had been verified. 

On the basis of our review of these data, we determined these sources 
to be sufficiently reliable for the purposes of our work. We also 
considered school improvement-related findings from Education studies, 
including the National Assessment of Title I Interim Report, Vol. 1: 
Implementation (2006). To ensure the findings from these studies were 
sufficiently reliable, we reviewed each study's methodology, including 
data sources and analyses, limitations, and conclusions. We found these 
studies to be sufficiently reliable for the purposes of our work. 

Objectives 2 and 3: Implementation of Corrective Action and 
Restructuring and State and District Assistance: 

To address the second objective on school's implementation of 
corrective action and restructuring and the third objective on district 
and state assistance, we designed and administered two Web-based 
surveys to a nationally representative sample of school principals: one 
for schools in corrective action and one for schools in restructuring, 
as of the 2005-2006 school year. The surveys were conducted between 
January and March 2007. To obtain the maximum number of responses, we 
sent follow-up e-mail notifications with a link to the surveys to those 
who had not completed the survey approximately 1 week after the initial 
launch and additional six follow-up notifications every week 
thereafter. In addition, approximately 3 weeks after the Web surveys 
began, we provided a mail survey to those who had not responded. The 
surveys included questions about corrective actions or restructuring 
options the school had taken. Both surveys included questions about 
factors that may have influenced student achievement and assistance 
provided by the state and district. We also conducted site visits to 5 
states and 10 school districts and 20 schools within these states, 
during which we conducted interviews and obtained documentation on 
school improvement efforts and related topics. Finally, we reviewed 
Education's regulations, guidance, and monitoring tools and interviewed 
department officials about monitoring and guidance related to 
corrective action and restructuring. Specifically, we reviewed the 
NCLBA, associated regulations, Local Education Agency and School 
Improvement Guidance (revised July 2006), monitoring tools and 
indicators used during Education's site visits, and selected monitoring 
reports and findings. 

Corrective Action Survey: 

Sample Design and Errors: 

Based on data obtained from the CSPR, the study population of 1,163 
schools consisted of all public Title I schools that were in corrective 
action in the 2005-2006 school year. We selected a random sample of 
schools in the population and calculated the sample size to achieve a 
precision of plus and minus 8 percent at the 95 percent confidence 
level for an expected proportion of 50 percent.[Footnote 41] To ensure 
the sample sizes were adequate, we set the sample size assuming we 
would obtain a 70 percent response rate. The total sample size was 240 
schools. In the sample, each school in the population had a known, 
nonzero probability of being selected. Each selected school was 
subsequently weighted in the analysis to account statistically for all 
the schools in the population, including those that were not selected. 

Because we surveyed a sample of schools, survey results are estimates 
of a population of schools and thus are subject to sampling errors that 
are associated with samples of this size and type. Since we followed a 
probability procedure based on random selections, our sample is only 
one of a large number of samples that we might have drawn. As each 
sample could have provided different estimates, we express our 
confidence in the precision of our particular sample's results as a 95 
percent confidence interval (for example, plus or minus 8 percentage 
points). This is the interval that would contain the actual population 
value for 95 percent of the samples we could have drawn. As a result, 
we are 95 percent confident that each of the confidence intervals in 
this report will include the true values in the study population. We 
excluded 8 of the sampled schools, because they were not in corrective 
action status in the 2005-2006 school year, were not Title I schools or 
had closed, and therefore were considered out of scope. All estimates 
produced from the sample and presented in this report are 
representative of the in-scope population. All percentage estimates 
included in this report have margins of error of plus or minus 8 
percentage points or less, unless otherwise noted. 

We took steps to minimize nonsampling errors that are not accounted for 
through statistical tests, like sampling errors. In developing the Web 
survey, we conducted several pretests of draft instruments. We 
pretested the survey instrument with school officials in Aurora, 
Illinois; Berkeley, California; and Orange, New Jersey, between October 
and November 2006. We selected schools in these states because they 
contained large numbers of schools in corrective action and thus it was 
likely that schools from these states would be included in our sample. 
In the pretests, we were generally interested in the clarity of the 
questions and the flow and layout of the survey. For example, we wanted 
to ensure definitions used in the surveys were clear and known to the 
respondents, categories provided in closed-ended questions were 
complete and exclusive, and the ordering of survey sections and the 
questions within each section was appropriate. We revised the survey on 
the basis of information we gathered in the pretests. 

A second step we took to minimize nonsampling errors was using a Web- 
based survey. By allowing respondents to enter their responses directly 
into an electronic instrument, this method automatically created a 
record for each respondent in a data file and eliminated the need for 
and the errors (and costs) associated with a manual data entry process. 
To further minimize errors, programs used to analyze the survey data 
and make estimations were independently verified to ensure the accuracy 
of this work. 

While we did not fully validate specific information that school 
officials reported in our survey, we took several steps to ensure that 
the information was sufficiently reliable for the purposes of this 
report. For example, data from mailed surveys were double-keyed to 
ensure data entry accuracy, and the information was analyzed using 
statistical software. We obtained corroborating evidence of schools' 
improvement status when the information provided by the school 
conflicted with the information we had received from the Department of 
Education. In addition, we verified the responses of those schools that 
reported that the school had made AYP. When survey responses did not 
align with the information that we obtained from state Web sites and 
school report cards, we made changes to the survey responses based on 
documentary evidence. After the survey was closed, we also made 
comparisons between select items from our survey data and another 
national-level data set.[Footnote 42] We found our survey data were 
reasonably consistent with the external sources. On the basis of our 
checks, we believe our survey data are sufficiently reliable for the 
purposes of our work. 

