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United States Government Accountability Office: 
GAO: 

Report to the Chairman, Committee on Education and the Workforce, 
House of Representatives: 

September 2013: 

Race To The Top: 

States Implementing Teacher and Principal Evaluation Systems despite 
Challenges: 

GAO-13-777: 

GAO Highlights: 

Highlights of GAO-13-777, a report to the Chairman, Committee on 
Education and the Workforce, House of Representatives. 

Why GAO Did This Study: 

Education created RTT under the American Recovery and Reinvestment Act 
of 2009 to provide incentives for states to reform K-12 education in 
areas such as improving the lowest performing schools and developing 
effective teachers and leaders. In 2010, Education awarded 12 states 
nearly $4 billion in RTT grant funds to spend over 4 years. A state’s 
RTT application and scope of work included the state’s plans for 
development and implementation of teacher and principal evaluation 
systems by participating school districts. These systems assess 
teacher and principal effectiveness based on student academic growth 
and other measures, such as observation of professional practice. 
Currently, additional states are designing and implementing similar 
evaluation systems. 

GAO was asked to review RTT teacher and principal evaluation systems. 
This report examines (1) the extent to which the 2010 grantee states 
have implemented their teacher and principal evaluation systems, (2) 
the challenges the grantee states have faced in designing and 
implementing these systems, and (3) how Education has helped grantee 
states meet their RTT objectives for teacher and principal evaluation 
systems. 

GAO reviewed relevant federal laws, regulations, and guidance; 
analyzed RTT applications and documentation on each state’s guidelines 
for their evaluation systems; and interviewed officials from all 12 
states, selected districts, and Education. 

What GAO Found: 

By school year 2012-13, 6 of 12 Race to The Top (RTT) states fully 
implemented their evaluation systems (i.e., for all teachers and 
principals in all RTT districts). However, their success in fully 
implementing by the date targeted in their RTT applications varied. 
Three of these states met their target date while three did not for 
various reasons, such as needing more time to develop student academic 
growth measures. The six states that did not fully implement either 
piloted or partially implemented. The scope of pilots varied. One 
state piloted to about 14 percent of teachers and principals while 
another piloted to about 30 percent of teachers. State or district 
officials in four of the six states expressed some concerns about 
their readiness for full implementation. 

Figure: Implementation status of evaluation systems in school year 
2012-13: 

[Refer to PDF for image: illustrated table] 

Teacher evaluations: 
Delaware: Full implementation by all RTT districts; 
District of Columbia: Full implementation by all RTT districts; 
Florida: Full implementation by all RTT districts; 
Georgia: Pilot or partial implementation;
Hawaii: Pilot or partial implementation;
Maryland: Pilot or partial implementation;
Massachusetts: Pilot or partial implementation;
New York: Pilot or partial implementation;
North Carolina: Full implementation by all RTT districts; 
Ohio: Pilot or partial implementation;
Rhode Island: Full implementation by all RTT districts; 
Tennessee: Full implementation by all RTT districts. 

Principal evaluations: 
Delaware: Full implementation by all RTT districts; 
District of Columbia: Full implementation by all RTT districts; 
Florida: Full implementation by all RTT districts; 
Georgia: Pilot or partial implementation;
Hawaii: Full implementation by all RTT districts; 
Maryland: Pilot or partial implementation;
Massachusetts: Pilot or partial implementation;
New York: Pilot or partial implementation;
North Carolina: Full implementation by all RTT districts; 
Ohio: Pilot or partial implementation;
Rhode Island: Full implementation by all RTT districts; 
Tennessee: Full implementation by all RTT districts. 

Source: GAO analysis. 

[End of figure] 

Officials in most RTT states cited challenges related to developing 
and using evaluation measures, addressing teacher concerns, and 
building capacity and sustainability. State officials said it was 
difficult to design and implement rigorous student learning objectives—
an alternate measure of student academic growth. In 6 states, 
officials said they had difficulty ensuring that principals conducted 
evaluations consistently. Officials in 11 states said teacher concerns 
about the scale of change, such as the use of student academic growth 
data and consequences attached to evaluations, challenged state 
efforts. State and district officials also discussed capacity 
challenges, such as too few staff or limited staff expertise and 
prioritizing evaluation reform amid multiple educational initiatives. 
Officials in 10 states had concerns about sustaining their evaluation 
systems. 

Education helps RTT states meet their goals for teacher and principal 
evaluation systems through a new monitoring process and through 
technical assistance. Education officials said the RTT monitoring 
process differs from other monitoring efforts in the frequency of 
contact with the states and the emphasis on continuous improvement and 
quality of RTT reforms. Officials from 8 of the 12 RTT states 
expressed generally positive views about Education’s monitoring. When 
states have not demonstrated adequate progress, Education has taken 
corrective action. For example, Education designated two states as 
high-risk, which resulted in additional monitoring. Education provides 
technical assistance through a contractor; officials from 10 RTT 
states told us assistance related to evaluation systems was generally 
helpful. Education officials said they plan to provide RTT and 
nongrantee states with more information to support their efforts. 

