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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

April 2012: 

School Improvement Grants: 

Education Should Take Additional Steps to Enhance Accountability for 
Schools and Contractors: 

GAO-12-373: 

GAO Highlights: 

Highlights of GAO-12-373, a report to congressional requesters. 

Why GAO Did This Study: 

The School Improvement Grant (SIG) program funds reforms in low 
performing schools. Congress provided $3.5 billion for SIG in fiscal 
year 2009, and a total of about $1.6 billion was appropriated in 
fiscal years 2010-2012. SIG requirements changed significantly in 
2010. Many schools receiving SIG funds must now use the funding for 
specific interventions, such as turning over certain school operations 
to an outside organization (contractor). GAO examined (1) what, if 
any, aspects of SIG pose challenges for successful implementation; (2) 
how Education and state guidance and procedures for screening 
potential contractors and reviewing contractor performance compare 
with leading practices; and (3) to what extent Education’s technical 
assistance and oversight activities are effectively supporting SIG 
implementation. GAO surveyed SIG directors in all 50 states and the 
District of Columbia; analyzed Education and state documents; and 
interviewed officials from 8 states and school districts in those 
states, SIG contractors, and education experts. 

What GAO Found: 

Successful SIG implementation posed a number of challenges. 
Specifically, state and district officials were challenged to build 
staff capacity and commitment for reform, facing difficulties such as 
recruiting and retaining strong staff members. In addition, the SIG 
requirements to develop teacher evaluations and increase student 
learning time were difficult to implement quickly and effectively 
because they required extensive planning and coordination. 
Furthermore, states sometimes had limited evidence about the 
performance of SIG schools when making grant renewal decisions. For 
example, although Education’s guidance identifies meeting annual 
student achievement goals as a key criterion for making renewal 
decisions, some states did not receive student achievement data by the 
time decisions had to be made. States also made decisions through 
qualitative assessments of schools’ implementation efforts, but such 
determinations were not always based on extensive interaction with 
schools or systematic monitoring. Education did not provide written 
guidance to states about making evidence-based grant renewal decisions 
after they encountered these challenges. 

Districts used a significant portion of their SIG funds to hire 
contractors for a range of services, such as managing school 
operations and conducting teacher professional development. Leading 
practices show that screening potential contractors and then reviewing 
their performance are important for ensuring accountability and 
quality of results. Education required screening of contractors before 
contract awards were made. However, Education did not require review 
of contractors during contract performance, and states varied in 
whether they ensured that contractors were reviewed during the course 
of contract performance. 

Education’s assistance and oversight activities are generally 
supporting SIG implementation. In our survey, nearly all states 
reported they were satisfied with Education’s technical assistance, 
particularly the agency’s SIG guidance and conferences. In addition, 
many states reported that Education’s guidance was timely. With 
respect to oversight, Education monitored 12 states in school year 
(SY) 2010-2011 and found deficiencies in 11 of the 12 states. 
Education is working with states to correct these deficiencies. For SY 
2011-2012, the agency plans to use a risk-based approach to conduct on-
site monitoring in 14 additional states. To maximize its oversight 
resources, Education also plans to conduct some limited monitoring in 
five additional states in SY 2011-2012. Education officials told us 
that they plan to monitor the remaining states in SY 2012-2013 and 
that these states represent a small percentage of SIG funds. 

What GAO Recommends: 

GAO recommends that Education (1) provide additional support to states 
about making evidence-based grant renewal decisions and (2) ensure 
that contractor performance is reviewed. Education generally supported 
our first recommendation but disagreed with the second. We modified 
our recommendation to address some of Education’s concerns. 

View [hyperlink, http://www.gao.gov/products/GAO-12-373]. To view an e-
supplement with more data see GAO-12-370SP. For more information, 
contact George Scott at (202) 512-7215 or scottg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Successful SIG Implementation Has Posed a Number of Challenges: 

States and Districts Screen Contractors Before Selecting Them to 
Receive SIG Funding, but Inconsistent Approach to Reviewing 
Performance Reduces Contractor Accountability: 

Education's Assistance and Oversight Are Supporting SIG Implementation: 

Conclusion: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Education: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Figures: 

Figure 1: Percentage of SY 2010-2011 and 2011-2012 School Grantees 
Using Each Reform Model: 

Figure 2: State Responses on Whether Inadequate Action by SIG Schools 
or Districts Was a Reason Schools Were Not Operating Very Differently: 

Figure 3: Survey Results Regarding the Helpfulness of Education's 
Technical Assistance Offerings: 

Abbreviations: 

Education: U.S. Department of Education: 

SIG: School Improvement Grant Program: 

SY: school year: 

View GAO-12-373 key component: 

School Improvement Grants: Survey of State Educational Agencies 
Regarding Grant Implementation [hyperlink, 
http://www.gao.gov/products/GAO-12-270SP], an e-supplement to 
GAO-12-373. 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

April 11, 2012: 

The Honorable Thad Cochran: 
Vice Chairman: 
Committee on Appropriations: 
United States Senate: 

The Honorable Tom Harkin: 
Chairman: 
The Honorable Richard C. Shelby: 
Ranking Member: 
Subcommittee on Labor, Health and Human Services, Education, and 
Related Agencies: 
Committee on Appropriations: 
United States Senate: 

The School Improvement Grant (SIG) program is designed to fund 
significant reforms in low performing schools. Schools that receive 
SIG funding (SIG schools) receive up to $2 million annually for 3 
years to improve student outcomes, such as standardized test scores 
and graduation rates. While the program--which provides funds to 
states on a formula basis--was first authorized in fiscal year 2002, 
it changed significantly in fiscal year 2009. Specifically, Congress 
greatly increased funding for the program from $125 million in fiscal 
year 2007 to $3.5 billion in fiscal year 2009. From this amount, $3 
billion was provided under the American Recovery and Reinvestment Act 
of 2009, and schools began spending these funds during school year 
(SY) 2010-2011.[Footnote 1] Additionally, a total of approximately 
$1.6 billion was appropriated in fiscal years 2010-2012. 

In addition to funding increases, the U.S. Department of Education 
(Education) made major changes to SIG program requirements in 2010. 
[Footnote 2] As a result of these changes, many schools receiving SIG 
funding must now use the funding to implement one of four intervention 
models, each with specific requirements, such as replacing principals 
or turning over school management or certain school operations to an 
outside organization (contractor). Also, states are now required to 
award SIG funds to school districts competitively, rather than by 
formula. States evaluate grant applications using several criteria, 
including the proposed intervention model for each school and the 
district's budget and reform implementation plan, as well as their 
capacity and commitment to effectively implement the reforms. After 
grant awards are made, states are also responsible for deciding 
whether to renew schools' SIG funding for additional years. State 
renewal decisions are to be based on criteria that can include whether 
school assessment results meet annual student achievement goals, and 
whether the school has implemented its chosen intervention model. 
Education oversees the program by reviewing state grant applications, 
monitoring implementation and providing technical assistance. 

The recent changes to the SIG program have raised questions about how 
grants are being implemented. The Senate Appropriations Committee and 
its Subcommittee on Labor, Health and Human Services, Education, and 
Related Agencies requested that we conduct a broad review of the SIG 
program, and in July 2011 we reported on early implementation issues 
in six states during the first year of the expanded SIG program. 
[Footnote 3] That report found that the program's implementation time 
frames in some cases did not allow schools sufficient time to plan and 
fully enact reforms, and we recommended that the Secretary of 
Education consider options to award SIG grants to school districts 
earlier in the school year. In this review, we addressed the following 
questions: (1) What, if any, aspects of SIG pose challenges for 
successful implementation? (2) How do Education and state guidance and 
procedures for screening potential contractors and reviewing 
contractor performance compare with leading practices? (3) To what 
extent are Education's technical assistance and oversight activities 
effectively supporting SIG implementation? 

To identify aspects of SIG that pose challenges to successful school 
turnaround, we administered a survey to the 50 states and the District 
of Columbia, and received a 100 percent response rate.[Footnote 4] We 
also reviewed Education documents and interviewed Education officials. 
We gathered in-depth information from eight states that were selected 
to represent a range of size, geographic diversity, and the 
intervention models being used. These states were California, 
Delaware, Nebraska, Nevada, Ohio, Rhode Island, Texas, and Virginia. 
In each of the states, we also interviewed school district and school 
officials from one to three districts that had SIG schools. To collect 
information about policies and procedures for screening potential 
contractors and reviewing contractor performance, we examined 
Education guidance and state monitoring policies. We also interviewed 
Education officials and state and local officials from our site visit 
states. We identified leading practices for screening and reviewing 
contractors based on our past work. To evaluate Education's technical 
assistance and oversight efforts, we reviewed relevant documents, such 
as SIG monitoring protocols, and interviewed relevant Education 
officials. We also gathered information from states through our survey 
and state site visits. We interviewed several Education-funded 
technical assistance providers that served our site visit states and 
various stakeholders, such as teachers' union officials. For more 
information about our scope and methodology, see appendix I. 