Response Rate: 

We received survey responses from 68 percent of the Title I schools in 
corrective action in our sample. After the survey was closed, we 
analyzed the survey respondents to determine if there were any 
differences between the responding schools, the nonresponding schools, 
and the population. We performed this analysis for four 
characteristics--percentage of minority students, percentage of 
students with free lunch, region, and locale. We found no significant 
differences between the estimates for the survey respondents and the 
overall population values for these characteristics. On the basis of 
the 68 percent response rate and this analysis, we chose to include the 
survey results in our report and produce sample-based estimates to the 
population of schools in corrective action in the 2005-2006 school 
year. 

Restructuring Survey: 

Sample Design and Errors: 

The study population of 920 schools consisted of public Title I schools 
that were implementing restructuring in the 2005-2006 school year. This 
population was obtained from the CSPR data provided by Education, as 
described above. We used the same sample design for the restructuring 
Web survey as the design used for the corrective action survey. The 
total sample size was 230 schools. 

We determined that 12 of the sampled schools were out of scope because 
they were not implementing restructuring in the 2005-2006 school year. 
All estimates produced from the sample and presented in this report are 
representative of the in-scope population. All percentage estimates 
included in this report have margins of error of plus or minus 8 
percentage points or less, unless otherwise noted. 

As with the corrective action survey, we took steps to minimize 
nonsampling errors. We pretested the survey instrument with school 
officials in Detroit, Michigan and Syracuse, New York, between October 
and November 2006. We selected schools in these states because the 
states contained large numbers of schools implementing restructuring 
and thus it was likely that schools from these states would be included 
in our sample. The pretests were conducted in the same manner as those 
done for the corrective action survey. On the basis of the pretests, 
the Web instrument underwent some revisions. Again, use of a Web-based 
survey also minimized nonsampling errors as did independently verifying 
programs used to analyze the survey data and make estimations. 

Steps taken to ensure that the information was sufficiently reliable 
for the purposes of this report mirror those taken for the corrective 
action survey, including obtaining corroborating evidence of schools' 
improvement status when the information provided by the school 
conflicted with the information we had received from the Department of 
Education. When a survey response did not align with the information 
that we obtained from state Web sites and school report cards, we made 
changes based on our documentary evidence. We checked a sample of 
schools that claimed to have made AYP to verify these responses and 
found that the responses were accurate. Again, we made comparisons 
between select items from our survey data and other national-level data 
sets,[Footnote 43] and found our survey data were reasonably consistent 
with the external sources. On the basis of our checks, we believe our 
survey data are sufficient for the purposes of our work. 

Response Rate: 

We received survey responses from 74 percent of the Title I schools 
implementing restructuring in our sample. After the survey was closed, 
we analyzed the survey respondents to determine if there were any 
differences between the responding schools, the nonresponding schools, 
and the population, as was done for the corrective action survey. We 
found no significant differences between the estimates for the survey 
respondents and the overall population values for these 
characteristics. On the basis of the 74 percent response rate and this 
analysis, we chose to include the survey results in our report and 
produce sample-based estimates to the population of schools in 
restructuring in the 2005-2006 school year. 

Combined Surveys: 

Many of the questions on the corrective action survey and restructuring 
survey were the same. For example, on both surveys we asked about the 
assistance provided by the state and district, the factors that impeded 
or facilitated student achievement, and the factors that helped or 
hindered implementation of school improvement efforts. For such 
questions, we combined the survey responses for reporting purposes. We 
weighted the respondents so that the estimates are for the in-scope 
combined population of corrective action and implementing restructuring 
schools. Because we surveyed a sample of schools, our results are 
estimates of a population of Title I schools in corrective action and 
implementing restructuring and thus are subject to sampling errors that 
are associated with samples of this size and type. All percentage 
estimates included in this report have margins of error of plus or 
minus 8 percentage points or less, unless otherwise noted. 

Site Visits: 

To understand corrective action and restructuring implementation at the 
local level, we conducted site visits to 5 states and 10 districts and 
20 schools within these states between October 2006 and March 2007. The 
5 states we chose were: California, Illinois, Maryland, New York, and 
Pennsylvania. Together, these 5 states had 59 percent of schools in 
corrective action and restructuring nationwide in the 2005-2006 school 
year and are located in a variety of geographic regions. We interviewed 
state officials on state efforts to oversee and assist schools in 
corrective action and restructuring. 

Within each of the 5 states, we visited 2 school districts, for a total 
of 10 school districts, as shown in table 10. The 10 districts were 
selected because they had experience implementing corrective action and 
restructuring. When viewed as a group, the districts also provided 
variation across characteristics such as geographic location and 
district size. 

Table 10: School Districts Selected for Site Visits: 

School District: Baltimore City Public School System; 
City, State: Baltimore, Md. 

School District: Brentwood Union Free School District; 
City, State: Brentwood, N.Y. 

School District: Chicago Public Schools; 
City, State: Chicago, Ill. 

School District: East Aurora School District #131; 
City, State: Aurora, Ill. 

School District: Los Angeles Unified School District; 
City, State: Los Angeles, Calif. 

School District: New York City Department of Education; 
City, State: New York, N.Y. 

School District: Pomona Unified School District; 
City, State: Pomona, Calif. 

School District: Prince George's County Public Schools; 
City, State: Upper Marlboro, Md. 

School District: School District of Philadelphia; 
City, State: Philadelphia, Pa. 

School District: York City School District; 
City, State: York, Pa. 

Source: GAO. 

