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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

July 2014: 

Education of Homeless Students: 

Improved Program Oversight Needed: 

GAO-14-465: 

GAO Highlights: 

Highlights of GAO-14-465, a report to congressional requesters. 

Why GAO Did This Study: 

The McKinney-Vento Homeless Assistance Act established a grant program 
to help the nation's homeless students-—more than one million in 
school year 2011-12-—have access to public education. Under the 
Education for Homeless Children and Youth grant program, states and 
their school districts are required to identify homeless children and 
provide them with needed services and support. In fiscal year 2014, 
Education received about $65 million to administer this program. 
Education provided formula grants to states, which competitively 
awarded funds to school districts to help meet program requirements. 
GAO was asked to review program implementation and oversight. 

GAO examined (1) how districts identify and serve homeless students 
and challenges they face (2) how Education and states collaborate with 
other service providers to address student needs and any barriers, and 
(3) the extent to which Education monitors program compliance. GAO 
reviewed relevant federal laws, guidance, and reports, and analyzed 
Education's state and school district survey data from school year 
2010-11. GAO also interviewed federal officials, and state and local 
officials in 20 school districts-—representing a mix of urban, 
suburban, and rural districts and grant status-—in four states, 
selected for geographic diversity and other characteristics, such as 
experience with natural disasters. 

What GAO Found: 

To identify and serve homeless students under the Education for 
Homeless Children and Youth (EHCY) program, officials in the 20 school 
districts where GAO conducted interviews reported conducting a range 
of activities to support homeless youth, but cited several challenges. 
With regard to GAO's interviews, 13 of the 20 districts identified 
homeless students through housing surveys at enrollment, while all 20 
relied on referrals from schools or service providers. However, 
officials in 8 of the 20 districts noted that the under-identification 
of homeless students was a problem. Districts GAO reviewed provided 
eligible students with transportation to and from school, educational 
services, and referrals to other service providers for support such as 
health care or food assistance. Among the challenges that officials in 
the 20 districts cited were limited staff and resources to provide 
services, the cost of transportation, student stigma associated with 
homelessness, and responding to students made homeless by natural 
disasters. Nationally, school districts surveyed most recently in 
school year 2010-11 by the Department of Education (Education) 
reported providing many services while facing similar challenges. 

Education's EHCY program manager and state program coordinators have 
collaborated with other government agencies and with private 
organizations by sharing information, participating in interagency 
councils on homelessness, and providing technical assistance to 
relevant staff. In addition, state EHCY program coordinators have 
provided training to school districts and helped connect local 
programs to ensure homeless students receive various services. 
However, federal and state officials frequently cited limited 
resources and differing federal definitions of homelessness as 
constraints to greater collaboration. 

Education has protocols for monitoring state EHCY programs, but no 
plan to ensure adequate oversight of all states, though monitoring is 
a key management tool for assessing the quality of performance over 
time and resolving problems promptly. Prior to fiscal year 2010, it 
had been Education's policy to monitor 50 states and 3 area programs 
at least once during a 3-year period, and it did so for fiscal years 
2007 to 2009. Subsequently, the department adopted a risk-based 
approach in fiscal year 2010 and monitored 28 states over the next 3 
years. In fiscal year 2013, Education again changed its approach to 
EHCY program monitoring and has monitored 3 state programs since then. 
Department officials cited other priorities and a lack of staff 
capacity as reasons for the decrease in oversight. As a result, 
Education lacks assurance that states are complying with program 
requirements. GAO found gaps in state monitoring of districts that 
could weaken program performance, reinforcing the importance of 
effective federal monitoring of states. 

Figure: Declining Frequency of Federal Monitoring for EHCY Compliance 
since Fiscal Year 2007: 

[Refer to PDF for image: horizontal bar graph] 

Number of states: 

2007-2009: 
Not monitored: 0; 
Monitored: 53. 

2010-2012: 
Not monitored: 25; 
Monitored: 28. 

2013-2014: 
Not monitored: 50; 
Monitored: 3. 

Source: GAO analysis of Department of Education documents. GAO-14-465. 

[End of figure] 

What GAO Recommends: 

GAO recommends that Education develop a plan to ensure adequate 
oversight of the EHCY program. Education concurred with our 
recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-14-465]. For more 
information, contact Kay Brown at (202) 512-7215 or brownke@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Selected School Districts Leveraged Existing Resources to Identify and 
Serve Homeless Students, but Faced Resource Limitations and Other 
Challenges: 

Federal and State Agencies Use Numerous Strategies to Collaborate to 
Improve Services to Homeless Students despite Barriers: 

Education Currently Lacks a Comprehensive Oversight Plan and Faces 
Limitations in Using its Performance Data to Assess Program Results: 

Conclusions: 

Recommendation for Agency Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Education for Homeless Children and Youth Program 
Monitoring Indicators: 

Appendix III: Comments from the Department of Education: 

Appendix IV: Comments from the U.S. Interagency Council on 
Homelessness: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Examples of Federal Programs that May Also Serve Homeless 
Children and Youth: 

Table 2: Selected Examples of Federal Education for Homeless Children 
and Youth (EHCY) Program Collaboration Activities within the 
Department of Education, with Other Federal Agencies, and with States: 

Table 3: Number of States Using Various Approaches to Monitor 
Districts, School Year 2010-11: 

Table 4: Required Data Elements from Grantee and Non-grantee School 
Districts: 

Figures: 

Figure 1: Excerpt of Possible Housing Situations from an Example of an 
Education for Homeless Children and Youth Eligibility Determination 
Form: 

Figure 2: Examples of Referral Sources for Homeless Students: 

Figure 3: Percent of Homeless Students Enrolled Nationwide by Primary 
Nighttime Residence, School Year 2011-12: 

Figure 4: Most Common Services Grantee School Districts Reported 
Providing to Homeless Children and Youth, School Year 2010-11: 

Figure 5: Time Spent on Collaboration and Top Collaboration 
Activities, Reported by State Education for Homeless Children and 
Youth (EHCY) Program Coordinators for School Year 2010-11: 

Figure 6: Examples of State Education for Homeless Children and Youth 
Program Collaboration Activities: 

Figure 7: Hours Worked by State Education for Homeless Children and 
Youth (EHCY) Program Coordinators and Number of Paid Staff in State 
EHCY Program Offices for School Year 2010-11: 

Figure 8: Overview of Education's Monitoring Process for the Education 
for Homeless Children and Youth Program: 

Figure 9: Frequency of Federal Monitoring for Education for Homeless 
Children and Youth (EHCY) Program Compliance since Fiscal Year 2007: 

Figure 10: Frequency of State Monitoring of Grantee and Non-grantee 
Districts, by Number of States, School Year 2010-11: 

Abbreviations: 

21st CCLC: 21st Century Community Learning Centers: 

CoC: Continuum of Care: 

Education: Department of Education: 

EHCY: Education for Homeless Children and Youth: 

ESEA: Elementary and Secondary Education Act of 1965, as amended: 

HHS: Department of Health and Human Services: 

HUD: Department of Housing and Urban Development: 

LEA: Local Educational Agency: 

LGBTQ: Lesbian, Gay, Bisexual, Transgender, or Questioning: 

MEP: Migrant Education Program: 

NAEHCY: National Association for the Education of Homeless Children 
and Youth: 

NCHE: National Center for Homeless Education: 

RHY: Runaway and Homeless Youth programs: 

SASA: Student Achievement and School Accountability: 

SEA: State Educational Agency: 

USICH: United States Interagency Council on Homelessness: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

July 31, 2014: 

The Honorable Tom Harkin: 
Chairman: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable Patty Murray: 
United States Senate: 

In school year 2011-12, more than 1.1 million children and youth 
enrolled in our nation's public schools were identified as homeless, 
according to data from the U.S. Department of Education (Education). 
[Footnote 1] Homeless children and youth may face a variety of 
barriers to continuing their education, including frequent moves, a 
lack of transportation to and from school, and a lack of adequate 
supplies and services, such as counseling, that may be necessary to 
help them remain in school. Research on homeless and highly mobile 
children suggests that they face challenges with academic achievement 
and school completion. We previously reported that students who change 
schools more frequently tend to have lower scores on standardized 
reading and math tests and drop out of school at higher rates than 
their less mobile peers.[Footnote 2] In addition, according to a study 
of an urban school district from school years 2005-06 to 2009-10, 
homeless and highly mobile children were more likely to exhibit lower 
levels of academic achievement compared with other students.[Footnote 
3] 

The Education for Homeless Children and Youth (EHCY) program, 
initially authorized by Title VII-B of the McKinney-Vento Homeless 
Assistance Act (McKinney-Vento Act), helps address barriers to school 
enrollment, attendance, and success for homeless children and youth. 
[Footnote 4] The act requires state educational agencies to ensure 
that homeless children and youth have equal access to the same free 
appropriate public education, including a public preschool education, 
as provided to other children. Congress appropriated about $65 million 
to carry out the EHCY program in fiscal year 2014.[Footnote 5] The 
McKinney-Vento Act authorizes Education to provide federal grants to 
states to administer and oversee activities under the EHCY program. 
[Footnote 6] In turn, states award a majority of these funds on a 
competitive basis to select school districts in their state (grantee 
districts), based on factors such as the needs of homeless children 
and youth within a particular district and the ability of the district 
to meet those needs.[Footnote 7] Regardless of whether a school 
district receives EHCY program funds, all districts must comply with 
certain program requirements, which include ensuring that homeless 
children and youth are appropriately identified, immediately enrolled 
in school, and receive the educational and other services for which 
they are eligible, such as transportation to and from school. In 
addition, as GAO has reported in the past, collaboration presents an 
opportunity to increase the efficiency and effectiveness of federal 
programs.[Footnote 8] Because no one system of services can meet every 
need of students experiencing homelessness, and funding for the EHCY 
program is set at relatively modest levels, collaboration at the 
federal, state, and local levels is essential to address the academic 
and non-academic needs of homeless students. The McKinney-Vento Act 
requires states and school districts to coordinate and collaborate 
with other programs and service providers that also serve these 
children and youth. In light of the issues facing homeless students, 
you asked us to examine the implementation and oversight of the EHCY 
program. 

This report addresses (1) how school districts identify and serve 
homeless students and the challenges in doing so, (2) how Education 
and states collaborate with other agencies and service providers to 
address the needs of homeless students and barriers to collaboration, 
and (3) the extent to which Education monitors compliance with the 
EHCY program requirements and how Education assesses program results. 

To gather information on how the EHCY program is implemented at the 
local level, we visited three states--Colorado, New Jersey, and 
Washington--and interviewed officials in Texas by phone.[Footnote 9] 
We selected states that represent geographic diversity and based on 
the recommendations of experts, including the National Association for 
the Education of Homeless Children and Youth (NAEHCY)[Footnote 10] and 
other national organizations working on issues related to 
homelessness, to obtain a mix of states implementing promising 
practices in their EHCY programs as well as experiencing challenges. 
In addition, we sought variation in the number of homeless students 
states identified in recent years and the size of states' EHCY grants, 
among other factors. We also selected two states that have recently 
experienced natural disasters to see how they coped with sudden 
increases in the number of homeless students. In each state, we 
interviewed state and school district officials. In total, we spoke 
with school district officials from 20 different school districts, 
nine of which were grantee districts. We selected these districts with 
the assistance of state EHCY program coordinators to represent a mix 
of urban, suburban, and rural districts, as well as grantee and non-
grantee districts. In the states we visited, we also met with school 
officials and youth or their families who have experienced 
homelessness. Information obtained from these states and school 
districts is non-generalizable. To obtain generalizable and national-
level information on states and grantee school districts, we analyzed 
Education data from two surveys covering school year 2010-11, which we 
found to be sufficiently reliable.[Footnote 11] We assessed the 
reliability of the survey data by performing electronic testing of the 
data elements, reviewing relevant documentation, and interviewing 
agency officials knowledgeable about the data. We used the survey data 
to examine how states and school districts implement the EHCY program 
and how states monitor school districts, among other things. All 
estimates obtained from the school district-level survey have margins 
of error of no greater than six percentage points. To obtain 
information on how Education administers the EHCY program and 
collaborates with other agencies, we interviewed Education officials 
and officials from other federal agencies, including the Departments 
of Health and Human Services (HHS) and Housing and Urban Development 
(HUD), as well as the U.S. Interagency Council on Homelessness 
(USICH). We also reviewed relevant documents--including federal laws 
and regulations, monitoring protocols, and policy memos--and examined 
Education's findings on the EHCY program from state monitoring 
reports. See appendix I for additional information on our scope and 
methodology. 

We conducted this performance audit from July 2012 through July 2014 
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: 

The Education for Homeless Children and Youth Program: 

The EHCY program is the key federal education program targeted to 
homeless children and youth, and, in school year 2011-12, more than 
1.1 million were enrolled in our nation's public schools,[Footnote 12] 
according to Education data.[Footnote 13] For purposes of the program, 
a homeless child or youth is one who lacks a fixed, regular, and 
adequate nighttime residence. This includes children who: 

* are sharing the housing of others due to loss of housing, economic 
hardship, or a similar reason (commonly referred to as "doubled-up"); 

* are living in motels, hotels, trailer parks, or camping grounds due 
to the lack of alternative adequate accommodations; 

* are living in emergency or transitional shelters; are abandoned in 
hospitals; or are awaiting foster care placement; 

* have a primary nighttime residence that is a public or private place 
not designed for or ordinarily used as a regular sleeping 
accommodation for human beings; 

* are living in cars, parks, public spaces, abandoned buildings, 
substandard housing, bus or train stations, or similar settings; and: 

* are migratory children who qualify as homeless due to their living 
circumstances, as described above.[Footnote 14] 

Education's Office of Student Achievement and School Accountability 
(SASA)--within the Office of Elementary and Secondary Education--
provides EHCY formula grants to states, which must comply with certain 
requirements.[Footnote 15] For example, the McKinney-Vento Act 
requires each state that receives funds to establish an Office of 
Coordinator for Education of Homeless Children and Youths, with 
responsibilities that include carrying out the state plan.[Footnote 
16] The state plan describes, among other things, procedures that will 
be used to identify homeless children and youth, strategies to address 
challenges, such as enrollment delays, and a demonstration of the 
state's efforts to review and revise policies to remove barriers to 
the enrollment and retention of homeless children and youth. Among 
other responsibilities, state educational agencies report data to 
Education on the educational needs of their homeless students; provide 
technical assistance to school districts and monitor their compliance 
with the program; and facilitate collaboration between the state and 
other service providers that serve homeless children and youth and 
their families. 

States are generally required to award no less than 75 percent of 
their grant to school districts on a competitive basis.[Footnote 17] 
Grants to school districts, awarded for a period of up to 3 years, are 
to be used for activities that facilitate the enrollment, attendance, 
and success of homeless children and youth in school. Grants to 
districts are to be awarded based on the need of the school district 
for assistance and the quality of the application submitted.[Footnote 
18] In determining which districts to fund, states are required to 
consider certain factors, such as the needs of homeless children and 
youth enrolled in the school district, the types of services to be 
provided under the program, and the extent to which the services will 
be coordinated with other services available to homeless children and 
youth. Districts are authorized to use these funds to support a range 
of activities for homeless students, such as tutoring, transportation, 
and referrals to health care services, as well as to provide 
professional development for educators and support coordination 
between schools and other agencies.[Footnote 19] According to 
Education data, in school year 2011-12, fewer than a quarter of school 
districts nationwide (3,531 out of 16,064) received EHCY program 
funds; these districts enrolled 68 percent of the homeless students 
identified that year.[Footnote 20] 

Education also allows states to use a regional approach to award their 
competitive grants. Through such an approach, according to the 
National Center for Homeless Education (NCHE), [Footnote 21] a state 
may provide funds to established regional educational entities, 
geographic clusters of school districts defined by the state, clusters 
self-selected by neighboring school districts, or some combination of 
these approaches. According to Education's survey of states in school 
year 2010-11, the most recent survey data available, 16 states 
reported that they provided funds through an intermediate educational 
agency or consortia. 