What GAO Recommends: 

GAO is not making recommendations in this report. 

View [hyperlink, http://www.gao.gov/products/GAO-13-777]. For more 
information, contact George Scott at (202) 512-7215 or scottg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Six of 12 RTT States Fully Implemented Their Evaluation Systems by the 
2012-13 School Year: 

Most RTT States Cited Challenges with Developing and Using Certain 
Evaluation Measures, Addressing Teacher Concerns, and Building 
Capacity and Sustainability: 

Education Supports RTT State Implementation Efforts through Monitoring 
and Technical Assistance: 

Concluding Observations: 

Agency Comments and Our Evaluation: 

Appendix I: Comments from the U.S. Department of Education: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Department of Education: 

Recovery Act: 

Tables: 

Table 1: Race to the Top Grant Awards, by Phase and Amount Awarded: 

Table 2: Race to the Top State Selection Criteria: 

Figures: 

Figure 1: Example Components of Race to the Top States' Evaluation 
Systems: 

Figure 2: Implementation Status for Race to the Top States' Evaluation 
Systems, School Year 2012-13: 

Figure 3: Capacity Challenges Faced by Race to the Top States: 

Figure 4: Examples of Race to the Top State and Selected District 
Efforts to Address Capacity Challenges: 

Figure 5: Cases of Technical Assistance Provided by the Reform Support 
Network to Race to the Top States on Teacher and Leader Effectiveness, 
Calendar Years 2010-2013: 

Abbreviations: 

Education: U.S. Department of Education: 

ESEA: Elementary and Secondary Education Act of 1965: 

Recovery Act: American Recovery and Reinvestment Act of 2009: 

RSN: Reform Support Network: 

RTT: Race to the Top: 

SLOs: student learning objectives: 

SY: school year: 

[End of section] 

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

September 18, 2013: 

The Honorable John P. Kline: 
Chairman: 
Committee on Education and the Workforce: 
House of Representatives: 

Dear Chairman Kline: 

The U.S. Department of Education (Education) created Race to the Top 
(RTT) to provide incentives for states to implement large-scale, far-
reaching reforms to improve student achievement, close achievement 
gaps, and increase graduation and college enrollment rates.[Footnote 
1] This program is part of the current administration's larger effort 
to ensure that students are college and career ready. RTT is the 
largest competitive grant fund ever administered by Education, and in 
2010, Education awarded nearly $4 billion in grant funds to 12 states. 
To be competitive for RTT grants, states had to demonstrate a 
commitment to reforming K-12 education across four interconnected 
areas: adopting standards and assessments, building data systems, 
supporting teachers and principals, and improving the lowest-achieving 
schools. Among the reforms related to teachers and principals, 
Education called for states and their participating school districts 
to improve teacher and principal effectiveness by developing 
evaluation systems that, in part, take into account data on student 
academic growth and inform personnel decisions, such as compensation, 
promotion, and retention.[Footnote 2] Education is also using other 
means to encourage reforms of teacher and principal evaluation 
systems. Currently, many non-RTT states and districts are designing 
and implementing evaluation systems to receive waivers from certain 
requirements of the Elementary and Secondary Education Act (ESEA) of 
1965, as amended.[Footnote 3] In addition, Education has prioritized 
evaluation system reform by setting a goal in its strategic plan to 
increase the number of states and districts that have comprehensive 
teacher and principal evaluation systems. More broadly, the current 
administration has included evaluation systems as an area of reform in 
its blueprint for revising ESEA. 

In 2011, we found that some states faced challenges implementing their 
RTT initiatives.[Footnote 4] We also found that states had made 
amendments to their RTT plans--including their evaluation systems--
such as changes to costs and timelines.[Footnote 5] You asked us to 
provide information about RTT grantees' progress toward implementing 
their teacher and principal evaluation systems. In this report, we 
examined (1) the extent to which the 2010 grantee states have 
implemented their teacher and principal evaluation systems; (2) the 
challenges the grantee states have faced in designing and implementing 
these systems; and (3) how Education has helped grantee states meet 
their RTT objectives for teacher and principal evaluation systems. 

In conducting this work, we focused on the 12 states that received RTT 
grant funds in 2010.[Footnote 6] We interviewed state officials from 
all 12 grantee states as well as school district officials in 
Maryland, New York, and North Carolina, either in person or by phone. 
We chose states that differed in terms of the flexibility they 
provided to districts to design their teacher and principal evaluation 
systems (Maryland and New York offer districts more flexibility, 
whereas North Carolina has a statewide evaluation system and offers 
districts less flexibility). In selecting these states, we also 
considered the RTT award amount and the percentage of students served 
by school districts participating in RTT. We interviewed a total of 12 
school districts in these three states. We asked state officials to 
identify districts that varied in terms of the design of their 
evaluation systems (if applicable) and the range of challenges they 
faced. Other criteria included whether a district was urban, suburban, 
or rural and the percentage of high-poverty or high-minority schools 
in the district.[Footnote 7] The views of these 12 districts cannot be 
generalized to all districts that participated in RTT, but they do 
provide important insights into some districts' experiences with RTT 
implementation. The state and district officials we interviewed 
provided information on the key components of their evaluation 
systems, the implementation status of these systems, what they 
considered to be their design and implementation challenges, and 
Education's monitoring activities and technical assistance. We also 
interviewed officials from unions or organizations representing 
teachers or principals in Maryland, New York, and North Carolina to 
obtain their perspectives on design and implementation challenges. 