[End of table] 

During the site visits, we interviewed state and district officials as 
well as officials representing 20 schools, including principals, 
teachers, and other school staff involved with school improvement 
activities in order to provide in-depth information and illustrative 
examples of our more general findings. The selected schools resembled 
the population of schools in corrective action and restructuring in 
terms of the grade levels served, and the students' racial, ethnic, and 
economic characteristics. While in many cases district officials 
selected the schools we visited, all of the schools had experience 
implementing corrective action or restructuring. Through our interviews 
with state, district, and school officials, we collected information on 
corrective actions and restructuring options implemented, factors 
affecting student achievement, and state and district assistance 
provided to schools in corrective action and restructuring. 

Objective 4: Education's Efforts to Support State Implementation: 

To address the fourth objective on Education's efforts to assist 
states' implementation of corrective action and restructuring 
provisions, we conducted interviews with representatives of the offices 
of Title I, Planning, Evaluation, and Policy Development, What Works 
Clearinghouse, Comprehensive Centers Program, and General Counsel. We 
also interviewed officials with the Center on Innovation and 
Improvement, the California and New York Regional Centers, and the 
Northwest Regional Education Laboratory. 

In addition, we interviewed experts in the field on school improvement, 
including those at the American Institutes for Research, Center on 
Education Policy, Council of the Great City Schools, Council of Chief 
State School Officers, Education Commission of the States, and RAND 
Corporation. We reviewed several studies on school improvement, 
corrective action, and restructuring. 

[End of section] 

Appendix II: Number of Schools in Corrective Action, Planning for 
Restructuring, and Implementing Restructuring, by State in 2005-2006 
and 2006-2007: 

Table 11: Number of Schools in Corrective Action, Planning 
Restructuring, and Implementing Restructuring, by State in 2005-2006 
and 2006-2007: 

State: Alabama; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 13; 
2005-2006: Implementing Restructuring: 27; 
2005-2006: Totals: 40; 
2006-2007: Corrective Action: 3; 
2006-2007: Planning for Restructuring: 5; 
2006-2007: Implementing Restructuring: 18; 
2006-2007: Totals: 26. 

State: Alaska; 
2005-2006: Corrective Action: 34; 
2005-2006: Planning for Restructuring: 5; 
2005-2006: Implementing Restructuring: 8; 
2005-2006: Totals: 47; 
2006-2007: Corrective Action: 35; 
2006-2007: Planning for Restructuring: 30; 
2006-2007: Implementing Restructuring: 12; 
2006-2007: Totals: 77. 

State: Arizona; 
2005-2006: Corrective Action: 25; 
2005-2006: Planning for Restructuring: 20; 
2005-2006: Implementing Restructuring: 4; 
2005-2006: Totals: 49; 
2006-2007: Corrective Action: 36; 
2006-2007: Planning for Restructuring: 12; 
2006-2007: Implementing Restructuring: 14; 
2006-2007: Totals: 62. 

State: Arkansas; 
2005-2006: Corrective Action: 4; 
2005-2006: Planning for Restructuring: 1; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 5; 
2006-2007: Corrective Action: 54; 
2006-2007: Planning for Restructuring: 19; 
2006-2007: Implementing Restructuring: 4; 
2006-2007: Totals: 77. 

State: California; 
2005-2006: Corrective Action: 406; 
2005-2006: Planning for Restructuring: 153; 
2005-2006: Implementing Restructuring: 247; 
2005-2006: Totals: 806; 
2006-2007: Corrective Action: 482; 
2006-2007: Planning for Restructuring: 343; 
2006-2007: Implementing Restructuring: 357; 
2006-2007: Totals: 1,182. 

State: Colorado; 
2005-2006: Corrective Action: 22; 
2005-2006: Planning for Restructuring: 13; 
2005-2006: Implementing Restructuring: 3; 
2005- 2006: Totals: 38; 
2006-2007: Corrective Action: 21; 
2006-2007: Planning for Restructuring: 16; 
2006-2007: Implementing Restructuring: 14; 
2006- 2007: Totals: 51. 

State: Connecticut; 
2005-2006: Corrective Action: 4; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 6; 
2005-2006: Totals: 10; 
2006-2007: Corrective Action: 63; 
2006-2007: Planning for Restructuring: 1; 
2006-2007: Implementing Restructuring: 6; 
2006-2007: Totals: 70. 

State: Delaware; 
2005-2006: Corrective Action: 2; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 2; 
2006-2007: Corrective Action: 3; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 1; 
2006- 2007: Totals: 4. 

State: District of Columbia; 
2005-2006: Corrective Action: 45; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 45; 
2006-2007: Corrective Action: 33; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 33. 

State: Florida; 
2005-2006: Corrective Action: 32; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 32; 
2006-2007: Corrective Action: 544; 
2006-2007: Planning for Restructuring: 30; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 574. 

State: Georgia[A]; 
2005-2006: Corrective Action: 19; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 66; 
2005-2006: Totals: 85; 
2006-2007: Corrective Action: 23; 
2006-2007: Planning for Restructuring: 19; 
2006-2007: Implementing Restructuring: 48; 
2006-2007: Totals: 90. 

State: Hawaii; 
2005-2006: Corrective Action: 2; 
2005-2006: Planning for Restructuring: 13; 
2005-2006: Implementing Restructuring: 41; 
2005-2006: Totals: 56; 
2006-2007: Corrective Action: 38; 
2006-2007: Planning for Restructuring: 3; 
2006-2007: Implementing Restructuring: 50; 
2006-2007: Totals: 91. 

State: Idaho; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 0; 
2006-2007: Corrective Action: 12; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 12. 

State: Illinois; 
2005-2006: Corrective Action: 151; 
2005-2006: Planning for Restructuring: 211; 
2005-2006: Implementing Restructuring: 20; 
2005-2006: Totals: 382; 
2006-2007: Corrective Action: 93; 
2006-2007: Planning for Restructuring: 177; 
2006-2007: Implementing Restructuring: 138; 
2006-2007: Totals: 408. 