Regardless of whether a school district receives EHCY program funds, 
all school districts are required to comply with certain requirements 
of the McKinney-Vento Act, including designating a homeless liaison to 
ensure that homeless children and youth are appropriately identified 
and provided the educational services for which they are eligible, 
among other things.[Footnote 22] Under the McKinney-Vento Act, 
homeless children and youth have certain rights, including the right 
to: 

* remain in their school of origin, if in their best interest; 
[Footnote 23] 

* immediately enroll in the selected school, even without the records, 
such as proof of residency, typically required;[Footnote 24] and: 

* receive services comparable to those offered to other students for 
which they are eligible, such as transportation, educational services, 
and free school meals.[Footnote 25] 

Other Federal Programs that May Also Support Homeless Children and 
Youth: 

Other programs administered by Education and other federal agencies, 
many of which receive more federal funding than the EHCY program, may 
also support the needs of homeless children and youth (see table 1 for 
selected examples). For example, under Title I, Part A of the 
Elementary and Secondary Education Act of 1965, as amended (ESEA), 
school districts are required to set aside funds as necessary to 
provide comparable services for homeless students who do not attend 
Title I schools.[Footnote 26] In addition, grantee school districts 
are required to coordinate with other organizations serving homeless 
children and youth, including those operating programs funded under 
the Runaway and Homeless Youth Act.[Footnote 27] The populations 
served by these programs vary, and for some programs, eligibility for 
services does not depend on being homeless. Among the programs that do 
target homeless populations, some use definitions of homelessness that 
are different from the one used by the EHCY program.[Footnote 28] 

Table 1: Examples of Federal Programs that May Also Serve Homeless 
Children and Youth: 

Federal Agency: Education; 
Program: Improving Basic Programs Operated by Local Educational 
Agencies (Title I, Part A of the Elementary and Secondary Education 
Act); 
Description: Provides financial assistance to school districts and 
schools with high concentrations of children from low-income families 
to help ensure that all children meet challenging state academic 
standards; 
Funding for fiscal year 2014: $14.385 billion. 

Federal Agency: Education; 
Program: Individuals with Disabilities Education Act, Parts B and C; 
Description: Part B supports special education and related services 
for children with disabilities aged 3-21 and Part C supports early 
intervention services for children younger than 3 years of age; 
Funding for fiscal year 2014: $12.265 billion. 

Federal Agency: Education; 
Program: Migrant Education Program; 
Description: Aims to ensure that migratory children are provided with 
appropriate education services that address their special needs and 
receive full and appropriate opportunities to meet the same challenging 
state academic content and student academic achievement standards that 
all children are expected to meet, among other purposes; 
Funding for fiscal year 2014: $374.8 million. 

Federal Agency: Education; 
Program: 21st Century Community Learning Centers; 
Description: Supports the creation of community learning centers that 
provide academic enrichment opportunities during non-school hours for 
children, particularly students who attend high-poverty and low-
performing schools; 
Funding for fiscal year 2014: $1.149 billion. 

Federal Agency: HHS; 
Program: Head Start; 
Description: Serves preschool-age children and their families and 
promotes the school readiness of children from birth to age 5 from low-
income families by enhancing their cognitive, social, and emotional 
development[A]; 
Funding for fiscal year 2014: $8.598 billion 

Federal Agency: HHS; 
Program: Runaway and Homeless Youth; 
Description: Supports temporary emergency shelter, transitional 
housing, street outreach services, and maternity group home programs 
to serve and protect runaway and homeless youth; 
Funding for fiscal year 2014: $114.1 million. 

Federal Agency: HUD; 
Program: Homeless Assistance Programs (including Emergency Solutions 
Grants and Continuum of Care Program); 
Description: Provide emergency shelter, supportive services, 
transitional housing, permanent housing, and prevention resources to 
assist individuals in shelters or on the streets attain permanent 
housing and self-sufficiency; 
Funding for fiscal year 2014: $2.105 billion. 

Source: Education, HHS, and HUD agency program descriptions and budget 
documents for fiscal year 2015, reporting appropriated amounts for 
fiscal year 2014. GAO-14-465. 

Note: This table is not intended to be exhaustive; other programs may 
also serve homeless children and youth that are not described here. 

[A] Homeless children are automatically eligible for the Head Start 
program. 

[End of table] 

The McKinney-Vento Act also created the U.S. Interagency Council on 
Homelessness (USICH), which currently consists of 19 federal cabinet 
secretaries and agency heads.[Footnote 29] The Homeless Emergency 
Assistance and Rapid Transition to Housing (HEARTH) Act of 2009 
established as the mission of USICH to coordinate the federal response 
to homelessness and create a national partnership at every level of 
government and with the private sector to reduce and end homelessness. 
[Footnote 30] 

Selected School Districts Leveraged Existing Resources to Identify and 
Serve Homeless Students, but Faced Resource Limitations and Other 
Challenges: 

Selected School Districts Largely Relied on Enrollment Forms and 
Referrals to Identify Homeless Students, but Faced Challenges and 
Noted Problems with Under-Identification: 

To identify homeless students, officials in a majority of school 
districts (13 of 20) said their districts systematically requested 
some information on the housing status of new students using a form 
during the enrollment process.[Footnote 31] Two of these districts 
also requested housing information from every student every year to 
help identify eligible students whose housing circumstances may have 
changed following enrollment. According to the National Center for 
Homeless Education (NCHE), using a questionnaire at enrollment can 
help school districts increase their identification of homeless 
students (see figure 1). 

Figure 1: Excerpt of Possible Housing Situations from an Example of an 
Education for Homeless Children and Youth Eligibility Determination 
Form: 

[Refer to PDF for image: form excerpt] 

Please choose which of the following situations the student currently 
resides in (you can choose more than one): 

House or apartment with parent or guardian; 
Motel, car, or campsite; 
Shelter or other temporary housing; 
With friends or family members (other than or in addition to 
parent/guardian). 

If you are living in shared housing, please check all of the following 
reasons that apply: 
Loss of housing; 
Economic situation; 
Temporarily waiting for house or apartment; 
Provide care for a family member; 
Living with boyfriend/girlfriend; 
Loss of employment; 
Parent/Guardian is deployed; 
Other (Please explain). 
Are you a student under the age of 18 and living apart from your 
parents or guardians? Yes/No. 

Source: National Center for Homeless Education. GAO-14-465. 

[End of figure] 

To identify students who were not identified at enrollment or whose 
housing status changed during the year, homeless liaisons in the 20 
school districts we interviewed also relied on referrals from school 
staff or other service providers (see figure 2).[Footnote 32] 

Figure 2: Examples of Referral Sources for Homeless Students: 

[Refer to PDF for image: illustration] 

Homeless liaison: 

School-based referrals: (enrollment staff, school secretaries, 
teachers, counselors, other programs in the districtsuch as special 
education programs, the Migrant Education Program, or nutrition 
programs). 

Homeless shelters. 

Self-referrals from students or word of mouth. 

Other service providers: (e.g., crisis centers, etc.). 

Source: GAO analysis of interviews with district officials. GAO-14-465. 

[End of figure] 

Officials said they provided information and training to a variety of 
staff in contact with students to help them recognize potential signs 
of homelessness, such as: 

* students who provide home addresses of shelters or other students; 

* students who request transportation changes; 

* students with attendance problems or who are tardy; 

* students who fall asleep in class; and: 

* students with dropping grades, hunger, or hygiene issues. 

Officials we interviewed also discussed the importance of training 
staff to identify homeless students, as identifying currently enrolled 
students is less systematic than identifying new students at 
enrollment. 

Despite ongoing efforts to identify homeless students through housing 
surveys and referrals, officials in 8 out of the 20 districts we 
interviewed noted a problem with the under-identification of homeless 
students. All four state EHCY program coordinators we interviewed 
acknowledged that school districts face financial disincentives to 
identifying homeless children and youth due to the cost of services 
districts must provide. Officials from both grantee and non-grantee 
districts[Footnote 33] reported facing significant challenges in 
identifying all eligible students.[Footnote 34] 

Student Mobility: 

Officials in 11 of the 20 districts we interviewed said they 
identified increasing numbers of homeless children and youth in recent 
years, and many noted the frequent mobility of some students, making 
it challenging for school staff to keep track of their homeless 
students. 

Confusion Regarding Applying Eligibility Requirements: 

Officials in 4 of the 20 districts said it was challenging to identify 
children and youth living doubled-up with others, particularly where 
living with extended family may be a cultural norm. In such cases, 
families may not consider themselves to be homeless or may be unaware 
of their rights to receive services under the program. For example, 
officials in one district told us that many of the district's 
immigrant families who work for a local meat processor live with 
relatives in doubled-up conditions but do not consider themselves 
homeless. To help clarify program eligibility, one district we 
reviewed used its enrollment form to ask parents or guardians to check 
a box when they are "living 'doubled-up' due to economic emergency, 
not to save money or for cultural preference." 

Limited Information from Housing Surveys: 

In one school district we reviewed, the enrollment form asks parents 
or guardians to check a box "if the student is homeless or living in 
temporary/transitional housing," and asks whether the student is an 
"unaccompanied youth," but does not describe eligible housing 
situations. As a result, a student who is living doubled-up due to 
economic circumstances may not be identified, even though this 
situation represents a majority of homeless students nationwide (see 
figure 3). 

Figure 3: Percent of Homeless Students Enrolled Nationwide by Primary 
Nighttime Residence, School Year 2011-12: 

[Refer to PDF for image: horizontal bar graph] 

Doubled-up: 75%; 
Shelters: 15%; 
Hotels/motels: 6%; 
Unsheltered: 4%. 

Source: Department of Education. GAO-14-465. 

[End of figure] 

Limited Staff Availability for Training and Outreach: 

Nationally, according to Education's survey of grantee school 
districts in school year 2010-11, homeless liaisons spent a median 
amount of nearly 2 hours per week on their responsibilities for the 
EHCY program.[Footnote 35] Many liaisons said that they juggled 
multiple responsibilities, including duties outside of the EHCY 
program. Officials in 7 of the 20 districts cited their limited 
availability to provide training and outreach or the lack of 
sufficiently trained school personnel as a challenge to identifying 
eligible students. In one state we visited the state EHCY program 
coordinator who surveyed homeless liaisons on the amount of time they 
spent on the EHCY program said she has found a link between the amount 
of time liaisons spend on the EHCY program and the number of homeless 
students they have identified. 

Confusion Regarding Terminology: 

One liaison said there is confusion around "awaiting foster care 
placement," a term used to describe some children and youth eligible 
for the EHCY program. Specifically, the liaison told us that she would 
receive requests for services for children in foster care, rather than 
for children awaiting foster care placement.[Footnote 36] In another 
district, a liaison said that among the district's many military 
families, the term "transition," sometimes used to describe eligible 
families, has a meaning unrelated to homelessness. 

Stigma: 

Officials in 7 of the 20 districts said that stigma around being 
identified as homeless makes it challenging to identify eligible 
children and youth. One formerly homeless student we interviewed 
described her initial identification as very traumatic because she did 
not want anyone at school to know about her housing status and did not 
want to be called homeless. She said she would rather have received 
bad grades in high school than have her teachers know of her 
situation. Another said that she did not want anyone to know she was 
homeless but found it difficult to hide when she had to resort to 
"couch-surfing" in the homes of many different people. 

Identification of Homeless LGBTQ Youth: 

Some officials we spoke with suggested the districts under-identify 
unaccompanied homeless youth,[Footnote 37] including lesbian, gay, 
bisexual, transgender, or questioning (LGBTQ) youth who tend to be 
overrepresented in the homeless youth population.[Footnote 38] 
Officials in five districts told us they are involved in efforts 
targeted to LGBTQ youth. For example, an official in one of these 
districts said the district has been involved in focus groups and 
worked with service providers on how to better identify and serve 
these youth who may have separated from their families due to their 
LGBTQ identification. 

Fear of Government: 

Officials in 5 of 20 districts told us that some families fear being 
known to government entities, such as child protective services, 
police, and immigration services. For example, officials in one 
district said parents may be afraid that the child protective services 
agency will remove their children from their custody if they are 
discovered to be homeless. 

Natural Disasters: 

Natural disasters, including floods and a hurricane that forced many 
families from their homes, also presented challenges for some 
districts we reviewed. To identify the large numbers of students 
displaced simultaneously in these districts, officials working in four 
of five districts we interviewed about their experiences with natural 
disasters relied heavily on staff and outside resources (e.g., 
shelters and community meetings).[Footnote 39] However, officials said 
that factors such as families' unwillingness to self-identify and 
frequent mobility following the disaster created challenges to 
identifying and serving students. For example, officials in a district 
affected by heavy flooding said that immediately following the 
flooding, families moved in with relatives or other families and did 
not necessarily consider themselves to be homeless. However, as time 
passed, the district had to identify families in another wave as 
families again were displaced from where they initially had moved. 

Under-identification can negatively affect homeless students' ability 
to access needed services and to succeed in school. For example, 
according to a formerly homeless youth we interviewed, prior to being 
identified as homeless during his final year of school, he had been 
receiving Fs on his report card. After being identified, he received a 
bus pass, school supplies, and a laptop--necessary supplies to help 
him graduate. Although he faced significant pressures outside of 
school, according to a school official, and challenges completing his 
schoolwork, he graduated and was able to obtain employment. Another 
unaccompanied homeless youth said that after he was identified as 
homeless he received assistance with school work and clothing for an 
internship, and was very happy to be able to stay at the same high 
school. Some officials we interviewed noted that children and youth 
not connected to school or other services can be particularly 
challenging to identify, leaving them most at risk of failing to 
receive necessary services. 

Selected School Districts Leveraged Resources to Serve Homeless 
Students, but Faced Resource and Coordination Challenges: 

Students experiencing homelessness have diverse needs, ranging from 
school-related to more basic needs. Nationally, grantee school 
districts in school year 2010-11 most frequently reported 
transportation to and from school, family or student preoccupation 
with survival needs, and frequent mobility from school to school as 
among homeless students' greatest barriers to school enrollment, 
attendance, and success, respectively, according to Education's survey 
of these school districts.[Footnote 40] Some officials we interviewed 
cited similar barriers. For example, a high school principal said that 
the most pressing need for homeless students in his school is for a 
safe place to sleep, and students who are worried about where they 
will sleep at night will not be focused on their studies. Some of the 
homeless youth we spoke with also indicated that stable housing or 
food were among their significant needs. Specifically, one 
unaccompanied homeless youth we interviewed--who has lived with a 
series of family members since leaving her mother's home--said that 
while she currently sleeps on the couch in her uncle's house, she 
worries every day about her next move as she does not know how long 
she will be allowed to stay. 

To help address the needs of homeless students, grantee school 
districts in school year 2010-11 reported providing a variety of 
services, according to Education's survey (see figure 4). 

Figure 4: Most Common Services Grantee School Districts Reported 
Providing to Homeless Children and Youth, School Year 2010-11: 

[Refer to PDF for image: horizontal bar graph] 

Service: School supplies; 
Estimated percent of grantee school districts: 91%. 