We conducted this performance audit from January 2011 to April 2012 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Education's changes to SIG requirements in 2010 have led to new 
responsibilities for the agency, states, and school districts. These 
entities all play key roles in the SIG award and implementation 
process, with Education supporting and overseeing state SIG efforts. 
Before awarding formula grants to states, Education reviews each 
state's application and approves the state's proposed process for 
competitively awarding SIG grants and monitoring implementation. As 
part of the state application process, states identify and prioritize 
eligible schools into three tiers: 

* Tier I schools. Receive priority for SIG funding and are the state's 
lowest-achieving 5 percent of Title I schools (or 5 lowest-achieving 
schools, whichever number is greater) in improvement status.[Footnote 
5] 

* Tier II schools. Secondary schools eligible for, but not receiving, 
Title I funds with equivalently poor performance as Tier I schools. 

* Tier III schools. Title I schools in improvement status that are not 
Tier I or Tier II schools. 

After states receive SIG funding, school districts submit applications 
to states describing their SIG reform plans for eligible schools. 
Education has required that districts base their plans on an analysis 
of each school's needs, called a needs assessment. After reviewing 
district applications, states distribute their SIG dollars using their 
approved competitive grant award process, giving priority to districts 
seeking funding for Tier I and Tier II schools. Education's 
regulations and guidance require districts receiving SIG awards for 
Tier I or Tier II schools to implement one of four intervention models 
in each school. Select aspects of each model are as follows: 

* Transformation. Transformation schools must replace the principal, 
implement a transparent and equitable teacher and principal evaluation 
system that incorporates student academic growth, identify and reward 
staff who are increasing student outcomes, and provide increased 
student learning time, among other requirements. 

* Turnaround. In addition to implementing many requirements of the 
transformation model, turnaround schools must use locally adopted: 

* competencies to screen existing staff and rehire no more than 50 
percent of the existing staff. 

* Restart. The district must reopen the school under the management of 
a contractor, such as a charter school operator, charter management 
organization, or education management organization. 

* Closure. The district must close the school and enroll its students 
in a higher achieving school within a reasonable proximity. 

Districts may choose to use contractors to implement aspects of their 
reform plans. Schools enacting a restart model are required to 
contract with an organization that will assume many of the decision-
making and leadership functions in that school. Districts employing 
other models may also contract with external organizations for 
services that could include data analysis, teacher professional 
development, and efforts to create safe school environments. Our work 
notes the importance of screening potential contractors before 
awarding contracts, as well as regular evaluation in order to ensure 
contractors are providing timely and quality services with government 
funds.[Footnote 6] 

In addition to reviewing district applications, states are also 
responsible for monitoring grant implementation. States make decisions 
about whether to renew funding for each SIG school for an additional 
year, based on factors such as whether schools meet annual student 
achievement goals that districts set for the schools. Pursuant to 
Education's guidance, if a school meets its annual goals, the state 
must renew the school's SIG grant. If a school does not meet one or 
more annual goals, Education's guidance gives states the flexibility 
to consider other factors such as the "fidelity with which the school 
is implementing" its chosen intervention model.[Footnote 7] 

Education provides states with technical assistance and oversight 
regarding SIG implementation. For example, Education funds 21 
Comprehensive Centers that help build states' capacity to assist 
school districts and schools. Sixteen of these organizations serve 
states in designated regions, and 5 provide technical assistance on 
specific issues, such as teacher quality. In addition, Education funds 
Regional Educational Laboratories, a network of 10 laboratories that 
serve designated regions by providing access to applied education 
research and development projects, studies, and other related 
technical assistance activities. Education also monitors states' 
implementation of SIG. This monitoring process consists of visits to 
selected states and several SIG districts and schools within the 
monitored states, followed by reports documenting any findings. States 
have an opportunity to respond to any findings before the release of 
Education's monitoring reports. 

States have awarded funding to two cohorts of schools since the 
program was modified and expanded in 2010. In the first cohort, 867 
schools received SIG funding to implement one of the four intervention 
models in SY 2010-2011, and in the second cohort 488 schools received 
funding to implement one of the intervention models in SY 2011-2012. 
Seven states[Footnote 8] have received waivers from Education to delay 
awarding funding to their second cohort of schools until SY 2012-2013 
because of various issues, such as turnover of key staff in state 
educational agencies. The proportion of schools choosing each model 
was similar in both cohorts and, as shown in figure 1, most schools 
chose to implement the transformation model. 

Figure 1: Percentage of SY 2010-2011 and 2011-2012 School Grantees 
Using Each Reform Model: 

[Refer to PDF for image: pie-chart] 

Transformation: 74%; 
Turnaround: 20%; 
Restart: 5%; 
Closure: 1%. 

Source: GAO survey of states. 

[End of figure] 

Successful SIG Implementation Has Posed a Number of Challenges: 

Staff Capacity and Commitment to Reform Posed Implementation 
Challenges: 

Although most states have increased the amount of staff time devoted 
to SIG since the program was expanded, some states have struggled to 
develop the necessary staff capacity to successfully support and 
oversee SIG implementation because of budget constraints. In our 
survey, 29 states told us that they have increased the staff time 
devoted to SIG since they first applied for SIG funds in the expanded 
SIG program. However, officials from four of the eight states we 
visited--California, Nebraska, Rhode Island, and Texas--told us that 
because of budgetary constraints, the time staff could devote to 
administering the SIG program and monitoring district implementation 
was significantly limited. For example, officials in California said 
that as a result of the state budget crisis, the state legislature 
reduced the amount of SIG funds available for state administration 
from the allowable 5 percent[Footnote 9] to 0.5 percent, limiting the 
number of staff available to administer the program and monitor 
districts. Several state officials we spoke with also reported that 
their existing workloads made it difficult to focus on SIG. For 
example, in several states the program was administered by officials 
who also had responsibilities for other major education programs, such 
as Race to the Top.[Footnote 10] 

In addition, state officials sometimes did not have expertise in 
supporting school turnaround efforts. Officials from Education and 
several states and research groups told us that SIG required states to 
support local reform efforts to a much greater extent than they had in 
the past, and staff in some states had not yet developed the knowledge 
base to fulfill these responsibilities. Even when states were able to 
develop expertise in school reform and hire necessary staff, officials 
from Education told us that personnel turnover in many states made it 
difficult to retain such knowledge. For example, Rhode Island 
officials said they encountered difficulties filling vacated positions 
because many nearby states were also recruiting from the same small 
pool of qualified applicants. Several states increased their capacity 
through actions such as contracting with nationally recognized experts 
to help them run their grant competitions, establishing school 
turnaround offices, or hiring turnaround specialists that regularly 
handled an individualized caseload of SIG schools. For example, 18 
states created new turnaround offices to help districts implement SIG, 
according to our survey. 

In addition to these state level issues, many districts also struggled 
to develop the necessary staff capacity to implement successful school 
reforms. It was particularly difficult for schools to recruit and 
retain qualified staff members, according to many stakeholders, 
including officials from several states and districts we visited. They 
told us that SIG schools were sometimes in rural areas or needed staff 
to have expertise that was in short supply, such as experience with 
reform or specialized academic subjects. Among the 12 states that 
Education monitored during SY 2010-2011, they found that 4 states did 
not ensure that turnaround schools met requirements to remove at least 
half of the schools' staff and hire new staff for those positions 
based on staff effectiveness.[Footnote 11] For example, Education 
found that one monitored district in Minnesota did not base hiring 
decisions on prospective teachers' instructional effectiveness. In 
addition, Education found that three of the monitored states did not 
ensure appropriate replacement of the principal in turnaround or 
transformation schools. 

Moreover, some districts did not have staff with expertise in using 
performance and evaluation data--such as data on student performance--
to inform plans for reforming schools and ongoing instructional 
improvements. Education officials said that, in many cases, school 
district staff were able to collect data, but did not have experience 
linking data to needed interventions. In addition, our review of the 
needs assessments districts were required to develop when planning SIG 
interventions showed that some were more extensive than others. Also, 
in one district we visited, the new teacher evaluation process did not 
include state assessment data on student achievement as one of the 
evaluation criteria, as required by Education. Several states, 
districts, and researchers identified promising practices for 
recruiting and retaining staff or improving data usage, such as 
developing "grow-your-own" leadership programs, conducting priority 
hiring for SIG schools, or hiring data coaches to help teachers 
collect and analyze student data. 