State: Indiana; 
2005-2006: Corrective Action: 10; 
2005-2006: Planning for Restructuring: 9; 
2005-2006: Implementing Restructuring: 6; 
2005-2006: Totals: 25; 
2006-2007: Corrective Action: 18; 
2006-2007: Planning for Restructuring: 6; 
2006-2007: Implementing Restructuring: 9; 
2006-2007: Totals: 33. 

State: Iowa; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 0; 
2006-2007: Corrective Action: 4; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 4. 

State: Kansas; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 2; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 2; 
2006-2007: Corrective Action: 3; 
2006-2007: Planning for Restructuring: 2; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 5. 

State: Kentucky; 
2005-2006: Corrective Action: 3; 
2005-2006: Planning for Restructuring: 6; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 9; 
2006-2007: Corrective Action: 56; 
2006-2007: Planning for Restructuring: 1; 
2006-2007: Implementing Restructuring: 5; 
2006-2007: Totals: 62. 

State: Louisiana; 
2005-2006: Corrective Action: 23; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 6; 
2005-2006: Totals: 29; 
2006-2007: Corrective Action: 3; 
2006-2007: Planning for Restructuring: 4; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 7. 

State: Maine; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 0; 
2006-2007: Corrective Action: 4; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 4. 

State: Maryland; 
2005-2006: Corrective Action: 6; 
2005-2006: Planning for Restructuring: 6; 
2005-2006: Implementing Restructuring: 41; 
2005-2006: Totals: 53; 
2006-2007: Corrective Action: 15; 
2006-2007: Planning for Restructuring: 2; 
2006-2007: Implementing Restructuring: 46; 
2006- 2007: Totals: 63. 

State: Massachusetts; 
2005-2006: Corrective Action: 32; 
2005-2006: Planning for Restructuring: 10; 
2005-2006: Implementing Restructuring: 19; 
2005-2006: Totals: 61; 
2006-2007: Corrective Action: 129; 
2006-2007: Planning for Restructuring: 24; 
2006-2007: Implementing Restructuring: 26; 
2006-2007: Totals: 179. 

State: Michigan; 
2005-2006: Corrective Action: 22; 
2005-2006: Planning for Restructuring: 40; 
2005-2006: Implementing Restructuring: 58; 
2005-2006: Totals: 120; 
2006-2007: Corrective Action: 46; 
2006-2007: Planning for Restructuring: 16; 
2006-2007: Implementing Restructuring: 37; 
2006-2007: Totals: 99. 

State: Minnesota; 
2005-2006: Corrective Action: 7; 
2005-2006: Planning for Restructuring: 1; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 8; 
2006-2007: Corrective Action: 10; 
2006-2007: Planning for Restructuring: 3; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 13. 

State: Mississippi; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 1; 
2005-2006: Implementing Restructuring: 1; 
2005-2006: Totals: 2; 
2006-2007: Corrective Action: 12; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 1; 
2006-2007: Totals: 13. 

State: Missouri[B]; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 7; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 7; 
2006-2007: Corrective Action: [Empty]; 
2006-2007: Planning for Restructuring: [Empty]; 
2006-2007: Implementing Restructuring: [Empty]; 
2006-2007: Totals: [Empty]. 

State: Montana; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 30; 
2005-2006: Totals: 30; 
2006-2007: Corrective Action: 4; 
2006-2007: Planning for Restructuring: 1; 
2006-2007: Implementing Restructuring: 31; 
2006-2007: Totals: 36. 

State: Nebraska; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 2; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 2; 
2006-2007: Corrective Action: 0; 
2006-2007: Planning for Restructuring: 1; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 1. 

State: Nevada; 
2005-2006: Corrective Action: 16; 
2005-2006: Planning for Restructuring: 2; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 18; 
2006-2007: Corrective Action: 18; 
2006-2007: Planning for Restructuring: 9; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 27. 

State: New Hampshire; 
2005-2006: Corrective Action: 1; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 1; 
2006-2007: Corrective Action: 2; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 2. 

State: New Jersey; 
2005-2006: Corrective Action: 34; 
2005-2006: Planning for Restructuring: 61; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 95; 
2006-2007: Corrective Action: 100; 
2006-2007: Planning for Restructuring: 16; 
2006-2007: Implementing Restructuring: 49; 
2006-2007: Totals: 165. 

State: New Mexico; 
2005-2006: Corrective Action: 16; 
2005-2006: Planning for Restructuring: 28; 
2005-2006: Implementing Restructuring: 24; 
2005-2006: Totals: 68; 
2006-2007: Corrective Action: 29; 
2006-2007: Planning for Restructuring: 17; 
2006-2007: Implementing Restructuring: 48; 
2006-2007: Totals: 94. 

State: New York; 
2005-2006: Corrective Action: 95; 
2005-2006: Planning for Restructuring: 43; 
2005-2006: Implementing Restructuring: 147; 
2005-2006: Totals: 285; 
2006-2007: Corrective Action: 67; 
2006-2007: Planning for Restructuring: 77; 
2006-2007: Implementing Restructuring: 166; 
2006-2007: Totals: 310. 

State: North Carolina; 
2005-2006: Corrective Action: 12; 
2005-2006: Planning for Restructuring: 5; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 17; 
2006-2007: Corrective Action: 59; 
2006-2007: Planning for Restructuring: 10; 
2006-2007: Implementing Restructuring: 2; 
2006-2007: Totals: 71. 