Service: Coordination between schools and agencies that provide 
services to homeless children and youth; 
Estimated percent of grantee school districts: 78%. 

Service: Tutoring or supplemental instruction; 
Estimated percent of grantee school districts: 76%. 

Service: Referrals for medical, dental, and other health services; 
Estimated percent of grantee school districts: 75%. 

Service: Obtaining or transferring records necessary for student 
enrollment in school; 
Estimated percent of grantee school districts: 74%. 

Service: Defraying the cost of transportation for homeless children 
and youth that is not fully funded by federal, state, or local funds; 
Estimated percent of grantee school districts: 65%. 

Service: Counseling for homeless children and youth; 
Estimated percent of grantee school districts: 63%. 

Service: District staff training and awareness-building about the 
needs of homeless children and youth; 
Estimated percent of grantee school districts: 61%. 

Service: Parent education related to rights and resources for homeless 
children and youth; 
Estimated percent of grantee school districts: 55%. 

Service: School staff training and awareness-building about the needs 
of homeless children and youth; 
Estimated percent of grantee school districts: 53%. 

Source: GAO analysis of Department of Education survey of grantee 
school districts. GAO-14-465. 

Notes: The figure depicts services that an estimated 50 percent of 
grantee districts or more reported providing. All estimates in this 
figure have margins of error of less than six percentage points. 

[End of figure] 

Similarly, the school districts we reviewed provided a range of 
services and supports to address the various needs of homeless 
students, which presented some challenges. These include 
transportation, coordination with other educational services, and 
partnering with community organizations: 

Transportation: 

Officials we interviewed said their districts provided eligible 
students with transportation to and from school, as required by the 
McKinney-Vento Act, through means such as public transit, district 
buses, taxi cabs, gas assistance and mileage reimbursements.[Footnote 
41] Officials in 9 of the 20 districts also said they collaborated 
with neighboring districts to transport homeless students across 
district boundaries, such as by splitting transportation costs or 
dividing responsibility for routes to and from school. 

However, district officials also reported challenges providing 
transportation due to cost and logistics. Nationally, according to 
Education's survey of grantee districts in school year 2010-11, an 
estimated 52 percent of them ranked defraying the cost of 
transportation among the services on which they spent the most EHCY 
funds[Footnote 42] and about one-third of districts (37 percent) 
reported that coordinating transportation services was among their 
responsibilities that took the most time. Officials in 7 of the 20 
districts we interviewed reported similar challenges. For example, one 
homeless liaison said that in school year 2011-12 the district spent 
$550,000 on cabs to transport homeless students.[Footnote 43] 
Officials in another district told us of a student who spent 4 hours 
per day commuting to and from the child's school of origin--the school 
that the family had requested.[Footnote 44] While district officials 
did not think this was in the best interest of the child, officials 
said they did not think they could refuse to provide transportation 
due to the distance.[Footnote 45] Some district officials we spoke 
with also said coordinating transportation across districts can be 
difficult. For example, billing and being billed by other districts 
can be inefficient and problematic. A district transportation official 
we interviewed noted the significant amount of administrative work it 
takes to arrange a student's transportation. For example, she said she 
could spend an entire day trying to figure out how to free up a bus 
driver to transport one homeless student to and from school when she 
also needs to worry about the transportation of another 500 students. 

Coordinating Educational Services: 

Officials in the districts we interviewed coordinated with other 
education programs and districts to help address homeless students' 
needs. For example, some districts used ESEA Title I, Part A funds to 
provide students with tutoring, uniforms, and funds for class fees, as 
well as hygiene kits, clothing and laundry vouchers, among other 
things.[Footnote 46] Officials in 7 of the 20 districts said these 
funds also supported salaries for positions that support homeless 
students, such as EHCY program staff, social workers and homeless 
student advocates. In addition, officials in some districts said they 
have coordinated with staff from special education programs to help 
facilitate services for homeless students; migrant education programs 
to help identify homeless migrant children; and in some instances, 
preschool programs to serve homeless preschool-aged children. 
Officials in 5 of the 20 districts said their preschool programs 
reserved spaces for homeless preschool-aged children or prioritized 
these students for services,[Footnote 47] and in four of these 
districts, officials said the district transported homeless 
preschoolers to and from school.[Footnote 48] Some officials also 
described coordinating with other districts. For example, officials in 
three districts said they coordinated with other districts to help 
homeless students obtain partial credit for work completed elsewhere 
but said that such efforts could be challenging. In one extraordinary 
case, we spoke with an official who said he worked for months to 
obtain a student's transcript from an African refugee camp to be able 
to eventually verify the student had received 33 credits, exceeding 
the 22 necessary to graduate. According to a formerly homeless youth 
we interviewed, receiving credit for work completed was very important 
to help her meet graduation requirements as she moved across the 
country twice during high school and attended a total of four high 
schools. 

Officials in 11 of the 20 districts we interviewed cited challenges 
due to limited staff availability or resources with which to serve 
homeless students and adequately address their needs. For example, a 
school principal in a K-8 school we visited without full-time 
counselors or support staff said homeless students there have access 
to about 30 percent of the support services the school would like to 
offer them. In another high school we visited, officials said there is 
a severe lack of resources at the school to support homeless students. 
Specifically, according to officials, teachers currently fund a "food 
closet" on nearly every floor of the high school to meet the needs of 
hungry students. 

Partnering with Community Organizations: 

To expand their ability to serve homeless students' needs, district 
and school officials also leveraged community resources to provide 
students with access to additional services and supports. For example, 
some officials we interviewed said that they referred homeless 
students or their families to organizations and agencies that provide 
health and mental health services, as well as to other community 
organizations, such as food pantries and shelters for students' 
pressing needs.[Footnote 49] Officials in 6 of the 20 districts 
reported they assisted homeless youth in accessing public benefits, 
such as for health care or food. Officials in some districts also said 
they referred students to other federal programs, such as Head Start 
and Runaway and Homeless Youth (RHY) programs, and housing programs 
for services.[Footnote 50] In one district we visited officials said 
they improved referrals for services by developing trainings for an 
interagency committee comprised of various community stakeholders on 
resources and services available to homeless students. However, 
officials said that a lack of community resources affected their 
ability to meet student needs. For example, officials in a number of 
school districts we interviewed (9 of 20) said the lack of available 
or affordable housing options made it challenging to address the needs 
of homeless children and their families. 

School districts also played an important role in addressing the needs 
of students displaced by natural disasters and maintaining their 
school stability. For example, in the immediate aftermath, officials 
we interviewed in one of five districts about their experiences with 
natural disasters said three schools were used as emergency shelters 
for families. Officials in four districts said they received a great 
deal of community support through donations--such as mattresses, 
heaters, food, clothing and supplies--to help address the significant 
needs of displaced students and families. However, officials also 
reported challenges in serving large numbers of newly identified 
homeless students, sometimes without additional funds for services. 
For example, one district without EHCY grant funds spent $750,000 to 
transport displaced students to and from school and to pay tuition to 
other districts where some students began attending school, according 
to officials. Maintaining contact with families through their moves 
was also a challenge for some officials we interviewed. In one 
district, officials said they were unaware of the number of students 
who have not returned to their school of origin or who plan to 
relocate permanently to where they went after the storm. In addition, 
officials in another district discussed the need for counseling 
following the trauma that students faced in fleeing and coping with a 
natural disaster. 

Text box: 

Homelessness Following a Natural Disaster: 

Three families we interviewed who were displaced from their homes 
following a hurricane--two of whom moved at least twice in the months 
following--told us of the important role their children's school 
played in helping to address their many needs. In addition to 
transportation and school supplies, the school provided homeless 
families with free before-and after-school care for students, food, 
gift cards, and clothing--some of which were donated by other 
organizations, businesses, and school districts, within and outside 
the state. According to school officials, families were also offered 
counseling services, though meeting students' needs for counseling has 
been a challenge. Officials described how children faced significant 
trauma following the storm. For example, one student carried a sibling 
on her back to escape rising floodwaters. 

Source: Interviews with school officials and families. GAO-14-465. 

[End of text box] 

Federal and State Agencies Use Numerous Strategies to Collaborate to 
Improve Services to Homeless Students despite Barriers: 

The Federal EHCY Program Manager Collaborates with Officials from 
Other Education Programs, Federal Agencies, and States to Increase 
Awareness about Homeless Education: 

The federal EHCY program manager collaborates with officials from 
other Education programs, federal agencies, and states (see table 2). 
[Footnote 51] These collaborative efforts are designed to share 
information with other programs likely to serve homeless students and 
increase awareness about the EHCY program and the rights of, and 
services available to, homeless students, among other things. In 
addition, the EHCY program manager provides training and technical 
assistance to state program coordinators. GAO has previously found 
that collaboration is essential for increasing the efficiency and 
effectiveness of federal programs and activities in areas where 
multiple agencies or programs have similar goals, engage in similar 
activities, or target similar beneficiaries.[Footnote 52] 

Table 2: Selected Examples of Federal Education for Homeless Children 
and Youth (EHCY) Program Collaboration Activities within the 
Department of Education, with Other Federal Agencies, and with States: 

Examples of collaboration activities with officials and staff from 
other Department of Education (Education) programs, offices, or 
initiatives: 
* EHCY program manager presents information to individuals 
responsible for implementing other Education programs, according to the 
EHCY program manager; 
Collaboration partners within Education[A]: Officials responsible for 
administering: 
* Elementary and Secondary Education Act, Title I, Part A programs; 
* Migrant Education Program; 
* Elementary and Secondary Education Act, Title III programs[B]. 

Examples of collaboration activities with officials and staff from 
other Department of Education (Education) programs, offices, or 
initiatives: 
* Officials from other Education programs/offices present at EHCY 
state coordinator conferences, according to the EHCY program manager; 
Collaboration partners within Education[A]: Officials responsible for 
administering: 
* Migrant Education Program; 
* Office of Special Education and Rehabilitative Services programs; 
* Early Learning Initiative (Office of Early Learning). 

Examples of collaboration activities with officials and staff from 
other Department of Education (Education) programs, offices, or 
initiatives: 
* Officials from other Education programs/offices present 
at the annual National Association for the Education of Homeless 
Children and Youth conference, according to the EHCY program manager; 
Collaboration partners within Education[A]: Officials responsible for 
administering: 
* Elementary and Secondary Education Act, Title I, Part A programs; 
* Office of Safe and Drug-Free Schools programs. 

Examples of collaboration activities with officials and staff from 
other Department of Education (Education) programs, offices, or 
initiatives: 
* Officials from other Education programs generally review 
materials developed by the National Center for Homeless Education 
(NCHE) that pertain to their programs, according to Education 
officials; 
Collaboration partners within Education[A]: Officials responsible for 
administering: 
* Elementary and Secondary Education Act, Title I, Part A programs; 
* Migrant Education Program; 
* Office of Special Education and Rehabilitative Services programs; 
* Office of Early Learning programs. 

Examples of collaboration activities with officials and staff from 
other Department of Education (Education) programs, offices, or 
initiatives: 
* EHCY program manager discusses relevant issues with staff from other 
Education programs, such as data on the number of students applying 
for financial aid for college as "independent," according to the EHCY 
program manager[C]; 
Collaboration partners within Education[A]: 
* Office of Postsecondary Education. 

Examples of collaboration activities with other federal agencies and 
entities: 
* As a member of the U.S. Interagency Council on Homelessness (USICH), 
Education shares responsibility with other agencies in fulfilling the 
council's mission to “coordinate the Federal response to homelessness 
and to create a national partnership at every level of government and 
with the private sector to reduce and end homelessness in the nation 
while maximizing the effectiveness of the Federal Government in 
contributing to the end of homelessness.”[D] 
* U.S. Interagency Council on Homelessness. 

Examples of collaboration activities with other federal agencies and 
entities: 
* Initiative to facilitate data sharing at the local level, according 
to Education and other federal officials[E]; 
Collaboration partners from other federal agencies/entities: 
* U.S. Interagency Council on Homelessness; 
* Department of Housing and Urban Development. 

Examples of collaboration activities with other federal agencies and 
entities: 
* Initiative to better understand how to prevent homelessness among 
lesbian, gay, bisexual, transgender, or questioning (LGBTQ) youth; 
Collaboration partners from other federal agencies/entities: 
* U.S. Interagency Council on Homelessness; 
* Department of Housing and Urban Development; 
* Department of Health and Human Services; 
Department of Justice. 

Examples of collaboration activities with states: 

* Provides technical assistance and training to state EHCY program 
coordinators, as required by the McKinney-Vento Act, often through 
NCHE[F]; 
- NCHE develops and shares issue briefs, tool kits, and other 
materials; disseminates information via its website and listserv; 
conducts training webinars and self-paced online training; and 
operates a helpline available to state and local EHCY program 
officials and staff, and others; 
* Provided additional technical assistance after recent natural 
disasters, according to Education and state officials; 
- NCHE is hosting a natural disaster workgroup of state EHCY program 
coordinators to develop a new section of the state coordinator 
handbook on preparing for, and responding to, natural disasters, 
according to Education and state officials. 

Source: GAO analysis of documentation and interviews with officials 
from the Department of Education, other federal agencies, and states. 
GAO-14-465. 

[A] Selected examples of Education offices, programs, and initiatives 
with which the EHCY program manager collaborates. 

[B] Title III of the Elementary and Secondary Education Act of 1965 
(ESEA), as amended, authorizes federal funding for language 
instruction for limited English proficient and immigrant students. 

[C] A student's dependency status determines whose financial 
information he or she is required to provide when filling out the Free 
Application for Federal Student Aid to apply for federal financial aid 
for college or university. Students determined to be "dependent" must 
provide financial information about their parents as well as 
themselves, whereas students determined to be "independent" must only 
provide their own financial information (and their spouse's if 
married). By law, unaccompanied homeless youth are considered 
"independent" and do not have to provide their parents' financial 
information. 20 U.S.C. § 1087vv(d)(1)(H). 

[D] 42 U.S.C. § 11311. USICH has developed a federal strategic plan to 
prevent and end homelessness called Opening Doors: Federal Strategic 
Plan to Prevent and End Homelessness. This plan has four main goals. 
They are (1) Finishing the job of ending chronic homelessness by 2015; 
(2) Preventing and ending homelessness among veterans by 2015; (3) 
Preventing and ending homelessness for families, youth, and children 
by 2020; and (4) Setting a path to ending all types of homelessness. 
USICH monitors and reports on the progress of implementation of the 
strategic plan, including the activities of agencies and programs. 

[E] HUD officials told us that they have also collaborated with the 
EHCY program manager, HHS, and USICH on initiatives to obtain an 
accurate count of children and youth experiencing homelessness and 
better understand the characteristics of those children and youth, and 
with the EHCY program manager and USICH on aligning housing status 
indicators and developing a cross walk of definitions of homelessness 
across programs to improve local collaboration and data analysis. In 
addition HUD has worked with the EHCY program manager on an initiative 
to identify and spread innovative practices employed by homeless 
housing providers to ensure fair and equal education of homeless 
children and youth, according to HUD officials. 

[F] Education is required to provide support and technical assistance 
to a state educational agency to assist it in carrying out its EHCY 
responsibilities, if requested by the state educational agency. 42 
U.S.C. § 11434(b). 