Districts also varied in their commitment to use SIG funds to enact 
major reforms. According to our survey, 35 of 51 states awarded grants 
to all or most Tier I applicants who applied for grants starting in SY 
2010-2011, but several officials from states we visited and research 
organizations reported that some districts receiving SIG grants were 
not prepared to make significant reforms. For example, officials in 
one large school district we visited told us they followed turnaround 
model requirements to rehire no more than 50 percent of teachers at a 
SIG school. However, the district officials said they relocated the 
released teachers to other SIG schools in their district because those 
schools had almost all of the vacancies. Similarly, in two states we 
visited, district officials moved a school's previous principal into 
another leadership position on site so that person could continue to 
work in the school even after a new principal was assigned. State and 
district officials also cited instances where districts chose their 
SIG model for reasons other than its likelihood of improving student 
success. For example, the superintendent in one district told us they 
chose the restart model because they considered it less restrictive 
than other models. Although many states responding to our survey told 
us that all or most of their transformation model schools were 
operating very differently after the first year of SIG, 33 states said 
that at least some of these schools choosing the transformation model 
were not.[Footnote 12] Figure 2 shows responses from these 33 states 
about whether inadequate action by SIG schools or districts was a 
reason the schools were not operating very differently. 

Figure 2: State Responses on Whether Inadequate Action by SIG Schools 
or Districts Was a Reason Schools Were Not Operating Very Differently: 

[Refer to PDF for image: pie-chart] 

Reason in none of schools: 1; 
Too early to tell or missing: 2; 
Reason in all schools: 4; 
Reason in around half of schools: 4; 
Reason in most schools: 9; 
Reason in few schools: 13. 

Source: GAO survey of states. 

[End of figure] 

Key SIG Requirements Are Difficult to Implement, Especially Under 
Short Time Frames: 

SIG requirements to increase student learning time and develop new 
teacher evaluation systems were particularly challenging for some 
districts to implement fully, especially given the significant time 
pressure that we identified as a concern in our previous report on 
SIG.[Footnote 13] Indeed, Education found districts that were not 
appropriately implementing increased learning time requirements in 
about half of the states that it monitored during SY 2010-2011 and in 
both states for which it had completed SY 2011-2012 monitoring reports 
by February 2012. According to district officials, at least half the 
districts we spoke with will not have fully implemented new teacher 
evaluation systems by the end of their second year of SIG. In 
addition, during its SY 2011-2012 monitoring visit to Iowa, Education 
found that student growth was not always incorporated in new teacher 
evaluation systems, as required. Our analysis showed that increased 
learning time and teacher evaluation requirements were challenging 
because the planning needed to implement them was complex and time-
consuming, and stakeholders, such as unions and parents, were 
sometimes reluctant to embrace the changes. Some districts struggled 
to develop increased learning time initiatives that would be 
sustainable after their 3-year SIG grant ended. More specifically: 

* Interventions required extensive planning. Effectively implementing 
increased learning time and teacher evaluations required extensive 
planning. Several stakeholders stressed the importance of carefully 
designing increased learning time schedules because, for the 
intervention to be successful, it must provide quality instruction 
rather than simply increasing the amount of poor instruction. 
Officials from several districts said they were unable to fully 
implement their plans for increased learning time at the beginning of 
the first year of increased SIG funding because, for example, they 
first needed to fully analyze their existing schedules and curricula 
and adapt them to meet SIG requirements. Officials from states and 
districts we visited often stressed that developing a teacher 
evaluation system is time-consuming because it requires districts to 
accurately and comprehensively identify, collect, and analyze 
information about teachers' performance and students' academic growth. 
In response to the challenges involved in planning and implementing 
teacher evaluation systems, Education allowed states to apply for a 
waiver to extend the planning period for this requirement, and 27 
states applied for and received the waiver as of February 2012. In its 
final SIG requirements, Education required schools implementing the 
transformation model to implement new teacher evaluation systems 
within the first year of the grant. Districts in states receiving 
these waivers must develop their evaluation systems during SY 2011-
2012; pilot or fully implement them by SY 2012-2013; and use them to 
make decisions about retention, promotion, and compensation by SY 2013-
2014. The timeline is the same regardless of whether the SIG schools 
in the district are from the first or second SIG cohort. 

* Stakeholders sometimes reluctant to embrace required changes. 
Implementation was also delayed or otherwise challenged by concerns 
from various stakeholder groups. Teachers and teachers' unions were 
sometimes concerned about increasing student learning time or 
implementing new teacher evaluations in SIG schools, according to 
Education, state, and district officials. For example, these officials 
said unions were concerned about whether teacher evaluation systems 
that incorporated student academic growth could do so in a manner that 
would not penalize teachers working with the most challenging 
students. Such concerns sometimes led to delays in finalizing 
evaluation systems. In a few cases, officials told us that other 
stakeholder groups such as parents and school board members were also 
resistant to SIG requirements. For example, an official in Virginia 
said that some schools trying to increase learning time had met 
resistance from parents because students often had jobs or 
responsibilities at home once the traditional school day was over. 

* Difficulty designing sustainable approaches for increasing learning 
time. State and district officials also questioned whether increased 
learning time initiatives would be sustainable after SIG funds were 
exhausted. For example, survey respondents from 26 states said the 
costs of increased learning time were unlikely or very unlikely to be 
sustainable after the SIG grant ends, compared with 10 states that 
reported it was likely or very likely to be sustainable.[Footnote 14] 
Rhode Island officials noted that increased learning time benefits 
students enrolled in SIG schools during the grant cycle, but state and 
local financial constraints will make it difficult to sustain the 
increased learning time for future students. Due in part to these 
concerns, one of the two districts in the state with SIG schools 
limited the amount of learning time it added in order to avoid 
significant cuts in this time after grant funding ends. 

While many officials stressed the complexity of effectively 
implementing these requirements, some states and districts that we 
visited found ways to address the challenges they posed. This was 
particularly true in districts that had started to plan for and 
implement similar school reforms prior to applying for SIG funds. Many 
officials from Education, state, and districts stressed the importance 
of stakeholder involvement while designing and implementing SIG 
reforms in order to enhance buy-in and strengthen reform initiatives. 
In order to increase students' learning time without increasing 
teacher workloads and salaries, Education officials and researchers 
told us that a few districts were working with community partners to 
fund or staff additional learning time or were staggering teachers' 
schedules so that students would be in class longer but teachers would 
not. In addition, a few states developed sample teacher evaluation 
system that met SIG requirements so that districts could use it as a 
framework for developing their own systems. 

Some States Had Limited Evidence about SIG Grant Performance When 
Making Grant Renewal Decisions: 

States often had limited evidence for making decisions about whether 
to renew schools' SIG funding. For example, in our survey, officials 
from 10 states told us that they did not use schools' achievement of 
annual goals to make grant renewal decisions after SY 2010-2011. 
According to state officials, at least half the states we interviewed 
did not have the annual student achievement data available at the time 
they had to make renewal decisions because assessment results only 
became available at the end of the summer. Officials from two of these 
states told us that timely access to annual achievement data will 
continue to be a problem in future years. In addition, even when these 
data were available, states frequently chose not to base their 
decisions on schools' achievement of annual goals. Twenty-three of 44 
states responding to our survey question said that, among schools that 
had their funding renewed, all or most did not meet their annual 
goals. Several officials from our site visits questioned the 
usefulness of annual goal data in determining whether progress was 
made, particularly because districts set their own performance 
targets. For example, California officials said they did not find 
annual goals data useful because districts often included generic 
annual goals in their applications for SIG funding instead of 
proposing goals based on schools' unique circumstances. 

Regardless of whether annual goals information was available, states 
almost always considered "fidelity of implementation"--the extent to 
which the school is implementing the requirements of its intervention 
model--when making grant renewal decisions. However, states did not 
always base decisions about this criterion on extensive information. 
In our survey, 48 of 51 states identified fidelity of implementation 
as an important factor in their decision-making process, more than any 
other factor. Several states we spoke with said that qualitative 
information about implementation was important for assessing grant 
progress because the first steps of school reform, such as efforts to 
change school culture, do not always result in measurable student 
achievement gains. However, making this assessment can involve a high 
degree of subjectivity and states' determinations were not always 
developed based on extensive interaction with schools or systematic 
monitoring of their implementation efforts. For example, officials in 
California told us they used fidelity of implementation as their key 
criterion for making grant renewal decisions, and that the primary 
method for evaluating this criterion was one telephone conversation 
with each district at the end of the year. Prior to those 
conversations, the state had limited interaction with most districts 
for the purpose of assessing their implementation and was unable to 
conduct SIG monitoring visits for budgetary reasons. In addition, a 
Virginia official told us the state used fidelity of implementation 
for making renewal decisions but would benefit from guidance on how to 
define and measure it. 