State: North Dakota; 
2005-2006: Corrective Action: 3; 
2005-2006: Planning for Restructuring: 2; 
2005-2006: Implementing Restructuring: 3; 
2005-2006: Totals: 8; 
2006-2007: Corrective Action: 3; 
2006-2007: Planning for Restructuring: 2; 
2006-2007: Implementing Restructuring: 14; 
2006-2007: Totals: 19. 

State: Ohio; 
2005-2006: Corrective Action: 25; 
2005-2006: Planning for Restructuring: 24; 
2005-2006: Implementing Restructuring: 29; 
2005-2006: Totals: 78; 
2006-2007: Corrective Action: 76; 
2006-2007: Planning for Restructuring: 19; 
2006-2007: Implementing Restructuring: 33; 
2006-2007: Totals: 128. 

State: Oklahoma; 
2005-2006: Corrective Action: 3; 
2005-2006: Planning for Restructuring: 3; 
2005-2006: Implementing Restructuring: 4; 
2005-2006: Totals: 10; 
2006-2007: Corrective Action: 10; 
2006-2007: Planning for Restructuring: 3; 
2006-2007: Implementing Restructuring: 2; 
2006-2007: Totals: 15. 

State: Oregon; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 1; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 1; 
2006-2007: Corrective Action: 9; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 1; 
2006-2007: Totals: 10. 

State: Pennsylvania; 
2005-2006: Corrective Action: 30; 
2005-2006: Planning for Restructuring: 5; 
2005-2006: Implementing Restructuring: 83; 
2005-2006: Totals: 118; 
2006-2007: Corrective Action: 29; 
2006-2007: Planning for Restructuring: 15; 
2006-2007: Implementing Restructuring: 63; 
2006-2007: Totals: 107. 

State: Rhode Island; 
2005-2006: Corrective Action: 6; 
2005-2006: Planning for Restructuring: 2; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 8; 
2006-2007: Corrective Action: 9; 
2006-2007: Planning for Restructuring: 2; 
2006-2007: Implementing Restructuring: 2; 
2006-2007: Totals: 13. 

State: South Carolina; 
2005-2006: Corrective Action: 26; 
2005-2006: Planning for Restructuring: 6; 
2005-2006: Implementing Restructuring: 7; 
2005-2006: Totals: 39; 
2006-2007: Corrective Action: 69; 
2006-2007: Planning for Restructuring: 27; 
2006-2007: Implementing Restructuring: 10; 
2006-2007: Totals: 106. 

State: South Dakota; 
2005-2006: Corrective Action: 13; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 2; 
2005-2006: Totals: 15; 
2006-2007: Corrective Action: 7; 
2006-2007: Planning for Restructuring: 12; 
2006-2007: Implementing Restructuring: 2; 
2006-2007: Totals: 21. 

State: Tennessee; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 13; 
2005-2006: Implementing Restructuring: 24; 
2005-2006: Totals: 37; 
2006-2007: Corrective Action: 10; 
2006-2007: Planning for Restructuring: 1; 
2006-2007: Implementing Restructuring: 19; 
2006-2007: Totals: 30. 

State: Texas; 
2005-2006: Corrective Action: 3; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 3; 
2006-2007: Corrective Action: 33; 
2006-2007: Planning for Restructuring: 2; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 35. 

State: Utah; 
2005-2006: Corrective Action: 1; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 1; 
2005-2006: Totals: 2; 
2006-2007: Corrective Action: 0; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 1; 
2006-2007: Totals: 1. 

State: Vermont; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 0; 
2006-2007: Corrective Action: 2; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006-2007: Totals: 2. 

State: Virginia; 
2005-2006: Corrective Action: 9; 
2005-2006: Planning for Restructuring: 3; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 12; 
2006-2007: Corrective Action: 12; 
2006-2007: Planning for Restructuring: 2; 
2006-2007: Implementing Restructuring: 2; 
2006-2007: Totals: 16. 

State: Washington; 
2005-2006: Corrective Action: 6; 
2005-2006: Planning for Restructuring: 9; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 15; 
2006-2007: Corrective Action: 26; 
2006-2007: Planning for Restructuring: 4; 
2006-2007: Implementing Restructuring: 8; 
2006-2007: Totals: 38. 

State: West Virginia; 
2005-2006: Corrective Action: 1; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 1; 
2005-2006: Totals: 2; 
2006-2007: Corrective Action: 6; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 1; 
2006-2007: Totals: 7. 

State: Wisconsin; 
2005-2006: Corrective Action: 6; 
2005-2006: Planning for Restructuring: 7; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 13; 
2006-2007: Corrective Action: 7; 
2006-2007: Planning for Restructuring: 4; 
2006-2007: Implementing Restructuring: 2; 
2006-2007: Totals: 13. 

State: Wyoming; 
2005-2006: Corrective Action: 0; 
2005-2006: Planning for Restructuring: 0; 
2005-2006: Implementing Restructuring: 0; 
2005-2006: Totals: 0; 
2006-2007: Corrective Action: 3; 
2006-2007: Planning for Restructuring: 0; 
2006-2007: Implementing Restructuring: 0; 
2006- 2007: Totals: 3. 

State: Totals; 
2005-2006: Corrective Action: 1,155; 
2005-2006: Planning for Restructuring: 727; 
2005-2006: Implementing Restructuring: 908; 
2005-2006: Totals: 2,790; 
2006-2007: Corrective Action: 2,330; 
2006-2007: Planning for Restructuring: 937; 
2006-2007: Implementing Restructuring: 1,242; 
2006-2007: Totals: 4,509. 

Source: GAO analysis of Education data. 

[A] For the 2005-2006 school year, Georgia required schools in 
corrective action to plan for restructuring. We reported these schools 
as in status as corrective action. 