[End of table] 

State Educational Agencies Collaborate with Other State Agencies, 
Service Providers, and School Districts: 

State EHCY program coordinators collaborate with other state agencies, 
service providers and school districts to improve services to homeless 
children and youth. The McKinney-Vento Act requires state EHCY 
coordinators to facilitate coordination between the state educational 
agency and other state agencies and to collaborate with school 
district homeless liaisons, service providers, and community 
organizations, among others.[Footnote 53] According to Education data 
from its survey of state EHCY program coordinators covering school 
year 2010-11, 30 state coordinators ranked coordinating with other 
organizations and agencies to provide and improve services to homeless 
children and youth among the three activities on which they spend the 
most time.[Footnote 54] Thirty-six state coordinators reported that 
building programmatic linkages among various programs, agencies, or 
organizations was among the top three collaboration efforts that 
improved program administration and/or services to homeless children 
and youth (see figure 5). 

Figure 5: Time Spent on Collaboration and Top Collaboration 
Activities, Reported by State Education for Homeless Children and 
Youth (EHCY) Program Coordinators for School Year 2010-11: 

[Refer to PDF for image: horizontal bar graph] 

Number of state EHCY program coordinators who ranked coordination 
among the top three activities on which they spend time: 30 out of 50. 

Number of state EHCY program coordinators who ranked various 
coordination and collaboration activities among top three for 
improving EHCY program or services: 

Building programmatic linkages: 
Number of state EHCY program coordinators: 36. 

Conducting monitoring visits: 
Number of state EHCY program coordinators: 28. 

Participating in interagency task forces or committees: 
Number of state EHCY program coordinators: 24. 

Sharing data: 
Number of state EHCY program coordinators: 20. 

Identifying barriers to school access: 
Number of state EHCY program coordinators: 17. 

Sharing transportation costs: 
Number of state EHCY program coordinators: 10. 

Reviewing state policies or regulations: 
Number of state EHCY program coordinators: 7. 

Identifying gaps in services: 
Number of state EHCY program coordinators: 6. 

Source: GAO analysis of Department of Education survey of states. GAO-
14-465. 

[End of figure] 

The collaborative activities state EHCY program coordinators engage in 
may vary depending on whether they are collaborating with school 
districts, other programs, interagency councils, or non-governmental 
entities (see figure 6). 

Figure 6: Examples of State Education for Homeless Children and Youth 
Program Collaboration Activities: 

[Refer to PDF for image: illustration] 

State EHCY Program Coordinator: 

School districts/homeless liaisons: 
* Training; 
* Technical assistance; 
* Disaster assistance. 

Other state education offices/programs: 
* Information sharing; 
* Cross-training; 
* Cost sharing (for training). 

Interagency councils: 
* Information/data sharing; 
* Identifying areas of overlap; 
* Development of joint products e.g., training webinars, data 
warehouses, or state strategic plans; 
* Creating joint documents. 

Other state departments/programs: 
* Information sharing; 
* Ensuring access to school meals; 
* Referrals for Immunizations and health insurance; 
* Data sharing/development of data warehouses; 
* Providing technical assistance/training . 

Nonprofits/associations/universities: 
* Information sharing; 
* Joint conferences/present at conferences; 
* Legislative agenda development; 
* Training on the needs of homeless students and developing and 
accessing resources to serve them; 
* Program evaluation. 

Source: GAO analysis of interviews with state EHCY program 
coordinators. GAO-14-465. 

[End of figure] 

State EHCY program collaboration activities with other state agencies, 
programs, service providers, and associations have included raising 
awareness of the program, developing joint products, such as strategic 
plans, and efforts to better connect students to services. For 
example, state EHCY program staff in one state told us they 
collaborate with the state's health department and Children's Health 
Insurance Program to make sure students have access to immunizations 
and help homeless families apply for health insurance for their 
children. Additionally, they collaborate with the state agriculture 
department to ensure homeless children have immediate access to free 
school meals. One state coordinator told us that she has partnered 
with the 21st Century Community Learning Centers (21st CCLC) program, 
which allowed the state to increase the number of high schools 
receiving 21st CCLC funding from 5 to 37 and increased the resources 
available to serve homeless students.[Footnote 55] In addition, three 
state coordinators we spoke with told us that they have worked with 
universities in their states to, for example, provide information 
about students experiencing homelessness and barriers they face to 
higher education. Officials in one state told us that this 
collaboration has led over 30 public institutions of higher learning 
to identify a single point of contact within the school to advocate 
for homeless students. 

State EHCY program coordinators we interviewed provide technical 
assistance and training to school districts, as required by the 
McKinney-Vento Act,[Footnote 56] but the amount and type of assistance 
varies, particularly in districts that do not receive EHCY grants. 
According to Education's survey of state EHCY program coordinators, 
nearly half (24 of 50), responded that providing technical assistance 
was the activity on which they spend the most time, and 42 said it was 
among the top three activities. While district homeless liaisons we 
spoke with generally told us that they receive a good deal of 
technical assistance and support from their state coordinator, in one 
state we visited, non-grantee school district liaisons told us that 
they have limited interactions with their state coordinator. 

Federal and State Agencies Face Similar Barriers to Greater 
Collaboration: 

Both federal and state officials frequently cited limited staff 
capacity as a barrier to greater collaboration. At the federal level, 
the EHCY program is administered by Education's Office of Student 
Achievement and School Accountability (SASA) and run largely by a 
single individual - the EHCY program manager. The EHCY program manager 
has primary responsibility for administering the EHCY program. In 
addition, this individual is responsible for overseeing a second 
Education program - ESEA Title I, Part D (Prevention and Intervention 
Programs for Children and Youth Who Are Neglected, Delinquent, or At 
Risk). The EHCY program manager told us that capacity is a challenge 
to additional collaboration. For example, he only attends conferences 
for Title I and other Education programs every few years. Similarly, 
while state EHCY program coordinators we spoke with generally felt 
that there is significant collaboration with other entities, several 
also told us that staff capacity was a significant barrier to further 
collaboration. State coordinators are generally responsible for 
managing the EHCY grant process, monitoring and overseeing 
implementation of the EHCY program at the school district level, and 
providing technical assistance and training to school district 
personnel, including homeless liaisons; sometimes in several hundred 
school districts. Many state coordinators have responsibilities in 
addition to those for the EHCY program. According to Education's 
survey data from school year 2010-11, 23 of the 50 state EHCY program 
coordinators reported working 30 hours or more per week on EHCY 
program responsibilities. The same survey found that more than half of 
the states (27) had one or fewer full-time employees working in the 
state EHCY program office (see figure 7). For example, one state 
coordinator we spoke with was also the coordinator for another 
education program, which she said takes up about 40 percent of her 
time.[Footnote 57] 

Figure 7: Hours Worked by State Education for Homeless Children and 
Youth (EHCY) Program Coordinators and Number of Paid Staff in State 
EHCY Program Offices for School Year 2010-11: 

[Refer to PDF for image: 2 pie-charts] 

Number of hours worked per week by 50 state EHCY program coordinators 
in their official capacity as state coordinator: 
40 hours or more: 17; 
30 to 39 hours: 6; 
20-29 hours: 13; 
10-19 hours: 7; 
Fewer than 10 hours: 7. 

Number of paid staff, including state EHCY program coordinator,in 50 
state EHCY program offices: 
More than 2: 10; 
Between 1 and 2: 13; 
1: 11; 
Less than 1: 16. 

Source: GAO analysis of Department of Education survey of states. GAO-
14-465. 

[End of figure] 

According to state EHCY program coordinators, resource constraints 
have prevented additional collaboration efforts. For example, three 
state coordinators told us they must choose which partners to 
collaborate with at the expense of others. In one of these states, 
this has meant limited collaboration with RHY programs. In GAO's 
previous work, we have emphasized the importance of agencies 
identifying and leveraging sufficient funding to accomplish their 
objectives and to initiate or sustain their collaborative efforts and 
we suggested approaches to help them do so.[Footnote 58] 

Federal and state officials also said that differing definitions of 
who is considered "homeless" under various federal programs was 
another barrier to collaboration.[Footnote 59] Because the population 
eligible for services under each program differs, the populations 
contained in data collected by one agency will be different than in 
data collected by other agencies, making data sharing more difficult. 
The federal EHCY program manager told us that the lack of a consistent 
definition across programs administered by Education and HUD has 
created a challenge to increasing data sharing at the local level 
between school districts and Continuums of Care (CoC).[Footnote 60] 
Because a relatively small number of students considered homeless 
under Education's definition may be eligible for services funded by 
CoCs, these entities sometimes feel that the additional work necessary 
to share the data is not worthwhile, according to the EHCY program 
manager. Nationally, most homeless students are "doubled up." 
Officials from one state told us that because this is the case in 
their state, though school districts want to provide wrap-around 
services that meet the wide variety of homeless youths' needs, these 
students may be ineligible for services through HUD programs.[Footnote 
61] However, one school district in one of the states we reviewed has 
entered into an agreement with the local CoC that allows school 
district personnel to access and enter data into the CoC's Homeless 
Management Information System. This partnership allows the school 
district and CoC partners to track the services homeless students have 
received, evaluate the need for additional services, and make 
referrals for those services, among other functions. A state EHCY 
program coordinator we spoke with told us that a common definition 
would allow Education and HUD programs to pool data, increasing 
collaboration and efficiency. This official said that instead of 
redundant data collection, resources could be used to provide 
additional services. 

Education Currently Lacks a Comprehensive Oversight Plan and Faces 
Limitations in Using its Performance Data to Assess Program Results: 

Education Has Protocols for Monitoring State EHCY Programs but Lacks a 
Plan to Ensure Oversight of All States: 

Education has protocols and procedures in place to monitor state EHCY 
programs. According to Education guidance, monitoring is the regular 
and systematic examination of a state's administration and 
implementation of a federal education grant, contract, or cooperative 
agreement.[Footnote 62] To hold states accountable to provide a free 
appropriate public education to homeless students,[Footnote 63] 
Education evaluates the degree to which states meet certain standards, 
called monitoring indicators[Footnote 64] (see appendix II). These 
include data on: 

* monitoring of school districts; 

* implementation of procedures to identify, enroll, and retain 
homeless students by coordinating and collaborating with other program 
offices and state agencies; 

* provision of technical assistance to school districts; 

* efforts to ensure that school district grant plans for services to 
eligible homeless students meet all requirements; 

* compliance with statutory and other regulatory requirements 
governing the reservation of funds for state-level coordination 
activities; and: 

* prompt resolution of disputes. 

Education's monitoring involves a review of documents, followed by an 
on-site or videoconference review, and preparation of a final report 
that includes any compliance findings for which the state must take 
corrective action (see figure 8).[Footnote 65] Between fiscal years 
2007 and 2009, Education's policy was to monitor 50 states and 3 other 
areas (i.e., 53 "states")[Footnote 66] at least once during that 3-
year time period and it followed this policy. 

Figure 8: Overview of Education's Monitoring Process for the Education 
for Homeless Children and Youth Program: 

[Refer to PDF for image: process illustration] 

Pre-review: 
* Select which states to monitor each year; 
* Contact state educational agency to request documents in advance; 
* Review documents. 

On site or remote review: 
* Interview two or three school districts, including one non-grantee 
district; 
* Interview state educational agency officials; 
* Conduct exit meeting with state educational agency officials to 
discuss findings. 

Post-review: 
* Prepare monitoring report; 
* Send monitoring report to state; 
* Follow up with state to ensure that findings are resolved; 
* Take corrective action if state does not resolve findings in timely 
way. 

Source: GAO analysis of Department of Education documents and 
interviews. GAO-14-465. 

[End of figure] 

Starting in fiscal year 2010, Education adopted a risk-based approach 
to select states for monitoring to more efficiently target and 
prioritize limited resources, resulting in longer gaps between 
monitoring visits in some states. Education conducts an annual risk 
assessment to evaluate which states have the highest risk of 
noncompliance, according to the EHCY program manager. The agency 
weighs the following four risk assessment criteria equally: the 
state's academic proficiency levels for students experiencing 
homelessness, the tenure of the state EHCY program coordinator, 
whether there are multiple or recurring EHCY monitoring findings, and 
a financial review of the state's EHCY grant expenditures.[Footnote 
67] Education also considers the size of the state's EHCY grant 
allocation and the length of time since a state was last monitored. 
Since Education adopted this approach in fiscal year 2010, it has 
monitored 31 of the 53 states for the EHCY program--28 from October 
2009 to September 2012 and 3 from October 2012 to July 2014. Of the 22 
remaining states, Education last monitored 7 states in fiscal year 
2007, 6 in fiscal year 2008, and 9 in fiscal year 2009 (see figure 9). 

Figure 9: Frequency of Federal Monitoring for Education for Homeless 
Children and Youth (EHCY) Program Compliance since Fiscal Year 2007: 

[Refer to PDF for image: horizontal bar graph] 

Number of states: 

2007-2009: 
Not monitored: 0; 
Monitored: 53. 

2010-2012: 
Not monitored: 25; 
Monitored: 28. 

2013-2014: 
Not monitored: 50; 
Monitored: 3. 

Source: GAO analysis of Department of Education documents. GAO-14-465. 

Note: Between fiscal years 2007 and 2009, Education monitored 53 
entities for EHCY compliance, including the 50 states, the District of 
Columbia, the Commonwealth of Puerto Rico, and the Bureau of Indian 
Education. For the purposes of this report, we refer to all of these as 
states. 

[End of figure] 

In the fall of 2012 Education began monitoring states that had 
received waivers from certain ESEA requirements under an initiative 
Education calls "ESEA Flexibility" and since that time, has monitored 
three states for compliance with the EHCY program.[Footnote 68] Under 
Education's ESEA flexibility initiative, 44 of the 53 states[Footnote 
69] currently have waivers from specific requirements of the ESEA, as 
amended. In these states, Education has conducted regular monitoring, 
but the monitoring only covers compliance with the ESEA waiver 
requirements and does not include monitoring for compliance with the 
EHCY program. As a result, the states with ESEA waivers currently have 
little EHCY program oversight at the federal level.[Footnote 70] 
Education officials cited the shift to a risk-based approach to 
monitoring the EHCY program, the more recent need to focus on ESEA 
flexibility waiver monitoring, and a lack of staff capacity as the 
primary reasons why they have not been able to monitor the states as 
frequently in recent years as in the past. Education officials said 
they intend to continue to monitor the EHCY program in the future, but 
the agency has not determined when or how it will do so. Standards for 
internal control emphasize the need for federal agencies to establish 
plans to help ensure goals and objectives can be met, including 
compliance with applicable laws and regulations.[Footnote 71] Absent a 
plan for future monitoring of grantees, Education cannot be sure that 
problems will be identified and resolved promptly. 

As a result of reducing the number of monitoring visits, Education has 
been unaware of the compliance status of some states for an extended 
period of time. According to GAO's Standards for Internal Control in 
the Federal Government, monitoring is a key management tool that helps 
agencies assess the quality of performance over time and ensure that 
the problems are promptly resolved.[Footnote 72] Additionally, one 
state EHCY program coordinator we interviewed said that federal 
monitoring ensures a higher level of compliance with the McKinney-
Vento Act and that it is in a state's best interest to be monitored 
regularly. According to this program coordinator, monitoring helps 
states improve how they address homeless students' needs and provides 
important leverage within the state to ensure that program funds are 
used as intended. Of the 22 states that Education has not monitored 
since at least fiscal year 2009, 10 had been required to take 
corrective actions following their last review to address compliance 
concerns. While Education found these actions to be sufficient, 
according to officials, Education is currently unaware of whether 
these states have remained in compliance and it is possible that they 
(or other states) may have new or recurring compliance issues. For 
example, one of the states we visited had not monitored its grantees 
on-site since school year 2008-09, whereas NCHE recommends states 
monitor grantees on-site at least once every 3 years. 