States were in some cases reluctant to discontinue SIG funding even 
when information they collected showed that schools were not 
implementing key requirements with fidelity. Several officials from 
states we visited said they renewed all schools' SIG funding even if 
the schools were struggling to fulfill key SIG requirements because 
tight implementation timeframes made the officials reluctant to 
eliminate funding after the first year of the grant. In our survey, 21 
states reported that half or fewer of their Tier I and Tier II schools 
were able to implement major aspects of their plan by the beginning of 
SY 2010-2011, such as extending the school day or having new staff in 
place. In the 19 cases where these states had made renewal decisions, 
the state renewed all or most grants. Furthermore, officials in 
several states we visited identified instances where they chose to 
renew schools' funding despite significant problems at the district or 
school level, such as having administrators who were not committed to 
enacting major reforms or were not ensuring that planned reforms were 
fully implemented. For example, officials from Nevada said they 
renewed such grants after the first year because they did not want to 
negatively impact students and teachers when significant district-
level problems were outside their control. 

Although Education reviewed states' proposed grant renewal procedures 
through the state SIG application process, the agency did not provide 
written guidance after grant renewal challenges arose. Education 
required states to submit their renewal processes for review as part 
of their SIG applications. Nonetheless, in several state applications 
we reviewed, descriptions of renewal processes and criteria did not 
align with the practices the state actually implemented. For example, 
states that told us they were unable to use annual goals data to make 
renewal decisions had originally identified these goals as a key 
renewal criterion in their applications to Education. In its work with 
states, Education officials told us they found some had difficulty 
using annual goals data or fidelity of implementation and that the 
agency provided technical assistance to several states that asked for 
help. However, agency officials were not aware of how states 
ultimately addressed these issues, and said the agency has not 
provided any additional technical assistance on grant renewal. 
[Footnote 15] 

States renewed almost all SIG grants at the end of SY 2010-2011, and 
in some cases imposed conditions on schools for renewal. According to 
Education, 39 states chose to renew funding to every SIG school in 
their state. Eleven states and the District of Columbia chose not to 
renew funding to one or more schools, for a total of 16 nonrenewed 
schools overall.[Footnote 16] Of these 16 schools, about two thirds 
were not renewed due to problems with fidelity of implementation. 
Several states we spoke with chose to renew grants with conditions or 
required changes. For example, officials in Ohio told us that 
struggling schools were required to take corrective actions in the 
second year of the 3-year grant and that their level of success in 
taking such actions will be a key criterion in future renewal 
decisions. In addition, New York officials renewed all grants after SY 
2010-2011 under the condition that transformation and restart schools 
would implement state and federal SIG teacher evaluation requirements 
by December 30, 2011. Once that deadline passed, state officials 
determined that no districts had met the requirements and suspended 
all SIG funding until they were met. In February 2012, the state 
commissioner reinstated funds to half of the SIG districts after 
determining that the districts had made the necessary changes. In our 
survey, 23 states reported that at least a few of their SIG schools 
were required to make major changes to their SIG plans as a condition 
of having funding renewed. 

States and Districts Screen Contractors Before Selecting Them to 
Receive SIG Funding, but Inconsistent Approach to Reviewing 
Performance Reduces Contractor Accountability: 

Contractors Provide a Wide Range of Services, and Many Receive 
Significant Amounts of SIG Funding: 

Contractors provide a wide range of services with SIG funds, and 
school districts have often given contractors major roles in schools 
using the restart, turnaround, and transformation models. Education's 
guidance identifies a clear role for contractors in schools using the 
restart model. Specifically, districts must hire a contractor to take 
over school operations. For example, in the Los Angeles Unified School 
District, the Partnership for Los Angeles Schools has been given full 
management authority over five restart schools. In contrast, Education 
allows districts with schools using the turnaround and transformation 
models--which include more than 90 percent of schools receiving SIG 
funds--to use contractors, but does not identify a specific role for 
them. Most turnaround and transformation schools we visited were 
working with contractors. Although in some cases turnaround and 
transformation schools used these contractors for minor tasks, in 
other cases the contractors played a major role in school operations. 
For example, in Virginia, the state required schools implementing the 
turnaround and transformation intervention models to use a contractor 
for a range of services that could include improving teacher 
performance, principal and management leadership, or changing school 
culture. 

Among the school districts we visited, several planned to spend 
significant amounts of their SIG grants on hiring contractors. These 
included districts using the restart, turnaround, and transformation 
models. For example, a district with one SIG school using the 
transformation model planned to spend about $450,000 for contractors 
in one school year. In addition, a district that we visited with three 
SIG schools planned to spend approximately $1.5 million on contractors 
over the 3-year period for services that included data analysis and 
curriculum planning. 

Our prior work and reports regarding services acquisition have shown 
the importance of building safeguards into acquisition processes to 
ensure accountability. These leading practices include screening 
potential contractors prior to award using a thorough selection 
process that evaluates their ability to achieve results and the 
contractors' past performance.[Footnote 17] Once a contractor has been 
selected, officials should routinely review contractors' work to help 
ensure they are providing timely and quality services and to help 
mitigate any contractor performance problems.[Footnote 18] 

Education and States Required Contractors to Be Screened, but 
Screening Procedures Varied: 

Education required and states reported requiring that potential 
contractors be selected after a thorough screening process. Education 
required that either states or districts screen contractors prior to 
contract award to ensure their quality.[Footnote 19] Although 
Education's guidance does not provide specific criteria for approval, 
Education requires each state to describe in its state application how 
it will ensure that school districts screen contractors. Each of the 
eight states we reviewed required districts to describe their plans to 
screen contractors in their applications for SIG funding. 

In addition, states varied in how they approached contractor screening 
at the state level, either taking an active role in the process or 
delegating screening responsibilities to districts. According to our 
survey, 17 of the 51 developed approved lists of contractors from 
which districts could choose. For example, Virginia officials told us 
they enacted statewide contracts with four organizations, and strongly 
encouraged districts to choose one of those four organizations. Ohio 
officials said they developed a list of approximately 100 state-
screened organizations from which districts could choose, but 
districts were free to use other contractors, provided that they 
screened those organizations. States that we visited that did not 
develop a list of approved contractors reported requiring districts to 
screen contractors. For example, Texas officials told us they required 
all districts to use a formal competitive process in selecting 
contractors, which included a process to evaluate contractor 
proposals, in order to be approved by the state. 

Education Does Not Require that All Contractors' Performance Be 
Reviewed, and State Review Approaches Vary: 

Education's monitoring protocols for the SIG program require the 
review of contractors in schools using the restart model, but they do 
not require review of contractors during contract performance for the 
other school improvement models. Education's protocol for monitoring 
states' SIG implementation asks whether districts have included 
accountability measures in the contract for restart schools and also 
asks for the district's current assessment of the contractor. The 
protocol does not include a similar question for turnaround and 
transformation schools.[Footnote 20] 

States varied in their approaches to the review of contractors, and in 
some cases reported that they did not require that districts review 
contractors during contract performance. Among the eight states we 
spoke with, none assessed districts' plans to review contractors in 
their SIG applications. In addition, several states reported not 
having any state-level review requirements. For example, Nebraska 
state officials said their districts conduct informal reviews of the 
contractors, but the state does not require reviews or provide 
districts with a formal process or metrics to assess performance. 
Similarly, in follow up calls for our state survey, state officials in 
several states said they do not require districts to review contractor 
performance and were unaware of whether districts conducted any 
reviews. In contrast, Nevada officials told us they require districts 
to add accountability steps for contractors in each phase of work. 

Inconsistent review of contractors during contract performance reduces 
states' and districts' ability to ensure that they are receiving the 
services they have paid for. In our work, one stakeholder told us that 
in the absence of stronger guidance or oversight, the extent to which 
contracts include accountability measures is largely dependent on the 
knowledge and experience of the individual contract manager. Although 
some district officials in our site visits described efforts to 
include accountability measures or regular review in the contracts, 
others indicated that contractors are reviewed informally, if at all. 

Education's Assistance and Oversight Are Supporting SIG Implementation: 

Education's Technical Assistance Was Well Received by States: 

Education's guidance and technical assistance on SIG implementation 
was well received by nearly all states. In our survey, nearly all 
states responded favorably about Education's guidance and various 
technical assistance offerings for SY 2011-2012. Most states reported 
that Education's guidance and technical assistance were helpful and 
many reported they were very helpful (see fig. 3). In our survey, we 
also inquired about the amount and timeliness of guidance provided by 
Education. Forty-one states reported that Education provided about the 
right amount of guidance for the second year of SIG. In addition, 33 
states responded that in SY 2011-2012, Education's guidance was 
timely, allowing the state to meet its needs, while 14 states 
commented that the guidance was not timely. 

Figure 3: Survey Results Regarding the Helpfulness of Education's 
Technical Assistance Offerings: 

[Refer to PDF for image: horizontal bar graph] 

Technical assistance offering: Guidance documents; 
Very helpful: 21; 
Helpful: 26; 
Neither helpful nor unhelpful: 1; 
Unhelpful: 1; 
Very helpful: 1. 

Technical assistance offering: Conferences; 
Very helpful: 24; 
Helpful: 19; 
Neither helpful nor unhelpful: 4; 
Unhelpful: 2; 
Very helpful: 1. 