[B] For the 2006-2007 school year, Missouri had yet to report which of 
its schools were identified for improvement, corrective action, or 
restructuring. 

[End of table] 

[End of section] 

Appendix III Comments from the Department of Education: 

United States Department Of Education: 
Office Of Elementary And Secondary Education: 

July 25, 2007: 

The Assistant Secretary: 

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

Dear Ms. Ashby: 

I am writing in response to your request for comments on the Government 
Accountability Office's (GAO's) draft report (GAO 07-1035) dated 
September 2007, entitled "No Child Left Behind Act: Education Should 
Clarify Guidance and Address Potential Compliance Issues for Schools in 
Corrective Action and Restructuring Status." I appreciate the 
opportunity to comment on the draft report. 

The following are responses to the recommendations in the report to 
take actions to support implementation of corrective action and 
restructuring in Title I schools required to take these actions: 

Recommendation 1. Ensure that guidance is provided to states and 
districts about when it may be appropriate to allow schools to continue 
corrective action implemented in earlier years of improvement and not 
take a new activity as the school moves into corrective action status. 

The Department agrees with this recommendation and will explore options 
for sharing not only the guidance recommended above but also guidance 
addressing other issues related to schools in corrective action and 
restructuring. Department staff discussed this issue at a meeting with 
State Title I directors in July 2007 and will also ask the State 
directors to identify other areas where guidance is needed. 

Recommendation 2. Obtain more specific information from states on 
district implementation, such as the primary activity that each school 
in corrective action and restructuring is implementing as well as more 
specific information on compliance issues states have identified as 
part of their monitoring activities. This information should be 
analyzed to identify areas where further federal guidance is needed and 
to ensure that areas of noncompliance are being addressed by states. 

The Department does have general information on the actions taken in 
schools in corrective action and restructuring, gathered as part of the 
National Assessment of Title I, and Federal monitors do interview staff 
of schools in corrective action and restructuring as part of the 
Department's on-site monitoring. However, we agree that there is a need 
for more information from States on district implementation of 
corrective action and restructuring. The Department will explore 
options for how this might be accomplished. 

With regard to compliance, the Department's existing monitoring 
protocol requires States to provide evidence of how they monitor their 
school districts to ensure compliance with Title I, Part A 
requirements. Federal monitors examine State monitoring reports for the 
school districts visited on site. The Department will review its 
monitoring process and consider possible options for gathering 
additional evidence of how States are ensuring that school districts 
comply with corrective action and restructuring requirements and on the 
procedures States use for addressing areas of noncompliance. 

Recommendation 3. Take additional steps through Education's monitoring 
process to ascertain whether states are ensuring that districts provide 
the assistance required by NCLBA. 

The Department agrees with this recommendation. Our current monitoring 
process requires each school district receiving an on-site visit to 
provide evidence that it has provided, or provided for, technical 
assistance grounded in scientifically based research to schools in 
improvement, corrective action, or restructuring. As with 
recommendation 2, we will consider options for revising our monitoring 
procedures to gather additional information on: (1) how States 
determine whether districts are providing technical assistance to 
schools in corrective action and restructuring and what types of 
assistance they provide, and (2) the follow-up actions States take to 
address areas of noncompliance. 

We appreciate the opportunity to share our comments and plans. Enclosed 
please find some recommended technical edits to the report for your 
consideration. 

Please let me know if you need additional information regarding 
activities underway at the Department to help States implement 
corrective action and restructuring in schools. 

Sincerely,

Signed by: 
Kerri L. Briggs: 

[End of section] 

Appendix IV: GAO Contacts and Acknowledgments: 

GAO Contact: 

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

Acknowledgments: 

Bryon Gordon, Assistant Director, and Elizabeth Morrison managed the 
assignment. Cara Jackson, Jason Palmer, and Nancy Purvine made 
significant contributions to this report in all aspects of the work. 
Susannah Compton, Nancy Hess, Jean McSween, and Jerome Sandeau provided 
analytical assistance. Sheila McCoy provided legal support, and Karen 
Burke developed the report's graphics. 

[End of section] 

Related GAO Products: 

Teacher Quality: Approach, Implementation, and Evaluation of Key 
Federal Efforts. GAO-07-861T. Washington, D.C.: May 17, 2007. 

No Child Left Behind Act: Education Actions May Help Improve 
Implementation and Evaluation of Supplemental Educational Services. GAO-
07-738T. Washington, D.C.: April 18, 2007. 

No Child Left Behind Act: Education Assistance Could Help States Better 
Measure Progress of Students with Limited English Proficiency. GAO-07- 
646T. Washington, D.C.: March 23, 2007. 

Reading First: States Report Improvements in Reading Instruction, but 
Additional Procedures Would Clarify Education's Role in Ensuring Proper 
Implementation by States. GAO-07-161. Washington, D.C.: February 28, 
2007. 

No Child Left Behind Act: Education Actions Needed to Improve 
Implementation and Evaluation of Supplemental Educational Services. GAO-
06-1121T. Washington, D.C.: September 21, 2006. 

No Child Left Behind Act: Education Actions Needed to Improve Local 
Implementation and State Evaluation of Supplemental Educational 
Services. GAO-06-758. Washington, D.C.: August 4, 2006. 

No Child Left Behind Act: States Face Challenges Measuring Academic 
Growth. GAO-06-948T. Washington, D.C.: July 27, 2006. 

No Child Left Behind Act: Assistance from Education Could Help States 
Better Measure Progress of Students with Limited English Proficiency. 
GAO-06-815. Washington, D.C.: July 26, 2006. 