Because of Education's limited monitoring of some states, it may not 
be aware of states' current practices and whether they comply with 
program requirements and their state plans, which Education has not 
required states to update since 2002.[Footnote 73] According to agency 
officials, Education has not requested updates to state plans because 
it has been waiting for the next reauthorization of the EHCY program 
before requesting new state plans.[Footnote 74] The EHCY program 
manager said that the agency reviews state plans as part of its 
monitoring review and that some states have updated their plans with 
new activities and goals.[Footnote 75] Some states have implemented 
programmatic changes since the plans were initially required in 2002. 
For example, one state we visited changed its service delivery model 
in recent years by adopting a regional approach to award grants to 
lead school districts that are responsible for providing services to 
other districts in their region. This state's EHCY coordinator 
confirmed that the state has not submitted any state plan updates to 
Education since 2002. However, because Education is no longer 
consistently monitoring all states for compliance, the agency is also 
unable to determine whether states' current practices are consistent 
with their existing state plan. GAO's Standards for Internal Control 
in the Federal Government suggest that management continually assess 
and evaluate whether internal control activities--such as reviewing 
and monitoring compliance with state plans--are effective and up-to-
date.[Footnote 76] 

Education Survey Data and GAO's Review Showed that States Generally 
Focused Their Monitoring on Grantee Districts and Not Non-Grantee 
Districts: 

The McKinney-Vento Act requires each state to describe in its plan how 
it will ensure that all school districts comply with EHCY program 
requirements, but does not specify how states must monitor compliance 
or where they should focus their efforts.[Footnote 77] NCHE's guidance 
[Footnote 78] to states on monitoring districts acknowledges the 
challenge of monitoring all districts on site annually--given resource 
constraints--and recommends that states utilize a combination of 
strategies, such as on-site monitoring for grantee districts and desk 
monitoring, i.e., phone calls or written correspondence, for non-
grantee districts. According to Education's survey of states in school 
year 2010-11, states use a variety of approaches in monitoring 
districts. Most states (43 out of 50) monitored grantees on-site and 
about half (26 out of 50) did so for non-grantees. States also 
commonly use desk monitoring, with about two-thirds (34 out of 50) 
using this approach for grantees and about half (26 out of 50) doing 
so for non-grantees (see table 3). 

Table 3: Number of States Using Various Approaches to Monitor 
Districts, School Year 2010-11: 

Monitoring approaches: Efforts are monitored through visits to local 
school districts; 
Grantee districts: 43; 
Non-grantee districts: 26. 

Monitoring approaches: Assurances of compliance with regulations are 
required; 
Grantee districts: 41; 
Non-grantee districts: 25. 

Monitoring approaches: Efforts are monitored through phone calls or 
written correspondence (i.e., desk monitoring); 
Grantee districts: 34; 

Non-grantee districts: 26. 

Monitoring approaches: Efforts are monitored by integrated monitoring 
visits to school districts that address this and other federal or state 
programs; 
Grantee districts: 33; 
Non-grantee districts: 29. 

Monitoring approaches: Progress reports are required; 
Grantee 
districts: 23; 
Non-grantee districts: 5. 

Monitoring approaches: Progress reports are requested; 
Grantee 
districts: 13; 
Non-grantee districts: 6. 

Monitoring approaches: Efforts are not monitored; 
Grantee districts: 0; 
Non-grantee districts: 2. 

Source: GAO analysis of Education's survey of states. GAO-14-465. 

Note: These results are based on a survey of 50 states. 

[End of table] 

The majority of states in Education's survey also reported including 
the EHCY program in the state's monitoring of other federal programs 
for both grantee districts (33 out of 50) and non-grantee districts 
(29 out of 50).[Footnote 79] States that monitor compliance for the 
EHCY program in this way are able to reach additional districts 
without adding to the state EHCY program coordinator's 
responsibilities, one of a few strategies that NCHE recommends to 
cover a large number of districts. For example, in one state we 
visited, a review team monitors about 100 school districts per year 
with a lengthy checklist for federal programs that includes the EHCY 
program. 

States focused their monitoring on districts that had received an EHCY 
grant from the state, resulting in limited oversight of many non-
grantee districts. NCHE's guidance indicates that states should 
monitor grantees at least once during the grant cycle--which can be up 
to 3 years--and non-grantees at least once every 3-to-5 
years.[Footnote 80] According to Education's survey, most states (39 
out of the 46 that responded to this question) said that they monitor 
grantees at least once every 2 years. Half (23 out of 46) of the 
states that responded to this question reported monitoring non-
grantees at least once every 2 years and the other half reported 
monitoring them less frequently (see figure 10). Additionally, 2 of 50 
states reported that they did not monitor non-grantees at all (see 
table 3). 

Figure 10: Frequency of State Monitoring of Grantee and Non-grantee 
Districts, by Number of States, School Year 2010-11: 

[Refer to PDF for image: vertical bar graph] 

Monitoring cycle frequency: More than once a year; 
Grantee districts: 6; 
Non-grantee districts: 2. 

Monitoring cycle frequency: Once a year; 
Grantee districts: 20; 
Non-grantee districts: 6. 

Monitoring cycle frequency: Every two years; 
Grantee districts: 13; 
Non-grantee districts: 16. 

Monitoring cycle frequency: Less than every two years; 
Grantee districts: 7; 
Non-grantee districts: 23. 

Source: GAO analysis of Department of Education survey of states. GAO-
14-465. 

Note: 46 out of the 50 states surveyed responded to this survey 
question. 

[End of figure] 

Similarly, state EHCY program coordinators in three of the four states 
we reviewed focused on monitoring grantees and employed a variety of 
approaches, according to our interviews with the coordinators. One 
state coordinator reported monitoring all grantee school districts on-
site annually. Two state coordinators reported monitoring grantees 
annually using a combination of on-site visits and desk reviews, in 
which grantees are monitored via phone and email and must send data to 
the state for review. The fourth state coordinator we interviewed 
reported conducting quarterly fiscal and program reviews in lieu of 
formal on-site or desk monitoring for all of the grantees since school 
year 2008-09.[Footnote 81] 

The four states we reviewed also varied with regard to how often they 
monitor non-grantees. State coordinators in two of the four states we 
reviewed regularly monitor all non-grantee districts within the 3 to 5 
year timeframe NCHE suggests. One state coordinator reported 
monitoring non-grantees on a 3-year rotational basis. Another state 
coordinator uses desk monitoring for all non-grantees annually and 
also uses a risk-based approach to select non-grantees for on-site 
monitoring.[Footnote 82] The other two state coordinators we 
interviewed do not regularly monitor non-grantees within the suggested 
timeframe; however, one of these states annually ensures that all 
districts have identified a homeless liaison. 

States may not focus monitoring efforts on non-grantee districts 
because they lack tools to enforce compliance. One state coordinator 
explained that the state can record a finding of noncompliance, but 
because there is no direct fiscal action or penalty attached to it, 
the district may disregard it. Another state coordinator said she has 
to accept a district's report of zero homeless students, even if she 
suspects that the district may be under-identifying them. In contrast, 
state coordinators we spoke with said that states can hold districts 
with EHCY grant funding more accountable because they have more direct 
leverage over them, in the form of the grant. According to Education's 
survey of states, 3 of 39 states that responded to this question 
reported that they withheld funds from grantees that were out of 
compliance. 

Monitoring is a key management tool for states to ensure districts' 
compliance with the McKinney-Vento Act and statewide accountability 
for administration of the federal grant. In the state that had not 
monitored its grantee districts on-site since school year 2008-09, we 
found that not all districts were aware of the availability of 
services through the regional structure adopted by the state. This 
state uses a regional approach for its grantee districts, whereby the 
grants are distributed to lead entities that are in turn responsible 
for ensuring that all homeless students within the region receive 
appropriate services. To do this, the grantee district may provide 
funds and/or services, such as training, to other districts in its 
region. While we met with two lead grantee school districts that 
provided services to other districts in the region, we also met with 
two other non-grantee districts whose officials were unaware that the 
district was eligible for funds or services from their respective lead 
grantee districts, indicating that the state's regional model was not 
being implemented effectively. Such problems suggest inadequate state-
level monitoring of school districts, reinforcing the importance of 
effective federal monitoring of states. 

Education Collects Performance Data but Faces Limitations in Using 
Them to Assess Program Results: 

Education relies on annual state performance data collected from 
school districts to determine the extent to which states are meeting 
the program's intended goal of ensuring that homeless students have 
access to a free appropriate public education (see table 4).[Footnote 
83] 

Table 4: Required Data Elements from Grantee and Non-grantee School 
Districts: 

Number of homeless students enrolled[A]; 
Grantee districts: [Check]; 
Non-grantee districts: [Check]. 

Number of homeless students served[B]; 
Grantee districts: [Check]; 
Non-grantee districts: [Empty]. 

Subgroups of homeless students enrolled (unaccompanied youth, migratory 
children and youth, children with disabilities, and Limited English 
Proficient students); 
Grantee districts: [Check]; 
Non-grantee districts: [Check]. 

Subgroups of homeless students served; 
Grantee districts: [Check]; 
Non-grantee districts: [Empty]. 

Primary nighttime residence by category (sheltered, unsheltered, 
hotels/motels, and doubled up); 
Grantee districts: [Check]; 
Non-grantee districts: [Check]. 

Academic achievement of homeless students enrolled (reading, 
mathematics, science)[C]; 
Grantee districts: [Check]; 
Non-grantee districts: [Check]. 

Source: Education's Consolidated State Performance Report Federal Data 
Collection Guide for State Coordinators of Homeless Education School 
Year 2012-2013. GAO-14-465. 

[A] Under the McKinney-Vento Act, students are enrolled if they are 
"attending classes and participating fully in school activities." 42 
U.S.C. § 11434a(1). According to Education, for data collection 
purposes, an enrolled student includes any child for whom a current 
enrollment record exists. Children aged 3 through 5 (not kindergarten) 
includes any preschool-aged (3 through 5) homeless child who is 
enrolled in a school district-administered preschool program. Children 
to be included may be attending at a specific location or 
participating in a home-based program. 

[B] For data collection purposes, the definition of served includes 
homeless children who have been served in any way through McKinney-
Vento grant-funded staff or activities. This definition includes 
children aged birth through 5 years old who are served by the grant 
program, regardless of whether or not they are enrolled in a preschool 
program operated by a school district, or in a preschool program where 
the school district is a partner administratively or financially, or 
has any accountability in serving the children. It is possible for a 
child to be served in a district, but not enrolled in that district. 

[C] Academic achievement refers to the number of students taking 
assessment exams and the percentage of students taking the exam that 
met or exceeded state proficiency standards. 

[End of table] 

Education has increased the number of data elements it requires school 
districts, particularly non-grantee districts, to report in the 
Consolidated State Performance Report. For example, in school year 
2010-11, Education began requiring states to report information on the 
academic achievement of homeless students in reading and mathematics 
from non-grantee school districts, data that had been required from 
grantee districts since at least the 2004-05 school year.[Footnote 84] 
In school year 2011-12, Education added corresponding data elements in 
science for all districts to the Consolidated State Performance 
Report. In school year 2012-13, Education began requiring states to 
report information on the number of homeless students enrolled in each 
district, by certain subcategories.[Footnote 85] Previously, Education 
had only required states to report this information by subcategory for 
grantee districts; for non-grantee districts, states were only 
required to report the total number of homeless students enrolled and 
their primary nighttime residence. 

Education presents trends in data on homeless students over time in 
its Consolidated State Performance Report;[Footnote 86] however, there 
are limitations to the use of state-reported data to assess the 
program's results. For example, the state data on the number of 
homeless students are likely incomplete or unreliable due in part to 
the under-identification of eligible students. In Education's survey 
of states, 13 of the 25 states that responded to this question had 
found that at least one grantee was not in compliance with the 
statutory requirement to identify homeless children and youth. In one 
of the four states we reviewed, Education found the data on the number 
of homeless students to be unreliable, which the state EHCY program 
coordinator attributed to a 2009-10 transition to a new, state-wide 
database system that led to undercounting homeless students. Both 
Education and the state educational agency are taking steps to address 
the state's data quality issues, according to officials from both 
agencies. Education officials told us that the under-representation of 
the number of homeless students in the data generally is an area of 
concern, which they are addressing in multiple ways. In addition to 
questioning states about this issue, an Education official said the 
agency has worked with a contractor who analyzed school district-level 
data in every state to help identify school districts that may have 
been under-identifying homeless students by comparing their rate of 
homeless student identification to the percentage of students 
receiving free or reduced-price lunch. The contractor has made 
presentations on the results of this analysis to state EHCY program 
coordinators, and Education plans to provide state EHCY program 
coordinators with additional technical assistance on outreach and 
identification. 

Another limitation to the use of state-reported data is that, by 
design, the data are difficult to compare across states. As GAO has 
previously reported, states vary in how they measure student academic 
achievement, as permitted by ESEA, to allow states to address their 
unique circumstances.[Footnote 87] Education has acknowledged this 
inherent limitation, as well as challenges in comparing data within 
states over time, as many states have made changes to their state 
assessments that can impact comparability.[Footnote 88] According to 
the Common Core State Standards Initiative, a voluntary state-led 
initiative, 43 states and the District of Columbia have chosen to 
adopt the Common Core State Standards--designed to define the 
knowledge and skills students should gain throughout their K-12 
education in order to graduate high school prepared to succeed in 
entry-level careers, introductory academic college courses, and 
workforce training programs. Most states have chosen to participate in 
one of two state-led consortia working to develop assessments based on 
these standards, expected to be available in school year 2014-15, 
which may lead to greater comparability across states. Similarly, 
according to agency officials, Education collects dropout and 
graduation rate data, including disaggregated data for homeless 
students, but these data are calculated differently in different 
states--making comparisons across states problematic.[Footnote 89] GAO 
has previously reported on the use of different state graduation 
rates, and recommended that Education provide information to all 
states on ways to account for different types of students in 
graduation rate calculations and assess the reliability of state data 
used to calculate interim rates, which it did.[Footnote 90] 

Aside from its annual data collection efforts, Education's latest 
study (forthcoming in 2014), which covers school year 2010-11, will 
provide some valuable information on program implementation, according 
to agency officials. The study collects information from surveys of 
state EHCY program coordinators and grantee school district homeless 
liaisons on topics such as their EHCY-related responsibilities; data 
collection and use; collaboration with other programs and service 
providers; barriers homeless students face to enrolling, attending, 
and succeeding in schools; and state monitoring of districts' 
compliance with the McKinney-Vento Act, among other topics.[Footnote 
91] 

Conclusions: 

The EHCY program, funded at about $65 million for fiscal year 2014, is 
intended to remove barriers to educational achievement for homeless 
students and provide them with access to critical services--such as 
transportation to school and referrals for health care. Such services 
are important to help mitigate the range of negative effects 
experienced by homeless children and youth across an array of 
measures, including academic achievement and school graduation rates. 
The program identified more than 1.1 million homeless students in 
school year 2011-12--students who, had they not been identified, might 
have faced greater difficulties succeeding in school and preparing to 
graduate. To increase the program's effectiveness, school districts, 
states, and the federal government leverage existing resources to 
ensure that homeless students are identified and their various 
academic and non-academic needs are met. The EHCY program promotes 
efforts to leverage resources, in part, by requiring coordination and 
collaboration among various programs and service providers that also 
serve homeless students. Collaboration can be particularly important 
for districts and communities addressing significant increases in 
homelessness following natural disasters. 