Technical assistance offering: Webinars or teleconferences; 
Very helpful: 12; 
Helpful: 29; 
Neither helpful nor unhelpful: 4; 
Unhelpful: 3; 
Very helpful: 1. 

Technical assistance offering: 1-on-1 technical assistance; 
Very helpful: 20; 
Helpful: 19; 
Neither helpful nor unhelpful: 5; 
Unhelpful: 1; 
Very helpful: 1. 

Technical assistance offering: Comprehensive centers; 
Very helpful: 18; 
Helpful: 19; 
Neither helpful nor unhelpful: 6; 
Unhelpful: 0; 
Very helpful: 0. 

Technical assistance offering: Newsletters/emails; 
Very helpful: 5; 
Helpful: 30; 
Neither helpful nor unhelpful: 7; 
Unhelpful: 2; 
Very helpful: 1. 

Technical assistance offering: Website; 
Very helpful: 3; 
Helpful: 30; 
Neither helpful nor unhelpful: 11; 
Unhelpful: 2; 
Very helpful: 1. 

Technical assistance offering: Regional education laboratories. 
Very helpful: 9; 
Helpful: 20; 
Neither helpful nor unhelpful: 6; 
Unhelpful: 0; 
Very helpful: 1. 

Source: GAO survey of states. 

Note: The data for this graphic is from our survey, in which we asked 
states about the helpfulness of specific technical assistance 
offerings. In addition to the answers presented, we also included "do 
not know" as a potential response. We also asked states about the 
usefulness of Education's communities of practice, the implementation 
initiative, and the on-site monitoring visit. For these three items, 
the number of states responding "do not know" was 23, 30, and 30, 
respectively. Because the "do not know" responses were numerous, we 
did not include them in our graphic. 

[End of figure] 

Although most states told us that Education's guidance was helpful, 
some identified additional technical assistance that would assist with 
SIG implementation. In an open-ended question on our survey that asked 
about the types of additional guidance that Education could provide, 
15 states indicated they wanted additional information about other 
states' SIG implementation efforts that are working well. Several 
states that we met with also mentioned wanting more information on 
successful and sustainable implementation strategies, proven 
contractors, increased learning time strategies, and teacher/principal 
evaluation systems. 

To provide additional support and enhance information sharing among 
the states, Education has recently begun three new assistance efforts. 
First, Education selected nine states to participate in the SIG 
"implementation support initiative" as an optional technical 
assistance resource.[Footnote 21] Under this initiative, each 
participating state receives a visit from an Education representative 
as well as officials from the eight other participating states. These 
site visits have two purposes--first, to provide technical assistance 
to the states, and second, to enable states to engage in peer-to-peer 
information sharing. Education reported that they have used 
information from these site visits to produce targeted technical 
assistance reports. Second, in December 2011, Education began 
conducting monthly check-in calls with state officials to better 
manage SIG implementation. Each state was assigned an Education 
program officer responsible for providing oversight and technical 
assistance support, including outreach and monthly check-in calls. 
Lastly, Education launched the School Turnaround Learning Community--
an on-line forum to provide states and districts with access to 
resources and to facilitate networking. According to Education, this 
initiative offers research-based practices and practical examples from 
states, districts and schools for developing and implementing SIG. 

Education is Now Using a Risk-Based Approach to Monitor All States 
within 3 Years: 

Education's oversight strategy is to monitor all states during the 3-
year period[Footnote 22]--starting with SY 2010-2011--in which the 
first cohort of schools will receive SIG funding. In selecting states 
for on-site monitoring for SY 2010-2011, Education did not use a SIG-
specific risk-based approach and instead used the existing Title I 
monitoring schedule.[Footnote 23] However, due to resource 
constraints, Education suspended its Title I monitoring and instead 
focused exclusively on SIG monitoring. Education also delayed SY 2010-
2011 monitoring to allow states and districts time to implement SIG 
before beginning monitoring in February 2011. For SY 2010-2011, 
Education conducted on-site monitoring in 12 states[Footnote 24] 
uncovering 28 deficiencies. At least one deficiency was identified in 
11 of the 12 monitored states, with California and Pennsylvania having 
the most deficiencies with seven and five, respectively. Half of the 
monitored states had deficiencies in ensuring appropriate district 
implementation of the increased learning time requirement. In 
addition, two states did not ensure that all SIG funds were used 
consistent with the SIG requirements.[Footnote 25] 

In SY 2011-2012, Education selected states with a risk based approach 
tailored for SIG based on factors such as the size of a state's SIG 
grant. For SY 2011-2012, Education officials initially selected 12 
states to conduct on-site monitoring.[Footnote 26] As of February 
2012, Education had issued SY 2011-2012 monitoring reports for Iowa 
and Florida, containing seven and two deficiencies respectively. For 
example, in Iowa, Education found that funds were not used 
consistently with SIG grant requirements nor was the state monitoring 
SIG as written in its approved SIG application. Education also set 
aside a portion of its oversight resources so that additional states 
could be selected for monitoring as more information became available. 
As of February 2012, Colorado and South Carolina were also selected to 
receive an on-site review. To maximize its oversight resources, 
Education plans to conduct some limited "desk monitoring" in five 
additional states in SY 2011-2012.[Footnote 27] According to 
Education, the desk monitoring protocol is similar to the on-site 
visit protocol, but--unlike the on-site monitoring--does not include 
interviews with school officials. Finally, Education officials told us 
that they plan to monitor the remaining states in SY 2012-2013, and 
that these states represent a small percentage of SIG funds. 

Conclusion: 

Dramatic funding increases in a short period of time--such as those 
made to SIG--can subject federal programs to considerable financial 
risk. While states and school districts carry a large share of the 
responsibility for planning and implementing successful SIG reforms, 
Education also plays a critical role in supporting these efforts and 
mitigating risk through strong oversight and accountability. For 
example, it is important that Education have rigorous processes for 
reviewing state SIG applications, conducting oversight, and providing 
technical assistance when needed. The ability to successfully carry 
out these functions is vital to ensuring the long-term success of the 
SIG program and protecting taxpayer funds from waste and abuse. 
Although SIG has been challenging to implement, in part due to the 
short implementation timeframes we highlighted in our July 2011 
report, Education has reviewed state SIG applications, distributed 
funds to states, begun its monitoring activities, and provided 
technical assistance. However, the agency's guidance in some cases has 
not been sufficient to ensure that schools and contractors are fully 
accountable. For example, given the implementation issues we and 
Education's monitoring have found, it is critical that states have 
rigorous SIG grant renewal procedures in place to identify schools 
that are not making progress. Education has provided limited guidance 
to states about how to make renewal decisions. Some states are using 
highly subjective review processes to renew nearly all grants, often 
without key information on SIG schools' performance. Until Education 
provides additional support about how states should make evidence-
based renewal decisions when, for example, state assessment results 
are received too late to be factored into these decisions, schools 
that are not making progress may continue receiving SIG funds. In 
addition, although contractors are receiving large amounts of many 
schools' SIG funds, Education has not ensured that states or districts 
review contractor performance during the terms of their contracts. 
Unless Education takes action to ensure that states or districts 
review contractor performance, districts may not receive an 
appropriate level of contractor services for their SIG funds and funds 
may not be well spent. 

Recommendations for Executive Action: 

To ensure that SIG grant renewal decisions serve to hold districts and 
schools accountable, we recommend that the Secretary of Education 
provide additional support to states about how to make evidence-based 
grant renewal decisions, particularly when states do not have annual 
student achievement goal information available at the time renewal 
decisions are made. 

To ensure that contractors hired with SIG funding are accountable for 
their performance, we recommend that the Secretary of Education take 
steps to ensure that the performance of SIG funded contractors, 
including those in turnaround and transformation schools, is reviewed 
during contract performance. In developing such requirements and to 
ensure that those reviews are targeted to contractors receiving large 
amounts of SIG funding, Education could consider setting a dollar 
threshold amount for contracts, above which contractor performance 
should be reviewed. 

Agency Comments and Our Evaluation: 

We provided a draft copy of this report to the Department of Education 
for review and comment. Education's comments are reproduced in 
appendix II. Education generally supported our recommendation about 
SIG grant renewal and outlined how the agency is planning to address 
this recommendation. 

Education did not agree with our draft recommendation that it should 
require states to ensure that the performance of all SIG-funded 
contractors be reviewed, including contractors in turnaround and 
transformation schools. In its comments, Education said that it 
believed that existing provisions and requirements address this issue 
appropriately. For example, Education cited a federal regulation that 
requires districts to follow their existing procurement procedures, 
and noted that districts and states have their own requirements for 
evaluating contractors to ensure accountability. Education also said 
that the type of evaluation process needed for a contractor should 
depend on the contractor's role, and that contractors used by schools 
implementing the turnaround or transformation models may be working on 
small, discrete projects and may require less provider-specific 
reviews than contractors in schools implementing the restart model. 