No Child Left Behind Act: States Face Challenges Measuring Academic 
Growth That Education's Initiatives May Help Address. GAO-06-661. 
Washington, D.C.: July 17, 2006. 

No Child Left Behind Act: Improved Accessibility to Education's 
Information Could Help States Further Implement Teacher Qualification 
Requirements. GAO-06-25. Washington, D.C.: Nov. 21, 2005. 

No Child Left Behind Act: Education Could Do More to Help States Better 
Define Graduation Rates and Improve Knowledge about Intervention 
Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005. 

No Child Left Behind Act: Most Students with Disabilities Participated 
in Statewide Assessments, but Inclusion Options Could Be Improved. GAO- 
05-618. Washington, D.C.: July 20, 2005. 

Charter Schools: To Enhance Education's Monitoring and Research, More 
Charter School-Level Data Are Needed. GAO-05-5. Washington, D.C.: Jan. 
12, 2005. 

No Child Left Behind Act: Education Needs to Provide Additional 
Technical Assistance and Conduct Implementation Studies for School 
Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004. 

No Child Left Behind Act: Improvements Needed in Education's Process 
for Tracking States' Implementation of Key Provisions. GAO-04-734. 
Washington, D.C.: Sept. 30, 2004. 

No Child Left Behind Act: Additional Assistance and Research on 
Effective Strategies Would Help Small Rural Districts. GAO-04-909. 
Washington, D.C.: Sept. 23, 2004. 

Special Education: Additional Assistance and Better Coordination Needed 
among Education Offices to Help States Meet the NCLBA Teacher 
Requirements. GAO-04-659. Washington, D.C.: July 15, 2004. 

Student Mentoring Programs: Education's Monitoring and Information 
Sharing Could Be Improved. GAO-04-581. Washington, D.C.: June 25, 2004. 

No Child Left Behind Act: More Information Would Help States Determine 
Which Teachers Are Highly Qualified. GAO-03-631. Washington, D.C.: July 
17, 2003. 

Title I: Characteristics of Tests Will Influence Expenses; 
Information Sharing May Help States Realize Efficiencies. GAO-03-389. 
Washington, D.C.: May 8, 2003. 

Footnotes: 

[1] Pub. L. No. 107-110. 

[2] In this report, we refer to Title I, Part A of NCLBA as "Title I." 
Other Parts of Title I (Parts B through I) generally are targeted at 
specific populations or purposes and are commonly referred to by their 
program names, such as Education of Migratory Children. 

[3] Of the 4,509 schools that had not made AYP for 4 or more 
consecutive years, 2,330 were in corrective action; 937 were planning 
for restructuring; and 1,242 were in restructuring status. 

[4] Pub. L. No. 103-382. 

[5] This requirement applies to all states and students in public 
schools regardless of whether the school receives Title I funding or 
not. 

[6] Students in grades 3 to 8 must be annually assessed in reading and 
mathematics, while high school students are only required to be 
assessed once in these subjects. Assessments in science, which were 
first required under NCLBA in school year 2007-2008, are required at 
least once in grades 3 to 8, grades 6 to 9, and grades 10 to 12. 20 
U.S.C. § 6311(b)(3)(C)(v) - (vii). 

[7] The timelines and other requirements for these improvement 
strategies are outlined in 20 U.S.C. § 6316(b). 

[8] 20 U.S.C. § 6316(b)(7). 

[9] 20 U.S.C. § 6316(b)(8). 

[10] Districts are required to ensure that their schools receive this 
technical assistance, but they do not have to provide it directly 
themselves. Instead, they may elect to provide it through other 
entities such as an institution of higher education, private 
organizations, educational service agencies, or other entities with 
experience in helping schools improve academic achievement. 20 U.S.C. § 
6316(b)(4)(B)(iv). 

[11] 20 U.S.C. § 6316(b)(4) and 34 C.F.R. § 200.40. 

[12] See LEA and School Improvement: Non-Regulatory Guidance 
(Department of Education, Washington, D.C.: July 21, 2006). 

[13] State may apply and report annually on multiple ESEA programs 
through a single consolidated application and report. These annual 
reports include information on numerous ESEA programs. 

[14] The number of schools in corrective action, planning for 
restructuring or implementing restructuring are from the 2005-2006 
school year. Their characteristics and comparisons to all other Title I 
schools are based on data from the 2004-2005 school year, the latest 
data available at the time we began our analyses. The Common Core of 
Data (CCD) refers to schools as Title I eligible. For the purposes of 
our analysis, we refer to these school as Title I schools. 

[15] We also analyzed these data taking into account the number of 
schools as a percentage of all Title I schools by state. In general, 
states with a higher percentage of Title I schools in improvement when 
NCLBA was passed also had a higher percentage in schools in corrective 
action and restructuring in 2005-2006. 

[16] 20 U.S.C. § 6316(f). 

[17] For this analysis, we compared the percentage of students who are 
members of racial or ethnic minority groups or who qualified for free- 
or reduced priced meals in the median schools when all schools were 
ranked by the percent of those characteristics in the schools. 

[18] Our finding on middle schools is similar to findings in other 
reports. See U.S. Department of Education, National Assessment of Title 
I Interim Report, Vol 1: Implementation, Institute of Education 
Sciences (Washington, D.C.: February 2006); and Center on Education 
Policy, NCLB: Middle Schools are Increasingly Targeted for Improvement 
(Washington, D.C: 2006). We found no notable difference between the 
percentage of middle schools in corrective action and restructuring and 
the percentage of all other Title I schools based on whether they were 
located in an urban, suburban, or rural area. 