Appropriately identifying eligible students, in collaboration with 
other providers, is key to ensuring that districts provide homeless 
students with the services they need. However, challenges districts 
face in identifying students coupled with potential financial 
disincentives to identify them due to the cost of providing them with 
services such as transportation, can lead to under-identification, 
which has several consequences. First, it can result in barriers to 
homeless students' educational stability and achievement. Homeless 
children and youth who are not identified may have difficulty getting 
to and from their school as their nighttime residence changes and may 
therefore be derailed in their attempts to obtain an education without 
the assistance available through the EHCY program. Second, under-
identification complicates Education's ability to fully assess program 
results due to concerns about the accuracy and completeness of the 
data, which it has taken some steps to address. Similarly, under-
identification complicates the ability of the U.S. Interagency Council 
on Homelessness to accurately assess progress toward its goal of 
ending homelessness for families, youth, and children by 2020. 

While it may not be possible to accurately determine the extent to 
which districts may be under-identifying students--and the extent to 
which these children and youth may not succeed academically--
monitoring states and school districts is imperative to ensure 
compliance with the requirements of the McKinney-Vento Act, 
particularly in light of the fact that some states are implementing 
the program differently than described in their state plans. Without 
monitoring states through regular reviews of state programs and 
implementation plans, Education will not have the information it needs 
to determine whether states are meeting requirements that help provide 
eligible students with the resources needed to pursue an education. 

Recommendation for Agency Action: 

To help ensure state compliance with the McKinney-Vento Act, Education 
should develop a monitoring plan to ensure adequate oversight of the 
EHCY program. This plan could, for example, determine a schedule of 
states to be monitored and incorporate procedures to assess whether 
states need to update their state plans. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Departments of Education, 
HHS, and HUD and to USICH for review and comment. Education and USICH 
provided formal comments that are reproduced in appendices III and IV. 
Education, HHS, HUD, and USICH also provided technical comments, which 
we incorporated as appropriate. 

Education agreed that sufficient oversight of EHCY program 
requirements at the federal, state, and local levels is necessary and 
that both inter-agency and cross-program collaboration is essential to 
ensure that the needs of homeless children and youth are addressed. 
Education noted that although not all state EHCY programs have been 
monitored in recent years, the department has continued to conduct 
risk assessments for all states and to provide technical assistance to 
states and school districts through the EHCY program office and NCHE. 

Education concurred with our recommendation that, in order to ensure 
compliance with the McKinney-Vento Act, the department should develop 
a monitoring plan to ensure adequate oversight of the EHCY program. 
Education said that it is currently developing a plan for monitoring 
for fiscal year 2015 and will increase monitoring for the EHCY 
program, ensuring that all states identified as "higher risk" in its 
next round of risk assessments are monitored through document reviews, 
on-site and remote interviews with state and local educational agency 
personnel. We encourage Education to continue to consider the length 
of time since a state was last monitored in its determination of risk 
and to consider developing a monitoring schedule to help ensure that 
it has the information it needs to determine whether all states are 
meeting EHCY program requirements. Education also said that it is 
making changes to its monitoring protocol, adding questions related to 
student academic achievement and potential under-identification of 
homeless students. We support Education's decision to increase its 
EHCY program monitoring and believe focusing additional attention on 
the issue of under-identification is particularly important. Without a 
fuller sense of the extent of under-identification, it is difficult 
for Education to gauge program results. Lastly, Education indicated 
that it plans to include the development of a secure website through 
which states can update their state plans in its next technical 
assistance contract. Since states may have changed the way they 
implement the EHCY program since their state plans were originally 
developed, we encourage Education to take steps to ensure that states 
that need to update their plans do so. 

USICH agreed that monitoring EHCY grantees is important to ensure 
homeless children and youth are identified. USICH also noted the 
important role that Education can play in fostering best practices, 
strategic partnerships, and innovation to address the needs of 
homeless students. USICH stated that it considers Education and the 
EHCY program to be critical partners in developing and advancing the 
work of USICH's goal of ending homelessness among families, children, 
and youth by 2020. 

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from its issue date. At that time, we will send copies of this report 
to the Secretaries of Education, HHS, and HUD, the Executive Director 
of USICH, relevant congressional committees, and other interested 
parties. In addition, the report will be made available at no charge 
on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-7215 or Brownke@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 V. 

Signed by: 

Kay E. Brown, Director: 
Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

We used several approaches to obtain information on how school 
districts, states, and the Department of Education (Education) 
implement and oversee the Education for Homeless Children and Youth 
(EHCY) program. To gather information on how the EHCY program is 
implemented at the local level, we visited three states--Colorado, New 
Jersey, and Washington State--and conducted interviews with a fourth 
state, Texas, by phone. We selected states that represent geographic 
diversity and were identified by experts, including the National 
Association for the Education of Homeless Children and Youth (NAEHCY) 
and other national organizations working on issues related to 
homelessness, for their experiences in providing education to homeless 
students. We identified these organizations during the course of our 
background research. We also considered the number of homeless 
students states identified in recent years, including any trends, the 
level of program funding states received, and the delivery structure 
of early childhood education programs in the state. In addition, we 
selected states that experienced surges in homelessness due to recent 
natural disasters--including wildfires, flooding, and a hurricane. 
Together, these states included about 13 percent of identified 
homeless students nationwide in school year 2011-12. In each state, we 
interviewed state officials to obtain information on how they 
collaborate with other agencies, service providers, and school 
districts, as well as their monitoring practices. We also met with 
school district officials. In all, we spoke with representatives from 
20 school districts in the four states. We selected school districts, 
with assistance from state EHCY program coordinators, to represent a 
mix of urban, suburban, and rural districts, as well as districts that 
received EHCY program funds (grantees) and those that did not (non-
grantees). In one state, we also met with representatives of two 
regional educational entities that are responsible for providing EHCY-
related services to several school districts within their respective 
regions and receive EHCY program funds to do so. In the states we 
visited, we also met with school officials at the elementary, middle, 
and high school levels, and youth that have experienced homelessness, 
or their families, about their educational experiences (12 youth and 
three families). Information obtained from these states, school 
districts, youth, and families is non-generalizable. We also attended 
the 2012 NAEHCY Conference to obtain further insights into how school 
districts were implementing the EHCY program and met with five 
additional state coordinators at that conference to discuss how they 
collaborated with various stakeholders. 

To obtain generalizable and national-level information from states and 
grantee school districts, we analyzed Education data from two surveys 
covering school year 2010-11. Education's surveys collected 
information on services school districts provided to homeless children 
and youth; state and local collaboration efforts with other Education 
programs; and how states monitored school districts, including any 
differences in monitoring among grantee and non-grantee districts. A 
total of 448 school districts were included in the district-level 
survey sample, including the 50 largest school districts and a random 
sample of 401 other school districts (3 districts were removed from 
the sample after the survey was released because they had merged with 
other districts). The surveys were conducted electronically, however, 
in a small number of cases (7 or 8) districts that did not initially 
respond to the electronic survey were administered the survey over the 
phone or on paper. The school district-level survey had a weighted 
response rate of 86 percent (96 percent for the 50 largest districts 
and 85 percent for the remaining 398 districts).[Footnote 92] The 
state survey was sent to all 50 states, the District of Columbia, and 
the Bureau of Indian Affairs. The Bureau of Indian Affairs did not 
respond and was later removed from the scope of the survey. One 
additional state provided incomplete survey answers, leaving 49 states 
and the District of Columbia as the state survey population. We 
assessed the reliability of Education's survey data by performing 
electronic testing of the data elements, reviewing relevant 
documentation, and interviewing agency officials knowledgeable about 
the data. We found that the data were sufficiently reliable for the 
purposes of this report. The responses of each eligible sample member 
who provided a usable questionnaire were weighted in the analyses to 
account statistically for all members of the population. We created 
weights for each survey respondent to account for unequal 
probabilities of selection and various unit response rates among the 
survey strata. All estimates obtained from the school district-level 
survey have margins of error of no greater than six percentage points. 

To obtain information on how Education administers the EHCY program, 
we interviewed Education officials about how the agency monitors 
states for compliance and collaborates with other federal programs. We 
also interviewed officials from other federal agencies, including the 
Departments of Health and Human Services (HHS) and Housing and Urban 
Development (HUD), as well as the U.S. Interagency Council on 
Homelessness (USICH), to obtain their perspectives on collaborating 
with Education on programs that serve homeless children and youth. We 
also interviewed Education officials about the agency's monitoring 
efforts. Additionally, we reviewed relevant documents--including 
federal laws and regulations, monitoring protocols, and policy memos--
and examined Education's findings on homeless education from state 
monitoring reports. 

We conducted this performance audit from July 2012 through July 2014 
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. 

Appendix II: Education for Homeless Children and Youth Program 
Monitoring Indicators: 

[End of section] 

Table: 

Federal monitoring indicator: 1.1: The state conducts monitoring and 
evaluation of school districts with and without subgrants, sufficient 
to ensure compliance with McKinney-Vento program requirements; 
Selected examples of acceptable evidence that states provide: Written 
procedure for monitoring school districts with and without subgrants to 
include: 
* Recent copy of monitoring policies and procedures, 
schedules for current and previous school years; 
* Sample notification letters to school districts, preparation 
checklists, or other forms; 
* A copy of the interview protocol for school district reviews; 
* Most recent copies of reports, recommendations and follow-up to 
corrective actions. 

Federal monitoring indicator: 2.1: The state implements procedures to 
address the identification, enrollment and retention of homeless 
students through coordinating and collaborating with other program 
offices and state agencies; 
Selected examples of acceptable evidence that states provide: Written 
communication to school districts updating state policies and 
procedures that address the problems homeless children and youth face 
in school enrollment and retention since the last Department of 
Education program review. Updates to the state plan, including the 
completion of planned activities and proposals for new state-level 
activities. 

Federal monitoring indicator: 2.2: The state provides, or provides for, 
technical assistance to school districts to ensure appropriate 
implementation of the statute; 
Selected examples of acceptable evidence that states provide: Copies 
of written guidance to school districts and/or information 
dissemination materials distributed electronically or by other means. 
The most recent liaison orientation, on-line trainings, conferences, 
and regional training agendas and technical assistant log. 

Federal monitoring indicator: 3.1 The state ensures that school 
district subgrant plans for services to eligible homeless students meet 
all requirements; 
Selected examples of acceptable evidence that states provide: Evidence 
that the state has an application and approval process to provide 
competitive subgrants to school districts. 

Federal monitoring indicator: 3.2: The state complies with the 
statutory and other regulatory requirements governing the reservation 
of funds for state-level coordination activities; 
Selected examples of acceptable evidence that states provide: State 
budget detail on reserved funds for state-level coordination 
activities for the current fiscal year and use of funds for the last 
fiscal year. 

Federal monitoring indicator: 3.3: The state has a system for ensuring 
the prompt resolution of disputes; 
Selected examples of acceptable evidence that states provide: Updated 
state dispute resolution policy and procedures including: 
* procedures for tracking disputes; 
* documents indicating that dispute procedures have been implemented; 
* records indicating that disputes are addressed, investigated and 
resolved in a timely manner; 
Evidence that the state tracks if school districts have a dispute 
resolution policy in place. 

Source: Department of Education. GAO-14-465. 

[End of table] 

[End of section] 

Appendix III: Comments from the Department of Education: 

United States Department of Education: 
Office of Elementary and Secondary Education: 
The Assistant Secretary: 
400 Maryland Ave., SW: 
Washington, DC 20202: 

July 18, 2014: 

Ms. Kay E. Brown: 
Director: 
Education, Workforce, and Income Security Issues: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Brown: 

I am writing in response to the recommendation made in the Government 
Accountability Office's (GAO's) draft report, "Education of Homeless 
Students: Improved Program Oversight Needed" (GAO-14-465). I 
appreciate the opportunity to comment on the draft report on behalf of 
the U.S. Department of Education (Department). 

We appreciate GAO's comprehensive review of how the Federal 
government, State educational agencies, and school districts are 
addressing the requirements of the Education for Homeless Children and 
Youth (EHCY) program authorized under Title VII-B of the McKinney-
Vento Homeless Assistance Act, as well as the inter- and intra-agency
coordination of programs serving homeless children and youth. The 
Department shares the view, outlined in the report, that given the 
increasing numbers of students identified as experiencing homelessness 
by our nation's public schools in recent years and complex demands for 
coordination of services, there needs to be sufficient oversight of
requirements at the Federal, State, and local levels. We also agree 
that inter-agency and cross-program collaboration is critical to 
addressing the needs of homeless children and youth, particularly with 
respect to natural disaster assistance, early childhood education, and 
coordination with housing and human service programs serving children 
and youth experiencing homelessness. 

The Department acknowledges that since transitioning to a risk 
assessment-based protocol for monitoring, not every State ha<; been 
monitored in recent years. Though this change resulted in a decrease 
in the number of States monitored annually, the Department has not
only continued to conduct risk assessments of all 50 States, it either 
maintained or increased activities designed to support State and local 
efforts related to program administration and improving the education 
of homeless students, including regular, high-quality technical 
assistance to States and school districts provided by the EHCY program
office and its contractor for the National Center for Homeless 
Education. To these points, we appreciate that GAO's report makes 
mention of the Department's more recent efforts with respect to 
homeless education. In particular, the Department has played a 
significant role in recent Federal interagency efforts to address 
homeless ness, and we are committed to continuing our involvement in 
these efforts. The Department also has made strides in collecting, 
using, and disseminating data regarding students experiencing 
homelessness through the annual Consolidated State Performance Report 
and EDFacts Reporting System. 

The report offered one recommendation for agency action. 

Recommendation: To help ensure state compliance with the McKinney-
Vento Act, Education should develop a monitoring plan to ensure 
adequate oversight of the EHCY program. This plan could, for example, 
determine a schedule of states to be monitored and incorporate 
procedures to assess whether states need to update their state plans. 

Response: The Department understands that adequate oversight of the 
EHCY program is critically important to the success of homeless 
students. We are currently developing a plan for monitoring for the 
2015 fiscal year and will increase monitoring for the EHCY program. 
Following the next round of risk assessments, the Department plans to 
monitor any State identified as "higher risk" and will budget for 
sufficient capacity to monitor effectively, including document 
reviews, on-site and remote interviews with SEA and local agency 
personnel with EHCY-related duties, notification of findings and/or
recommendations, and instituting corrective action measures as 
necessary. Further, owing to our recently enhanced capacity to use 
data from LEAs, a new monitoring protocol will include questions about 
the academic performance and potential under-identification of 
homeless students in all LEAs in a State. We believe our enhanced 
protocol and new monitoring plan will translate into strengthened 
oversight of the EHCY program. Lastly, our next contract for a 
national homeless education technical assistance center, to be
awarded in September 2014, will include the development of a secure 
extranet Web site through which States can update their State plans 
more regularly and in ways that State Coordinators have identified as 
being meaningful for program administration. 

We appreciate the opportunity to review the draft report and comment 
on the recommendations. I am also enclosing a document with technical 
comments. 