We agree with Education that the need for performance reviews should 
be dependent on the specific role of the contractor, and we modified 
our recommendation to address some of Education's concerns. 
Specifically, Education may wish to create a dollar threshold above 
which performance reviews are required. We continue to believe, 
however, that the current monitoring framework is inadequate. As noted 
in our report, schools implementing the turnaround and transformation 
models account for the overwhelming majority of SIG schools, and 
contractors operating in these schools are performing a range of 
functions, including some that are large or complex. In our view, 
there is a need for additional steps to ensure adequate review of 
contractor performance. Furthermore, our work shows that as a 
practical matter, states varied in their approaches to contractor 
review, with some imposing no requirements on districts. Education 
says that it will clarify in existing guidance the requirement for SIG 
recipients to follow state and local procurement procedures. Education 
could use this opportunity to implement our recommendation through 
additional guidance on contractor performance reviews. 

In addition, Education implied that our report was based only on the 
first year of SIG implementation. This is inaccurate. We also 
conducted interviews with all eight states, reviewed SIG documents, 
received finalized survey responses, and interviewed Education 
officials several times during the second year of implementation, 
thereby enabling us to reflect activities beyond the first year. Based 
on the number and significance of deficiencies identified in 
Education's SIG monitoring reports--including some completed during 
the SY 2011-2012--as well as our own findings, we continue to believe 
that Education should take additional steps to increase program 
accountability. 

Education also provided technical comments that we have incorporated 
into the report as appropriate. 

We are sending copies of this report to relevant congressional 
committees, the Secretary of Education, and other interested parties. 
In addition, this report will be available at no charge on GAO's 
website at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made key contributions to 
this report are listed in appendix III. 

Signed by: 

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

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This study's objectives were to answer the following questions: (1) 
What, if any, aspects of the School Improvement Grant (SIG) program 
pose challenges to successful implementation? (2) How do U.S. 
Department of Education (Education) and state guidance and procedures 
for screening potential contractors and reviewing contractor 
performance compare with leading practices? (3) To what extent are 
Education's oversight and technical assistance activities effectively 
supporting SIG implementation? To meet these objectives, we used a 
variety of methods, including document reviews of Education and state 
documents; a web-based survey of the 50 states and the District of 
Columbia; interviews with Education officials and stakeholders; site 
visits to and teleconferences with 8 states; and a review of the 
relevant federal laws, regulations, and guidance. The survey we used 
was reviewed by Education and several external reviewers, and we 
incorporated their comments as appropriate. 

We conducted this performance audit from January 2011 through April 
2012 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Providing Information on Challenges to Successful SIG Implementation: 

To identify aspects of the SIG program that pose challenges for 
successful SIG implementation, we analyzed responses to our survey of 
state educational agency officials with responsibility for SIG in the 
50 states and the District of Columbia. The wed-based survey was in 
the field from August to October 2011. In the survey, we asked states 
to provide information on challenges they faced in implementing the 
SIG program and on other aspects of the program, such as SIG grant 
renewal. We received responses from all 50 states and the District of 
Columbia, for a 100 percent response rate. We reviewed state responses 
and followed up by telephone and e-mail with select states for 
additional clarification and context. 

Nonsampling error could affect data quality. Nonsampling error 
includes variations in how respondents interpret questions, 
respondents' willingness to offer accurate responses, and data 
collection and processing errors. We included steps in developing the 
survey, and collecting and analyzing survey data to minimize such 
nonsampling error. In developing the web survey, we pretested draft 
versions of the instrument with state officials in various states to 
check the clarity of the questions and the flow and layout of the 
survey. Education officials also reviewed the draft survey and 
provided comments. On the basis of the pretests and reviews, we made 
minor revisions of the survey. Using a web-based survey also helped 
remove error in our data collection effort. By allowing state SIG 
directors to enter their responses directly into an electronic 
instrument, this method automatically created a record for each SIG 
director in a data file and eliminated the errors (and costs) 
associated with a manual data entry process. In addition, the program 
used to analyze the survey data was independently verified to ensure 
the accuracy of this work. Detailed survey results are available at 
GAO-12-370SP. 

We also conducted site visits to and teleconferences with eight 
states--California, Delaware, Nebraska, Nevada, Ohio, Rhode Island, 
Texas, and Virginia--that reflect a range of population size, number 
of SIG schools, and use of the four SIG intervention models. In each 
state, we interviewed state officials, as well as district or school 
officials from one to three districts that had Tier I or Tier II SIG 
schools. Districts were selected in consultation with state officials 
to cover heavily and sparsely populated areas, and a variety of SIG 
intervention models. We also reviewed documents, such as state and 
district applications for SIG funds, and the relevant federal laws, 
regulations and guidance.[Footnote 28] We interviewed Education 
officials and stakeholders, such as teachers' union officials from the 
national and local levels. 

Identifying How Education and State Guidance on Contractors Compare 
with Leading Practices: 

To gather information about state policies and procedures for 
selecting and overseeing contractors, we analyzed state survey 
results. Our survey questions included whether states had developed a 
list of approved contractors, the SIG turnaround models for which they 
required that districts work with contractors, and whether states 
reviewed contractor performance. We reviewed Education documents, 
including SIG guidance, the state application template, and monitoring 
protocols, and interviewed Education officials responsible for 
reviewing state applications and providing oversight of states. 
Further, we reviewed state and district SIG applications from the 
eight states to identify their selection and review processes for 
contractors, and proposed contract expenditures. We also spoke with 
state and local officials about their procedures for selecting and 
overseeing contractors, as well as with several contractors working 
with districts we visited. We compared Education and state 
requirements for selecting and overseeing SIG contractors to leading 
contracting practices that were identified through collaboration with 
our contracting experts and review of GAO-09-374[Footnote 29] and GAO-
05-274.[Footnote 30] 

Describing the Extent to Which Education Has Supported SIG 
Implementation: 

To address the extent of Education's support and oversight of SIG 
implementation, we reviewed Education guidance, summaries of Education 
assistance, monitoring time frames, monitoring protocols, and 
monitoring reports from SY 2010-2011. In addition, we analyzed survey 
results. We asked states to provide information on the federal role in 
SIG, including their perspectives on technical assistance offered by 
Education and Education's monitoring process. We also talked with 
officials from Comprehensive Centers and Regional Educational 
Laboratories serving several of the eight states we worked with. The 
technical assistance providers were selected to include those working 
with large, medium, and small rural states. In addition, we 
interviewed Education officials in charge of the Comprehensive Centers 
Program and in charge of SIG monitoring efforts. 

[End of section] 

Appendix II: Comments from the Department of Education: 

United States Department of Education: 
400 Maryland Ave., SW: 
Washington, DC 20202: 
[hyperlink, http://www.ed.gov] 

March 23, 2012: 

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

Dear Mr. Scott: 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO's) draft report, "School Improvement 
Grants: Education Should Take Additional Steps to Enhance 
Accountability for States, Schools and Contractors" (12-373). We 
appreciate the time that your office has committed to this study and 
your efforts to gather grantee perspectives on implementation. 

The School Improvement Grants (SIG) program focuses on tuning around 
the country 's persistently lowest-achieving schools. It requires 
States and districts to target rigorous interventions, and funding to 
support those interventions, at those schools that have continued to 
fail students year after year. Given the difficulty and complexity of 
some of these very important tasks, we anticipated that States and 
districts would encounter various challenges, and we developed 
extensive guidance and provided technical assistance to help them meet 
those challenges. While we agree that tackling specific aspects of SIG 
requirements may not be easy for some districts and schools, it is 
nonetheless important work that is already showing great promise and 
early positive results. 

States and districts have demonstrated courageous leadership in 
implementing reforms that require them to do things in a different way 
than they have done before. And districts and their school leaders and 
teachers across the country are taking on their duties under SIG 
responsibly and effectively. We are encouraged that most of your 
survey respondents reported that most or all of their schools 
implementing the transformation model are operating very differently 
after the first year of SIG. That means that hundreds of the lowest-
performing schools across the country are making dramatic changes 
under the SIG program. While initially we were not expecting 
significant increases in achievement gains after the first year of 
implementation, there are preliminary data from 43 States that show 
meaningful improvement. 

To provide some further background on the program, SIG seeks to 
accelerate achievement in our nation's lowest-performing five percent 
of schools through far-reaching interventions. Federal grants support 
school leaders, teachers, unions, and local partners in the community 
to undertake this challenging work. We are seeing some very 
encouraging signs of progress in the first year of data from SIG 
schools, which few experts anticipated. 

At the national level, the No Child Left Behind law required 
persistently low-performing schools to take action to improve student 
learning. But in reality, chronically underperforming schools were 
required to do little—and for years the Federal government provided 
little or no money to help support change in these schools. Almost no 
high schools, for example, were included in the earlier Federal school 
improvement efforts—even though just 15 percent of our nation's high 
schools produce half of the nation's 1.2 million dropouts. 