[19] Results for reading are mixed, with proficiency rates higher for 
some district's or groups of middle school students than elementary 
school students, but lower for others. See U.S. Department of 
Education, The Nation's Report Card: Reading 2005. NCES 2006-451 
(Washington, D.C.: October, 2005). See The Nation's Report Card: 
Mathematics 2005. NCES 2006-453 (Washington, D.C.: October, 2005); The 
Nation's Report Card: Trial Urban District Assessment Mathematics, 
2005, NCES 2006-457r (Washington, D.C.: February 2006); The Nation's 
Report Card: Trial Urban District Assessment Reading, 2005. NCES 2006- 
455r (Washington, D.C.: February 2006). 

[20] RAND, Focus on the Wonder Years: Challenges Facing the American 
Middle School (Santa Monica, Calif.: 2004). 

[21] Center on Education Policy, NCLB: Middle Schools Are Increasingly 
Targeted for Improvement, NCLB Policy Brief 2 (Washington, D.C.: 2005). 

[22] The number of schools in corrective action and restructuring for 
one state did not change between school years 2005-2006 and 2006-2007, 
and another state had yet to finalize its data for 2006-2007. 

[23] See Center on Education Policy, What Now? Lessons from Michigan 
about Restructuring Schools and Next Steps Under NCLB (Washington, 
D.C.: 2007). 

[24] All survey findings are based on what school officials reported 
through GAO's Web-based or paper survey. We did not verify whether 
schools had implemented the activities they reported taking. 

[25] The information provided in this section pertains only to those 
schools that were in the implementation stage of restructuring in 2005- 
2006 school year. This section does not pertain to schools that were 
planning for restructuring. 

[26] Another study found similar results for schools implementing 
restructuring in the state of California. See Center on Education 
Policy, Beyond the Mountains: An Early Look at Restructuring in 
California (Washington, D.C.: 2007). 

[27] Margins of error for estimates pertaining to schools that 
implemented "other" major restructuring do not exceed 15 percent. 

[28] These categories reflect the examples of "other" major 
restructuring provided in Education's 2006 guidance. 

[29] Education Week (Editorial Projects in Education), "Quality Counts: 
2007. From Cradle to Career: Connecting American Education from Birth 
to Adulthood," (Bethesda, Md.: January 2007). 

[30] According to the same report, many states currently authorize 
turning over school management to the state educational agency through 
state policy. (Education Week (Editorial Projects in Education), 
(January 2007). 

[31] Another state educational agency we visited attempted to take over 
schools, but state officials told us that the state legislature 
prevented it from doing so. 

[32] Department of Education, National Assessment of Title I Interim 
Report, Vol. 1: Implementation, Institute of Education Sciences 
(Washington, D.C.: February 2006). Education explained its findings in 
part by noting that the survey did not specify whether schools were 
planning restructuring or implementing restructuring. 

[33] Our findings throughout this section are based on analyses that 
did not allow us to determine whether the type of school improvement 
activity, level of implementation, or number of activities taken caused 
schools to make AYP. However, we did test for whether these factors 
were related to making AYP, and found no statistically significant 
relationships. The RAND Corporation has conducted a study that 
emphasizes the importance of implementation of school reform efforts. 
See RAND, Evaluating Comprehensive School Reform Models at Scale: Focus 
on Implementation (2006), Arlington, VA. 

[34] Among schools that made AYP, the 95 percent confidence interval 
for this estimate ranges from 65 percent to 87 percent of principals 
who believed teacher quality helped or greatly helped school 
improvement activities in their school. 

[35] Mintrop, H. and Trujillo, T., "Corrective Action in Low-Performing 
Schools: Lessons for NCLB Implementation from First-Generation 
Accountability Systems," Education Policy Analysis Archives, Vol. 13, 
Issue 48 (December 2005) and Ronald C. Brady, Can Failing Schools be 
Fixed? (Thomas B. Fordham Foundation, Washington, D.C.: January 2003). 

[36] Our prior work has also documented some administrative challenges 
associated with student mobility. See GAO-05-879, No Child Left Behind 
Act: Education Could Do More to Help States Better Define Graduation 
Rates and Improve Knowledge about Intervention Strategies (Washington, 
D.C.: Sept. 20, 2005). 

[37] The comprehensive centers under this program replaced the former 
Comprehensive Regional Assistance Centers, the Regional Technology in 
Education Consortia, the Eisenhower National Clearinghouse for 
Mathematics and Science Education, and the Regional Mathematics and 
Science Education Consortia. 

[38] See Herbert J. Walburg, editor. "Handbook on Restructuring and 
Substantial School Improvement" (Center on Innovation and Improvement, 
Lincoln, Ill.: 2007). 

[39] Learning Point Associates, School Restructuring Under No Child 
Left Behind: What Works When? A Guide for Education Leaders. 
(Naperville, Ill.: 2007). 

[40] We also used locale (urban, suburban, town/rural) to enhance our 
analyses of minority status and poverty status in order to account for 
the clustering of minority students and students who are poor in urban 
areas. 

[41] Since the margin of error for a proportion estimate with a given 
sample size is greatest at 50 percent, we were conservative when 
planning the sample size. 

[42] We compared our district survey data to data on schools in 
corrective action reported by Education in the National Assessment of 
Title I Interim Report , Vol. 1: Implementation, Institute of Education 
Sciences (Washington, D.C.: February 2006). 

[43] We compared our district survey data to data on schools in 
restructuring reported by Education in the National Assessment of Title 
I Interim Report, Vol. 1: Implementation, Institute of Education 
Sciences (Washington, D.C.: February 2006). We also compared our survey 
data to data on schools in restructuring reported by the Center on 
Education Policy in Wrestling the Devil in the Details: An Early Look 
at Restructuring in California (Washington, D.C.: February 2006). 

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