Sincerely, 

Signed by: 

Deborah S. Delisle: 

Enclosure: 

[End of section] 

Appendix IV: Comments from the U.S. Interagency Council on 
Homelessness: 

July 18, 2014: 

Ms. Kay E. Brown, Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Brown: 

The U.S. Interagency Council on Homelessness (USICH) appreciates the 
opportunity to comment on the Government Accountability Office (GAO) 
July 2014 draft report Education of Homeless Students: Improved 
Program Oversight Needed (GAO?14?465). USICH's close collaboration 
with the Department of Education (ED) and other Council agencies 
informs our response to the report and its recommendations. 

We appreciate GAO's attention to the challenges involved in 
consistently identifying and connecting students experiencing 
homelessness with appropriate interventions. We share the urgency 
conveyed in the report to address homelessness among students and all 
Americans, which is enshrined in the goals of Opening Doors. 
Specifically, the Obama Administration has committed to end 
homelessness for families, children, and youth—including students 
experiencing homelessness—by 2020. The Administration views 
homelessness among children and youth as an urgent crisis and concurs 
that homelessness for students can have negative impacts on their 
ability to access and take full advantage of educational opportunities. 

USICH is working with ED and other Council agencies to achieve our 
goal of ending homelessness among families, children, and youth by 
2020. Through two interagency working groups—-one on families with 
children and another on youth-—Council member agencies are 
implementing strategies to increase community capacity to identify 
homelessness and connect families and youth to stable housing and 
supports to improve health, employment, and educational outcomes. ED 
and the EHCY program are critical partners in developing and advancing 
this work. 

The central insight motivating strategies for ending homelessness 
among families with children and youth is that we must scale up the 
interventions known to work, based on data and research. ED's 
partnership with USICH and other Council agencies is focused primarily 
on helping to identify the collaborations at a local level that can 
support better linkages between schools and other parts of the 
homeless response system, which in turn improves housing and 
educational outcomes for students experiencing homelessness and their 
families. To this end, ED and USICH developed comprehensive strategies 
to improve collaboration between schools and homeless services 
organizations. Use of data is a central theme of this effort, 
spotlighting local partnerships that use data on homelessness among 
students from schools to inform the planning of the community's 
response to youth homelessness. 

The focus of GAO's report calls attention to the important role ED 
plays in monitoring activities for EHCY grantees. USICH agrees that 
monitoring is important in identifying children and youth experiencing 
homelessness. At the same time, focusing exclusively or primarily on 
this role could inadvertently overlook the equally important role that 
ED can play in fostering local school and homeless services 
partnerships. While monitoring can be vital, particularly where 
practice diverges from requirements or fails to achieve core purposes, 
we advise GAO consider a more expansive view of the role ED can play 
not only in ensuring compliance, but also in fostering best practices, 
strategic partnerships, and innovation. We believe the central focus 
of ED's activities under EHCY is advancing practice by supporting such 
innovation. 

To achieve both roles, ED needs adequate resources and staff capacity. 
The current scale of resources and staffing allocated to EHCY presents 
a challenge to ED's ability to adequately monitor EHCY grantees and 
foster best practices at the local level. The $65 million allocated to 
the program dispersed among the 1,168,354 million students identified 
in schools as homeless equates to only $55.63 dollars per student per 
year. USICH and the Administration recognize that additional resources 
are needed to end homelessness among families and youth, and stand as 
a committed partner to Congress and leaders in communities across the 
country in developing a more robust response to the crisis facing far 
too many young people. 

Thank you for the opportunity to comment on this report. 

Sincerely, 

Signed by: 

Laura Green Zeilinger: 
Executive Director: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Kay E. Brown, (202) 512-7215 or brownke@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Kathryn Larin (Assistant 
Director), Avani Locke (Analyst-in-Charge), David Barish, and Jennifer 
Cook made key contributions to this report. Also contributing to this 
report were Alicia Cackley, Sarah Cornetto, Keira Dembowski, Justin 
Fisher, Hedieh Fusfield, Jessica Gray, Thomas James, Jean McSween, 
Mimi Nguyen, Paul Schmidt, Almeta Spencer, Kathleen van Gelder, and 
Amber Yancey-Carroll. 

[End of section] 

Related GAO Products: 

Managing for Results: Implementation Approaches Used to Enhance 
Collaboration in Interagency Groups. [hyperlink, 
http://www.gao.gov/products/GAO-14-220]. Washington, D.C.: February 
14, 2014. 

Homelessness: Fragmentation and Overlap in Programs Highlight the Need 
to Identify, Assess, and Reduce Inefficiencies. [hyperlink, 
http://www.gao.gov/products/GAO-12-491]. Washington, D.C.: May 10, 
2012. 

Homelessness: To Improve Data and Programs, Agencies Have Taken Steps 
to Develop a Common Vocabulary. [hyperlink, 
http://www.gao.gov/products/GAO-12-302T]. Washington, D.C.: December 
15, 2011. 

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

Homelessness: A Common Vocabulary Could Help Agencies Collaborate and 
Collect More Consistent Data. [hyperlink, 
http://www.gao.gov/products/GAO-10-702]. Washington, D.C.: June 30, 
2010. 

Runaway and Homeless Youth Grants: Improvements Needed in the Grant 
Award Process. [hyperlink, http://www.gao.gov/products/GAO-10-335]. 
Washington, D.C.: May 10, 2010. 

Disconnected Youth: Federal Action Could Address Some of the 
Challenges Faced by Local Programs That Reconnect Youth to Education 
and Employment.[hyperlink, http://www.gao.gov/products/GAO-08-313]. 
Washington, D.C.: February 28, 2008. 

[End of section] 

Footnotes: 

[1] Department of Education, National Center for Homeless Education, 
Education for Homeless Children and Youths Program: Data Collection 
Summary (March 2014). 

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

[3] J. J. Cutuli et al., "Academic Achievement Trajectories of 
Homeless and Highly Mobile Students: Resilience in the Context of 
Chronic and Acute Risk," Child Development, vol. 84, no. 3 (2013). 

[4] Stewart B. McKinney Homeless Assistance Act, Pub. L. No. 100-77, 
§§ 721-725, 101 Stat. 482, 525-28 (codified as amended at 42 U.S.C. §§ 
11431-11435). In 2000, the law was renamed the McKinney-Vento Homeless 
Assistance Act. Pub. L. No. 106-400, 114 Stat. 1675 (2000). The EHCY 
program was significantly amended by the McKinney-Vento Homeless 
Education Assistance Improvements Act of 2001, enacted as part of the 
No Child Left Behind Act of 2001, Pub. L. No. 107-110, §§ 1031-1034, 
115 Stat. 1425, 1989-2007 (2002). 

[5] See generally Consolidated Appropriations Act, 2014, Pub. L. No. 
113-76, div. H, tit. III, 128 Stat. 5, 391-92 (2013). The amount for 
the EHCY program was specified in a report from the Senate Committee 
on Appropriations. S. Rep. No. 113-71, at 166 (2013). 

[6] See 42 U.S.C. § 11432. In general, subject to minimum award 
requirements, the amount that a state receives for the EHCY program is 
based on the proportion of funds allocated nationally that it receives 
under Title I, Part A of the Elementary and Secondary Education Act of 
1965, as amended (ESEA). 

[7] See 42 U.S.C. § 11433. For purposes of this report, we use the 
term "school district" to refer to a local educational agency. In 
addition, for the purposes of our report, we refer to districts that 
received an EHCY grant from their state as "grantee districts," and 
those that did not as "non-grantee districts." 

[8] GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, 
Overlap, and Duplication and Achieve Other Financial Benefits, 
[hyperlink, http://www.gao.gov/products/GAO-13-279SP] (Washington, 
D.C.: Apr. 9, 2013). 

[9] It was not the purpose of this report to assess states' or 
districts' compliance with the McKinney-Vento Act. 

[10] NAEHCY is a membership organization made up of local homeless 
education liaisons, educators, school counselors, social workers, 
registrars, nurses, child advocates, shelter staff, state and federal 
policy specialists, and partners from community-based and national non-
profit organizations. It provides professional development, resources, 
and training support on meeting the educational needs of children and 
youth experiencing homelessness. 

[11] Education is expected to release a report based on these surveys 
in 2014. 

[12] These data include only those children and youth enrolled in 
school who were identified and reported as homeless by school 
districts; these data do not include homeless children and youth 
enrolled in school who were not identified or reported by school 
districts or homeless children and youth not enrolled in school. Due 
to changes in how the data collection instrument for states was pre-
populated beginning in school year 2011-12, the number of homeless 
students that year cannot be compared to prior years. However, 
Education reported a 13 percent increase in the number of homeless 
students enrolled--from 939,903 to 1,065,794--between school years 
2009-10 and 2010-11. 

[13] Department of Education, National Center for Homeless Education, 
Education for Homeless Children and Youths Program: Data Collection 
Summary (March 2014). 

[14] 42 U.S.C. § 11434a(2). In this report, when we refer to the EHCY 
program definition of homelessness, we mean this definition. 
"Migratory child" is defined in section 1309 of the ESEA, see 20 
U.S.C. § 6399(2). 

[15] See generally 42 U.S.C. § 11432. In addition to the 50 states, 
the District of Columbia, Puerto Rico, the outlying areas (the U.S. 
Virgin Islands, Guam, American Samoa, and the Northern Mariana 
Islands) and the Bureau of Indian Affairs also receive funds. Apart 
from the outlying areas and the Bureau of Indian Affairs, funds are 
generally allocated to states based on each state's share of ESEA 
Title I, Part A funds. 

[16] For the purposes of this report, we refer to the Office of 
Coordinator as the state coordinator for the EHCY program. 

[17] 42 U.S.C. §§ 11432(e)(1), 11433(c)(1). States that receive the 
minimum state award amount are required to distribute no less than 50 
percent to districts. States may use the remaining funds for state-
level activities. 

[18] 42 U.S.C. § 11433(c). 

[19] 42 U.S.C. § 11433(d). 

[20] Data from school year 2011-12 are the most recent data available. 

[21] NCHE is Education's technical assistance and information center 
for the EHCY program. It provides research, resources, and information 
that help communities address the educational needs of children 
experiencing homelessness. NCHE also supports educators and service 
providers by producing training and awareness materials, and providing 
training at regional and national conferences and events. 

[22] 42 U.S.C. § 11432(g)(1)(J)(ii), (g)(6). 

[23] The "school of origin" is the school that the child or youth 
attended when permanently housed or the school in which the child or 
youth was last enrolled. 42 U.S.C. § 11432(g)(3)(G). In determining 
the best interest of a child or youth, a district must, to the extent 
feasible, keep a homeless child or youth in the school of origin 
unless doing so is contrary to the wishes of the child or youth's 
parent or guardian. 42 U.S.C. § 11432(g)(3)(A)-(B). 

[24] 42 U.S.C. § 11432(g)(3)(C). 

[25] 42 U.S.C. § 11432(g)(4). 

[26] 20 U.S.C. § 6313(c)(3)(A). Under Education's regulations, school 
districts are also directed to reserve Title I funds as reasonable and 
necessary to conduct "other authorized activities," which, according 
to Education officials, could include providing additional support to 
homeless students who do attend Title I schools. 34 C.F.R. § 
200.77(g). In addition, the Consolidated Appropriations Act, 2014 
authorized school districts to use Title I funds to support homeless 
liaisons and provide transportation for homeless students to their 
schools of origin. Education notified state Title I directors and EHCY 
state coordinators of these new flexibilities in a letter dated March 
21, 2014. 

[27] 42 U.S.C. § 11432(g)(5). Runaway and Homeless Youth programs 
provide temporary emergency shelter, transitional housing, street 
outreach services, and maternity group home programs for youths to 
help them transition to self-sufficiency. 

[28] For example, a different provision in the McKinney-Vento Act 
defines homeless individuals eligible for services under the Homeless 
Assistance programs administered by HUD. See 42 U.S.C. § 11302. Other 
programs, such as the Head Start program administered by HHS, use the 
EHCY definition of homeless children and youth. 42 U.S.C. § 9832(11). 

[29] See 42 U.S.C. §§ 11311-11320. Title II of the McKinney-Vento Act 
established the "Interagency Council on the Homeless" in 1987. The 
Consolidated Appropriations Act, 2004, renamed it the "United States 
Interagency Council on Homelessness." Pub. L. No. 108-199, div. G, § 
216, 118 Stat. 3, 394. 

[30] Pub. L. No. 111-22, div. B, § 1004, 123 Stat. 1632, 1666 
(codified at 42 U.S.C. § 11311). 

[31] Officials in the remaining seven districts told us they used 
other methods to identify homeless students. For example, districts 
may identify students as homeless informally at enrollment through 
conversations with new students. 

[32] Under the McKinney-Vento Act, liaisons are to ensure that 
homeless students are identified by school personnel and through 
coordination with other entities and agencies. 42 U.S.C. § 
11432(g)(6)(A)(i). 

[33] For the purposes of our report, we will refer to districts that 
received an EHCY grant from their state as "grantee districts," and 
those that did not as "non-grantee districts." 

[34] Three of four state EHCY program coordinators we interviewed said 
grantee and non-grantee districts generally face the same challenges. 
The fourth state EHCY program coordinator did not compare challenges 
between grantee and non-grantee districts. 

[35] The 95 percent confidence interval for this median is from 1.6 to 
1.9. 

[36] In this state, according to the state educational agency, a child 
is awaiting foster care placement during the period of time between 
the initial placement of the child into state care and the 30-day 
shelter care hearing--at which time the court reviews the status of 
the child and either orders the child to return home or to remain in 
placement (i.e. in foster care). 

[37] Unaccompanied youth are those not in the physical custody of a 
parent or guardian. 42 U.S.C. § 11434a(6). 

[38] Andrew Cray, Katie Miller, and Laura E. Durso, Seeking Shelter: 
The Experiences and Unmet Needs of LGBT Homeless Youth, Center for 
American Progress (Washington, D.C.: September 2013). 

[39] Officials in one of these districts said they relied on students 
to self-identify while another district also used previously scheduled 
parent-teacher conferences to identify students. 

[40] Officials in grantee school districts were asked to select among 
eight barriers to school enrollment, six barriers to school 
attendance, and nine barriers to school success, aside from "other 
(please specify)." 

[41] State plans are required to contain assurances that the state and 
its school districts will adopt policies and practices to ensure that 
transportation is provided, at the request of the parent or guardian 
(or in the case of unaccompanied youth, the liaison) to and from the 
school of origin. 42 U.S.C. § 11432(g)(1)(J)(iii). 

[42] The Consolidated Appropriations Act, 2014 authorized school 
districts to use ESEA Title I funds to provide transportation for 
homeless students to their schools of origin. Consolidated 
Appropriations Act, 2014, Pub. L. No. 113-76, div. H, tit. III, 128 
Stat. 5, 388 (2013). 

[43] Officials told us the district did not receive an EHCY grant. The 
state's EHCY program coordinator said that to ensure that EHCY grant 
funds are not used solely to defray the costs of transportation, the 
state limits the amount of the grant districts can use for 
transportation purposes to 65 percent. 

[44] The McKinney-Vento Act requires school districts to place 
homeless children or youth in either their school of origin or in a 
public school in the local attendance area where they are actually 
living, according to the best interest of the child or youth. 42 
U.S.C. § 11432(g)(3)(A). In making the best interest determination, 
the Act states that to the extent feasible, a school district shall 
keep a student in the school of origin, unless doing so is contrary to 
the wishes of the parent or guardian. If a district decides to place a 
student in a school that is not the school of origin or one requested 
by the parent or guardian, it must provide a written explanation to 
the parent or guardian along with a statement about their right to 
appeal the placement decision. 42 U.S.C. § 11432(g)(3)(B). 