SIG has impacted over 1,200 schools, each of which received a three-
year grant of up to $2 million a school. In the first cohort of 
schools, 45 percent were high schools. Some of the nation's high 
schools present some of the toughest challenges. We are still getting 
in the results of the first year of the SIG program. But preliminary 
data show that after just one year, the commitment to change is 
producing dramatic gains in learning in a significant number of schools.
There are about 850 schools in the first SIG cohort. We now have 
preliminary achievement data from 43 States, covering about 700 of 
those schools in their first year of the program. In year one, roughly 
one in four schools saw double-digit increases in mathematics 
proficiency. About one in five schools had double-digit increases in 
reading proficiency. In roughly 60 percent of SIG schools, the 
percentage of students who were proficient in mathematics or reading 
went up in the first year of the program. 

As encouraging as these increases in academic achievement are, they 
arc still preliminary. We will need several years of data to confirm a 
lasting improvement in academic achievement. We are also continuing to 
gather data on other critical outcomes that matter to assessing 
student progress, such as changes in graduation rates, dropout rates, 
discipline, attendance, and other indices. 

States are taking very seriously their responsibility to award grants 
and provide effective oversight and support to their districts and 
schools. We are encouraged that, according to your survey, 29 States 
increased the amount of staff dedicated to the SIG program since
2009 and 50 States linked each SIG school or district with a 
designated State support person or team. Moreover, 31 States have 
visited SIG districts at least once a month for monitoring or 
technical assistance, and all have been providing technical assistance 
to their districts through webinars, conferences, and telephone calls. 

We also agree that States have some varying levels of capacity to 
implement the SIG program, especially because they have been required 
to provide new levels of support and oversight for their lowest-
performing schools. For this reason, the Department has focused on 
providing technical assistance to States to help build capacity. In 
addition to our guidance and application support, we launched the 
online School Turnaround Learning Community, which now has over 3,000 
members, to provide webinars and tools to support implementation of 
challenging interventions like increased learning time and teacher 
evaluations. We also initiated a peer-to-peer technical assistance 
initiative that brings State SIG leads to other States to observe and 
learn from promising practices in those other States. We are pleased 
that, as the draft report noted, the Department's technical assistance 
has been well received by nearly all the States: 44 States reported 
that the Department's guidance and resources are helpful or very 
helpful and all 11 States in the peer-to-peer initiative found it 
helpful or very helpful. 

In the fall of 2011, the Department also created the new Office of 
School Turnaround (OST) in the Office of Elementary and Secondary 
Education to administer the SIG program. OST has focused on increasing 
formal monitoring, as well as regular communications with SIG grantees 
through frequent check-in calls. As a result, the Department has more 
information to address implementation challenges and identify 
opportunities to target technical assistance and oversight to where 
they are most needed. Because we understand that States want even more 
opportunities to learn from each other, we continue to provide those 
peer-to-peer efforts though additional conferences, the online
School Turnaround Learning Community, and a second round of the peer-
to-peer technical assistance initiative. 

Our responses to your specific recommendations for the Department are 
as follows: 

Recommendation #1: To ensure that SIG grant renewal decisions serve to 
hold districts and schools accountable, we recommend that the 
Secretary of Education provide additional support to states about how 
to make evidence-based grant renewal decisions, particularly when 
states do not have annual student achievement goal information 
available at the time renewal decisions are made. 

We have no significant objection to Recommendation 1, since the 
Department is already providing such additional support to help States 
with these issues. It should be noted, however, that two different 
types of evidence may inform a State educational agency's
(SEA'S) evidence-based decision regarding whether to renew a local 
educational agency's (LEA's) SIG grant with respect to a particular 
school or schools: (1) "results-based" evidence, or evidence related 
to achievement and progress on the SIG leading indicators; and (2) 
"process-based" evidence, or evidence related to how a school or LEA 
is implementing a SIG intervention model and whether that 
implementation is in accordance with the LEA's approved application 
and the requirements of the SIG program. 

With respect to "results-based" determinations, the Department 
recognizes that turning around the nation's lowest-achieving schools, 
which by definition have experienced year after year of failure, is 
challenging work that does not always bring immediate results. The
Department also recognizes that improvement in academic achievement 
often may not be evident in one academic year, even though we have 
seen some early successes in the SIG program. With this in mind, the 
Department issued final requirements for the SIG program that require 
SEAs to renew an LEA's SIG grant with respect to all schools that are 
meeting their achievement goals and making progress on the SIG leading 
indicators, and that permit SEAs to renew the grants even with respect 
to schools that are not making their goals. The SIG requirements also 
permit SEAs to set their own criteria for making renewal decisions 
with respect to grants for schools that are not meeting their 
achievement goals and making progress on the leading indicators. 

Consistent with the Department's view about the time it may take to 
improve achievement in persistently lowest-achieving schools, many 
SEAs were reluctant to terminate SIG grants at the end of the first 
year of implementation for a school's failure to meet its achievement 
goals and to demonstrate progress on the leading indicators, as the 
SEAs felt there had not been sufficient time for schools to 
demonstrate progress in improving student achievement. Additionally, 
as noted in the GAO draft report, student achievement data were not 
available in many States at the time renewal decisions were made at 
the end of the first year, but became available during the second year 
of implementation. Given State timelines in reporting achievement 
data, we agree that SEAs would benefit from some additional guidance 
on how to make "results-based-renewal decisions when they do not have 
annual achievement data available at the time renewal decisions are 
made. 

With respect to "process-based" determinations, under section 440 of 
the General Education Provisions Act, 20 U.S.C. § l232c, an SEA has 
authority to take certain enforcement action, including suspending or 
withholding payments under a Federal program, if an LEA has failed to 
comply substantially with the Federal requirements applicable to that 
program. OST has confirmed that, consistent with this authority, at 
least eight SEAs made "process-based" determinations to decline to 
renew SIG grants for twelve schools in nine LEAs because the schools 
were not implementing their SIG interventions with fidelity to the SIG 
final requirements. 

OST maintains regular communication with States regarding renewal 
decisions through monthly check-in calls, reviews of SIG applications, 
and on-site and desk monitoring. SEAs were not yet making renewal 
decisions during the first monitoring cycle. However, OST is 
monitoring renewal decisions during the second monitoring cycle. OST 
will examine the criteria used by States that have declined to renew 
one or more SIG awards to determine whether such criteria were 
appropriate, and will provide additional guidance and/or technical 
assistance to all States based on those findings. Additionally, OST 
will update guidance to clarify that SEAs may terminate a grant if a 
district fails to comply with program requirements, even in the 
absence of data on annual goals, and provide guidance on using other 
data, such as data on SIG leading indicators, as part of renewal 
decisions. Finally, the requirement that fiscal year (FY) 201 I 
applicants provide a signed assurance that they will use the renewal 
process identified in the FY 2010 application to determine whether to 
renew an LEA's grant illustrates the importance of the renewal process. 

Recommendation #2: To ensure that contractors hired with SIG funding 
are accountable for their performance, we recommend the Secretary of 
Education require states to ensure that the performance of all SIG 
funded contractors, including those in turnaround and transformation 
schools, is reviewed during contract performance. 

For the reasons outlined below, we do not agree with this 
recommendation. This issue is already addressed appropriately and 
adequately through existing provisions and requirements, and we will 
continue to monitor these matters and provide further assistance when 
appropriate to drive continuous improvement. The Department requires 
that LEAs screen external providers to ensure their quality and has 
emphasized the importance of this screening process through guidance, 
a Dear Colleague Letter, and recurring technical assistance efforts. 
SEAs and LEAs are also required to monitor implementation of the SIG 
grants and school progress, which includes the performance of SIG 
contractors. The Department believes, however, that the type of 
evaluation process necessary for contractors paid with SIG funds 
depends on the contractors' role in supporting SIG models. For 
example, the Department has required that LEAs hold external providers 
under the restart model accountable for 'fleeting the SIG requirements 
because they are engaged in whole-school reform and have considerable 
flexibility with respect to the school improvement activities they 
will undertake. External providers supporting the implementation of a 
turnaround or transformation model may require less provider-specific 
monitoring, as they generally work on specific, discrete activities to 
improve student academic achievement. 

Further, under 34 C.F.R. § 80.36(a), when procuring services under a 
SIG grant, an LEA must follow the same policies and procedures it uses 
for procurements from non-Federal funds. As part of their policies and 
procedures for procurements from non-Federal funds, districts and 
States have their own requirements and practices for screening and 
evaluating external partners and for ensuring appropriate controls and 
accountability in this context. While we continue to review and 
monitor this area carefully, it is not always necessary to establish 
new Federal requirements on top of this type of State and local 
requirements. The Department does not believe it is necessary or 
appropriate to review State procurement laws as part of the SIG 
application process, but it is important for States and districts to 
follow these laws. OST will clarify through our guidance that States 
and districts are required, when using SIG funds, to follow their 
State and local procurement laws and evaluate external providers where 
required under those laws. 