[45] According to Education guidance, school districts may consider 
the age of a child or youth, the distance of a commute, and the impact 
it may have on a student's education, among other things, in 
determining what is feasible. 

[46] According to Education, homeless children and youth are 
automatically eligible for ESEA Title I, Part A services. Under Title 
I, Part A, school districts must reserve, or set aside, such funds as 
are necessary to provide comparable services to homeless children who 
are not attending Title I schools. 20 U.S.C. § 6313(c)(3)(A). For 
example, Title I, Part A funds may be used to provide educationally-
related support services, such as tutoring, to children at shelters, 
motels, and other places where homeless children may live. According 
to officials, Education's regulations also permit school districts to 
reserve Title I funds to provide support to homeless students who do 
attend Title I schools. See 34 C.F.R. § 200.77(g). 

[47] In some of the districts, the preschool programs officials 
referred to were Head Start programs. Homeless children who meet the 
EHCY program definition are automatically eligible for Head Start. 
Homeless preschoolers are also a target population under the McKinney-
Vento Act. For example, each state plan must include procedures to 
ensure that homeless children have equal access to the same public 
preschool programs, administered by the state educational agency, as 
provided to other children in the state. 42 U.S.C. § 11432(g)(1)(F)(i). 

[48] In one of these districts, an official said that homeless 
preschoolers can ride the bus but must be accompanied by a sibling. 
According to Education guidance, a district must provide 
transportation for homeless preschoolers only if it provides 
transportation for other preschoolers. 

[49] Under the McKinney-Vento Act, liaisons must ensure that homeless 
children, youth, and their families receive referrals to health care, 
mental health, dental, and other appropriate services. 42 U.S.C. § 
11432(g)(6)(A)(iii). 

[50] Officials in four districts said that the use of different 
federal definitions of homelessness has created some challenges or 
confusion. Some HUD programs use a definition of homelessness that is 
different than the EHCY program definition. For example, according to 
officials we spoke with some families living doubled-up may not be 
eligible for HUD programs. As we have previously reported, the HEARTH 
Act of 2009 broadened the definition of homelessness used by HUD 
homeless assistance programs. However, the HEARTH Act did not fully 
align the definitions used by the EHCY program and the homeless 
assistance programs. For example, an individual or family who is 
sharing housing with others may be eligible for services under the 
homeless assistance programs, but only if they will imminently lose 
their housing, have no subsequent residence identified, and lack the 
resources or support networks need to obtain other permanent housing. 
Unaccompanied youth and homeless families with children and youth who 
meet the EHCY program definition may be eligible for homeless 
assistance programs as well, but only under certain other 
circumstances. See 42 U.S.C. § 11302(a)(5)-(6). 

[51] The federal EHCY program manager has primary responsibility for 
overseeing the EHCY grant making process; providing technical 
assistance, including serving as the contract representative for NCHE; 
program monitoring and oversight; reviewing program performance data; 
and coordinating interagency collaboration efforts. 

[52] [hyperlink, http://www.gao.gov/products/GAO-13-279SP]. 

[53] 42 U.S.C. § 11432(f)(4)(5). 

[54] Providing technical assistance was the only activity that more 
state coordinators (42) reported among the top three activities on 
which they spend their time. In addition, 24 ranked raising awareness 
and understanding among districts of the requirements of the McKinney-
Vento Act and the role of the district homeless liaison among the top 
three activities. 

[55] The 21ST Century Community Learning Centers (21ST CCLC) program 
is an Education program which supports the creation of community 
learning centers that provide academic enrichment opportunities during 
non-school hours for children, particularly students who attend high-
poverty and low-performing schools. Some states, if they are approved 
for a waiver by Education, may also offer expanded learning time 
programs within the school day. 

[56] 42 U.S.C. § 11432(f)(6). 

[57] While such arrangements might facilitate collaboration between 
the two programs under the same coordinator, it may also create 
challenges to collaboration with other programs due to the additional 
responsibilities of that single individual for multiple programs. 

[58] GAO, Managing for Results: Key Considerations for Implementing 
Interagency Collaborative Mechanisms, [hyperlink, 
http://www.gao.gov/products/GAO-12-1022] (Washington, D.C.: Sept. 27, 
2012); GAO, Results-Oriented Government: Practices that Can Help 
Enhance and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005); GAO, Managing for Results: Implementation Approaches Used to 
Enhance Collaboration in Interagency Groups, [hyperlink, 
http://www.gao.gov/products/GAO-14-220] (Washington, D.C.: Feb. 14, 
2014). 

[59] GAO has previously reported on the lack of a common definition of 
homelessness across federal agencies and programs. See GAO, 
Homelessness: A Common Vocabulary Could Help Agencies Collaborate and 
Collect More Consistent Data, [hyperlink, 
http://www.gao.gov/products/GAO-10-702] (Washington, D.C.: June 30, 
2010). As we reported in 2012, the HEARTH Act of 2009 broadened the 
definition of homelessness used by HUD homeless assistance programs. 
See GAO, Homelessness: Fragmentation and Overlap in Programs Highlight 
the Need to Identify, Assess, and Reduce Inefficiencies, [hyperlink, 
http://www.gao.gov/products/GAO-12-491] (Washington, D.C.: May 10, 
2012). However, the HEARTH Act did not fully align the definitions 
used by the EHCY program and the homeless assistance programs. 

[60] The CoC program is designed to assist individuals (including 
unaccompanied youth) and families experiencing homelessness and to 
provide the services needed to help such individuals move into 
transitional and permanent housing, with the goal of long-term 
stability. The program is designed to promote community-wide planning 
and strategic use of resources to address homelessness; improve 
coordination and integration with mainstream resources and other 
programs targeted to people experiencing homelessness; improve data 
collection and performance measurement; and allow each community to 
tailor its program to the particular strengths and challenges within 
that community. HUD awards CoC program funding competitively to 
nonprofit organizations, states, and/or units of general purpose local 
governments, which may contract or subgrant with other organizations 
or government entities to carry out the grant's day-to-day program 
operations. 

[61] Under the EHCY program, homeless children and youth include those 
who are sharing the housing of others due to loss of housing, economic 
hardship, or a similar reason. 42 U.S.C. § 11434a(2)(B)(i). Under the 
Continuum of Care program, an individual or family who is sharing 
housing with others may be considered homeless, but only if they will 
imminently lose their housing, have no subsequent residence 
identified, and lack the resources or support networks need to obtain 
other permanent housing. Unaccompanied youth and homeless families 
with children and youth who meet the EHCY program definition may meet 
the definition of homeless for the Continuum of Care program as well, 
but only under certain other circumstances. See 42 U.S.C. § 
11302(a)(5)-(6). 

[62] In addition, GAO's Standards for Internal Control in the Federal 
Government state that internal control should generally be designed to 
assure that ongoing monitoring occurs in the course of normal 
operations, is performed continually, and is ingrained in the agency's 
operations. See GAO, Standards for Internal Control in the Federal 
Government, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.: 
November 1999). 

[63] The McKinney-Vento Act requires Education to determine the extent 
to which state educational agencies are ensuring that each homeless 
child and youth has access to a free appropriate public education. 42 
U.S.C. § 11434. In some states, preschool programs are operated under 
the authority of entities other than the state educational agency or 
school districts. Because the McKinney-Vento Act requirements only 
apply to state educational agencies and school districts, Education 
has no role in monitoring homeless education in preschool programs 
operated by other entities. 

[64] U.S. Department of Education, Student Achievement and School 
Accountability Programs (SASA) Monitoring Plan for Formula Grant 
Programs (March 2013). The published indicators provide guidance for 
all states regarding the purpose and intended outcomes of monitoring 
by describing what is being monitored and providing the criteria for 
judging the quality of implementation. 

[65] A finding is a compliance issue that has a required corrective 
action by the state educational agency. 

[66] In addition to the 50 states, Education's Office of Student 
Achievement and School Accountability (SASA) also monitors the 
District of Columbia, the Commonwealth of Puerto Rico, and the Bureau 
of Indian Education. For the purposes of this report, we refer to all 
of these as states. Education also provides EHCY grants to the 
outlying areas (the U.S. Virgin Islands, Guam, American Samoa, and the 
Northern Mariana Islands), but according to SASA officials these areas 
consolidate their eligible federal funds under Title V and are 
therefore monitored by a different office, the Office of School 
Support and Rural Programs, within the Office of Elementary and 
Secondary Education. 

[67] Education's final determination of the level of risk averages the 
risk levels for its EHCY program as well as for another Education 
program under Title I, Part D (State Agency Program for Neglected and 
Delinquent Children and Youth), which uses the same criteria. 

[68] The ESEA authorizes the Secretary of Education to waive, with 
certain exceptions, any statutory or regulatory requirement of ESEA 
for states or school districts that receive ESEA funds and submit a 
waiver request that meets statutory requirements. 20 U.S.C. § 7861. In 
2011, Education invited states to request waivers of specific 
requirements of the ESEA, as amended. To be approved, Education 
required states to develop and implement specified changes, including 
comprehensive plans to improve educational outcomes for all students, 
close achievement gaps, increase equity, and improve the quality of 
instruction. Education reviewed requests and granted waivers to 45 
states through school year 201314; however, one state's waiver is not 
being renewed after the 2013-14 school year, making the current total 
44 states with waivers. Under the ESEA, waivers can be effective for 
up to 4 years, although they may be extended. These waivers do not 
exempt states from requirements of the McKinney-Vento Act. 

[69] The states currently without ESEA waivers are the Bureau of 
Indian Education, California, Iowa, Montana, Nebraska, North Dakota, 
Vermont, Washington, and Wyoming. 

[70] According to Education officials, although the agency has not 
conducted on-site monitoring of the EHCY program for these states, it 
has conducted annual risk assessments and analyzed state and school 
district performance data. Officials also said that Education responds 
to complaints it may receive and provides technical assistance. 

[71] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[72] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[73] Under the McKinney-Vento Act, states are required to develop 
plans that describe how they will implement the program and submit the 
plans to Education. 42 U.S.C. § 11432(g). Education is responsible for 
reviewing state plans using a peer review process and evaluating 
whether state laws, policies, and practices described in the plan 
adequately address the problems of homeless children and youths 
relating to access to education and placement as described in the 
plan. 42 U.S.C. § 11434(a). 

[74] The EHCY program was last reauthorized as part of the ESEA 
reauthorization in 2002. Reauthorization of the EHCY program is again 
being considered as part of future ESEA reauthorization, according to 
Education officials. Education officials said that clearance from the 
Office of Management and Budget would be needed before they can 
require states to update their state plans. 

[75] Education is currently developing a template that will allow 
states to voluntarily update their state plans online, according to 
officials; however, they said this website is unlikely to be completed 
before next year. 

[76] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[77] 42 U.S.C. § 11432(g)(2)(A). 

[78] NCHE has developed various resources which are available to 
assist state EHCY program coordinators ensure their monitoring efforts 
are effective, for example a state coordinator's handbook for 
monitoring. 

[79] However, the survey data do not show whether this monitoring 
addresses all aspects of the EHCY program or if it just asks about 
financial elements related to the EHCY program, which is the case for 
two of the four states we reviewed. 

[80] U.S. Department of Education, National Center for Homeless 
Education, State Coordinator's Handbook for LEA Monitoring (Fall 
2006), State Coordinators' Handbook (December 2010), and A Guide to 
Meeting Compliance Requirements for the McKinney-Vento Program 
(December 2011). 

[81] According to the state coordinator in the state that had not 
monitored grantee districts on-site since school year 2008-09, the 
state educational agency will start to monitor grantee districts on-
site at least once every 2 years, starting in April 2014. 

[82] This state's EHCY program coordinator reported annually reviewing 
each district's data on homeless students and visiting those non-
grantees with the highest risk of noncompliance based on several risk 
factors, such as fewer than expected homeless students identified 
given a district's poverty rates; trends in under-identification; a 
high number of disputes with neighboring districts and/or complaints 
from parents; and the size of the district, with larger districts 
assumed to have a higher risk of noncompliance. 

[83] The McKinney-Vento Act requires Education to collect and 
disseminate certain information regarding homeless children and youth. 
42 U.S.C. § 11434(h). Education is required to determine, based on 
information it collects and information provided by states, the extent 
to which state educational agencies are ensuring that each homeless 
child and homeless youth has access to a free appropriate public 
education. 42 U.S.C. § 11434(f). According to Education, states report 
data through two methods--on an ongoing basis through its EDFacts 
database and through the Consolidated State Performance Report, which 
states must certify annually. The National Center for Homeless 
Education releases these data in a data collection summary for the 
EHCY program on an annual basis. 

[84] These data included the number and percentage of homeless 
students who were enrolled in school and assessed in reading and math 
and the percent of these students who achieved proficiency levels. 

[85] The subcategories of homeless children and youth are (1) 
unaccompanied homeless youth, (2) migratory children and youth, (3) 
children with disabilities, and (4) Limited English Proficient 
students. 

[86] As of March 2014, Education was not able to calculate percentage 
changes in enrollment and nighttime residence data from year to year 
due to a recent change in how it produced these data, but anticipated 
being able to do so in future years. Beginning in school year 2011-12, 
Education required states to identify which districts received grants 
and which did not. As a result, Education was able to report 
enrollment and primary nighttime residence data by grantees and non-
grantees using school district-level data, instead of state-level 
data. However, because homeless students frequently move from district 
to district, it is possible that the same student would be reported by 
multiple districts in a state in the school district-level data. 
Consequently, increases in enrollment data from year to year may be a 
result of this duplication as well as to an actual increase in the 
number of homeless students. See U.S. Department of Education, 
National Center for Homeless Education, Education for Homeless 
Children and Youths Program Data Collection Summary (March 2014). 

[87] GAO, No Child Left Behind Act: Improvements Needed in Education's 
Process for Tracking States' Implementation of Key Provisions, 
[hyperlink, http://www.gao.gov/products/GAO-04-734] (Washington, D.C.: 
Sept. 30, 2004). 

[88] Academic achievement data may be particularly unreliable for 
homeless students, who tend to move frequently and often have erratic 
school attendance, increasing the likelihood that they will miss 
taking the academic achievement exams, which are typically given only 
once during high school. 

[89] In addition, school districts have difficulty tracking students 
who leave school because they do not know whether a student has 
dropped out of school or is enrolled in another school district, 
undermining the reliability of the dropout data. Our previous work 
found that student mobility was the primary factor affecting the 
accuracy of graduation rates; students who come and go make it 
difficult to keep accurate records. See GAO, No Child Left Behind Act: 
Education Could Do More to Help States Better Define Graduation Rates 
and Improve Knowledge About Intervention Strategies, [hyperlink, 
http://www.gao.gov/products/GAO-05-879] (Washington, D.C.: Sept. 20, 
2005). 

[90] See [hyperlink, http://www.gao.gov/products/GAO-05-879]. 
According to agency officials, Education requires states and school 
districts to report a standard 4-year adjusted cohort graduation rate 
for all students. This rate is comparable across states, but it is not 
disaggregated for homeless students. 

[91] Education had initially intended to survey both grantee and non-
grantee school districts but found that the variation in how states 
implement the program prevented doing so. 

[92] To determine the weighted response rate, we used the response 
rate definition "RR3," as defined by the American Association for 
Public Opinion Research in "Standard Definitions: Final Dispositions 
of Case Codes and Outcome Rates for Surveys," (Revised 2011). RR3 
estimates the proportion of cases of unknown eligibility that are, in 
fact, eligible. 

[End of section] 

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