Overall, we believe that in a number of aspects, the draft report 
presents an incomplete and somewhat misleading view of how well SIG is 
being implemented. It is important to note that the draft report 
examines the first year of a redesigned program that dramatically 
alters how States and districts intervene in their lowest-performing 
schools. While there is always room for some improvements in the early 
stages of implementation, and the Department is committed to 
continuous improvement in implementing its programs such as SIG, the 
draft report presents some information that should be modified and 
clarified, including the title of the report. As noted in the enclosed 
technical comments, we believe a more appropriate title would be 
"Education Should Provide Some Additional Guidance and Assistance to 
Further Improve School Improvement Grants Implementation by States,
Schools and Contractors." Please see the enclosure for a more detailed 
discussion of this issue and other suggested edits to the report. 

Thank you again for the opportunity to comment on the draft report. 
Please let us know if you have any questions or would like to discuss 
our comments and suggestions. We look forward to receiving the final 
report. 

Sincerely, 

Signed by: 

Michael Yudin: 
Acting Assistant Secretary for Elementary and Secondary Education: 

Enclosure: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

In addition to the contact named above, the following staff members 
made important contributions to this report: Elizabeth Sirois, 
Assistant Director; Scott Spicer, Analyst-in-Charge; Jacques 
Arsenault; Melissa King; Salvatore Sorbello; and Barbara Steel-Lowney. 
In addition, Jean McSween, James Rebbe, Tom James, William Woods, and 
Kathleen Van Gelder provided guidance on the study. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 111-5, 123 Stat. 115, 181. 

[2] 75 Fed. Reg. 66,363 (Oct. 28, 2010). 

[3] For more information, see GAO, School Improvement Grants: Early 
Implementation Under Way, but Reforms Affected by Short Time Frames, 
[hyperlink, http://www.gao.gov/products/GAO-11-741] (Washington, D.C., 
July 25, 2011). The six states were: Delaware, Nebraska, Nevada, Rhode 
Island, Ohio, and Virginia. 

[4] This report does not contain all the results from the survey. The 
survey and a more complete tabulation of the results are included in 
[hyperlink, http://www.gao.gov/products/GAO-12-370SP]. When discussing 
survey results in this report, the term "states" also includes the 
District of Columbia. See appendix I for more information about our 
survey design and implementation. 

[5] Title I, Part A of the Elementary and Secondary Education Act of 
1965, as amended, provides funding to school districts and schools 
with high concentrations of students from low-income families. Under 
Title I, states set academic targets and measure schools' progress in 
meeting them. Schools in improvement status have missed academic 
targets for at least two consecutive years. The definitions of Tier I 
and Tier II schools also include high schools that have a graduation 
rate of less than 60 percent over a number of years. 

[6] GAO, Contract Management: Opportunities to Improve Surveillance on 
Department of Defense Service Contracts, [hyperlink, 
http://www.gao.gov/products/GAO-05-274] (Washington, D.C.: Mar. 17, 
2005). 

[7] We refer to this as fidelity of implementation. Education's 
guidance does not further define the process or factors states should 
use when making this determination. 

[8] The seven states are Alabama, California, Hawaii, Missouri, Rhode 
Island, Tennessee, and Vermont. In addition, the Bureau of Indian 
Affairs was granted a waiver. 

[9] Under federal law, states are allowed to reserve not more than 5 
percent of SIG grant funds for administrative costs. 20 U.S.C. § 
6303(g)(8). 

[10] Race to the Top awards education reform grants to select states 
through a competitive grant process. Funding for the program was first 
authorized through the American Recovery and Reinvestment Act of 2009. 

[11] Using locally adopted competencies to measure the effectiveness 
of staff, schools implementing the turnaround model must screen all 
existing staff and rehire no more than 50 percent, and select new 
staff. 

[12] For each model, our survey asked whether all, most, around half, 
few, or none of the schools in a state were operating very differently 
after the first year of SIG implementation. Thirty-three states told 
us that some (most, around half, or few) transformation schools were 
operating very differently after the first year, while 13 states told 
us that all transformation schools were operating very differently and 
5 did not provide a response. For more information, about the extent 
to which schools were operating very differently after the first year 
of SIG and reasons cited by state officials, see our e-supplement 
[hyperlink, http://www.gao.gov/products/GAO-12-370SP]. 

[13] [hyperlink, http://www.gao.gov/products/GAO-11-741]. Both the 
turnaround model and the transformation model require school districts 
to provide increased learning time. Increased learning time is defined 
by Education's guidance as significantly increasing the total number 
of school hours to include: (1) instruction in core academic subjects; 
(2) instruction in other subjects and enrichment activities that 
contribute to a well-rounded education; and (3) teachers to 
collaborate, plan, and engage in professional development. The 
transformation model also requires school districts to use "rigorous, 
transparent, and equitable evaluation systems for teachers and 
principals that take into account data on student growth as a 
significant factor." 

[14] The remaining 15 respondents said that either it was as likely as 
unlikely that these costs would be sustainable; they did not know; the 
question was not applicable, or it was too early to tell. 

[15] Education officials told us they will review state renewal 
processes through monitoring starting in SY 2011-2012, but that their 
SY 2010-2011 monitoring took place prior to states making renewal 
decisions. 

[16] The Bureau of Indian Affairs also chose not to renew two schools. 

[17] GAO, Federal Contractors: Better Performance Information Needed 
to Support Agency Contract Award Decisions. [hyperlink, 
http://www.gao.gov/products/GAO-09-374], (Washington, D.C.: Apr. 23, 
2009). 

[18] For the purposes of this report, we define review during the 
course of contract performance as monitoring or quality assurance 
surveillance, as described in [hyperlink, 
http://www.gao.gov/products/GAO-05-274]. 

[19] Education's guidance requires that contractors implementing the 
restart model must be selected through a "rigorous review process," 
which permits a district to examine a prospective contractor's plans 
and strategies, and to ensure that the contractor has the capacity to 
implement its strategies. The guidance also requires districts to 
screen all other contractors for quality, stating that this screening 
serves a similar purpose as the rigorous review process used for 
restart contractors. 

[20] Education officials said they included this requirement for 
restart schools because their regulation requires districts to 
contract with external management organizations and that the 
contractors are selected through a rigorous review process. Education 
officials also said that they include review requirements for restart 
contractors because those contractors are an essential part of the 
restart model, and that they have more flexibility than the 
contractors used in a school implementing a different model. 

[21] According to Education officials, 17 states volunteered for this 
initiative, and the 9 states selected to participate were Alabama, 
Arizona, Arkansas, Connecticut, Louisiana, Michigan, Oklahoma, South 
Carolina, and Virginia. States that had received an Education SIG 
monitoring visit or were awarded a Race to the Top grant were not 
selected to participate. 

[22] Education officials also told us that nine of these states 
received technical assistance visits through the implementation 
initiative. 

[23] Education monitors how states receiving Title I grants implement 
and administer the Title I program to determine whether states comply 
with program requirements. 

[24] In SY 2010-2011, Education conducted monitoring site-visits to 
the following states: California, Indiana, Maine, Michigan, Minnesota, 
Mississippi, Montana, Nebraska, Nevada, Pennsylvania, South Dakota, 
and Tennessee. Education officials told us that they also conducted 
pilot monitoring site-visits in Maryland and New Mexico, but these 
visits were limited and used to test monitoring questions 

[25] Education required states to take corrective actions to address 
identified deficiencies. Education officials commented that states 
must submit evidence to prove that the identified deficiencies have 
been addressed. Education would then evaluate the strength of the 
evidence to determine if it adequately addressed the weakness. 
Education began issuing its monitoring reports in the spring of 2011 
and as of March 2012, seven states--Indiana, Maine, Michigan, 
Mississippi, Nevada, Pennsylvania, and South Dakota--had adequately 
addressed all of the weaknesses identified from their monitoring 
report. In addition, two states, Minnesota and Nebraska, have 
addressed some of the identified weaknesses, but still have other 
weaknesses to resolve. 

[26] For SY 2011-2012, Education initially planned to conduct 
monitoring site visits to the following 12 states: Florida, Georgia, 
Hawaii, Illinois, Iowa, Missouri, New Mexico, New York, Oregon, Rhode 
Island, Texas, and Wisconsin. 

[27] As of February 2012, Education had identified Idaho and Wyoming 
as states that would receive desk monitoring. Education has completed 
the desk monitoring for Idaho. 

[28] This includes Department of Education, Office of Inspector 
General, School Improvement Grants: Selected States Generally Awarded 
Funds Only to Eligible Schools, ED-OIG/A05L002 (Washington D.C., March 
2012). 

[29] [hyperlink, http://www.gao.gov/products/GAO-09-374]. 

[30] [hyperlink, http://www.gao.gov/products/GAO-05-274]. 

[End of section] 

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