In addition, we reviewed documents to obtain information on states' 
guidelines for the evaluation systems used by their districts, 
including each state's RTT application, teacher and principal 
evaluation system manuals, and progress reports developed by the 
states and Education. We also reviewed relevant federal laws, 
regulations, and guidance and interviewed Education officials from the 
Implementation and Support Unit, as well as officials from the 
contractor Education hired to provide technical assistance. We 
obtained data from the contractor on the number and types of technical 
assistance activities provided to RTT states. We assessed the 
reliability of data by interviewing agency officials knowledgeable 
about the data and determined that the data were sufficiently reliable 
for the purposes of this report. The American Recovery and 
Reinvestment Act of 2009 (Recovery Act) requires that we conduct 
bimonthly reviews of how the act's funds are used by selected states 
and localities.[Footnote 8] This report fulfills this requirement in 
that we examined the use of Recovery Act funds by the 12 states that 
were awarded RTT grants in 2010. 

We conducted this performance audit from August 2012 through September 
2013 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: 

RTT Overview: 

In accordance with Recovery Act requirements, Education established 
the RTT grant fund to encourage states to reform their K-12 education 
systems and to reward states for improving student outcomes, such as 
making substantial gains in student achievement and improving high 
school graduation rates. States competed for RTT grant funds based on 
reforms across four areas: 

* adopting standards and assessments that prepare students to succeed 
in college and the workplace and to compete in the global market; 

* building data systems that measure student academic growth and 
success and inform teachers and principals about how they can improve 
instruction; 

* recruiting, developing, rewarding, and retaining effective teachers 
and principals, especially where they are needed most; and: 

* turning around the lowest-achieving schools. 

Education awarded RTT grants in three phases. Twelve states received 
grants in 2010 in Phases 1 and 2 to support the design and 
implementation of their teacher and principal evaluation systems and 
other RTT reforms.[Footnote 9] Award amounts ranged from $75 million 
to $700 million (see table 1). States were required to subgrant at 
least 50 percent of their total grant award to districts that chose to 
participate in RTT. The 4-year grant period began on the date funds 
were awarded to the state. States must obligate all funds within that 
period, and they have 90 days following the end of their grant period 
to liquidate all obligated funds unless they receive a no-cost 
extension. Education may grant extensions for states beyond the 90 
days on a case-by-case basis.[Footnote 10] Any Phase 1 and Phase 2 
funds not obligated and liquidated by September 30, 2015, will revert 
to the U.S. Treasury. 

Table 1: Race to the Top Grant Awards, by Phase and Amount Awarded: 

Phase 1: 

State: Tennessee; 
Total amount awarded: $501 million; 
Date grant awarded: 7/26/2010; 
Expected end date: 7/25/2014. 

State: Delaware; 
Total amount awarded: $119 million; 
Date grant awarded: 6/11/2010; 
Expected end date: 6/10/2014. 

Phase 2: 

State: Florida; 
Total amount awarded: $700 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: New York; 
Total amount awarded: $697 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Georgia; 
Total amount awarded: $400 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Ohio; 
Total amount awarded: $400 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: North Carolina; 
Total amount awarded: $399 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Maryland; 
Total amount awarded: $250 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Massachusetts; 
Total amount awarded: $250 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: District of Columbia; 
Total amount awarded: $75 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Hawaii; 
Total amount awarded: $75 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Rhode Island; 
Total amount awarded: $75 million; 
Date grant awarded: 9/24/2010; 
Expected end date: 9/23/2014. 

State: Total; 
Total amount awarded: $3.941 billion. 

Source: Department of Education grant award notification letters. 

[End of table] 

Criteria for Awarding RTT Grants: 

Education identified 19 primary criteria to guide peer reviewers in 
the selection of states for RTT grants (see table 2).[Footnote 11] 

Table 2: Race to the Top State Selection Criteria: 

Category: A. State Success Factors; 

Criteria: (A)(1) Articulating state's education reform agenda and 
local educational agencies' participation in it. 

Criteria: (A)(2) Building strong statewide capacity to implement, 
scale up, and sustain proposed plans. 

Criteria: (A)(3) Demonstrating significant progress in raising 
achievement and closing gaps. 

Category: B. Standards and Assessments; 

Criteria: (B)(1) Developing and adopting common standards. 

Criteria: (B)(2) Developing and implementing common, high-quality 
assessments. 

Criteria: (B)(3) Supporting the transition to enhanced standards and 
high-quality assessments. 

Category: C. Data Systems to Support Instruction; 

Criteria: (C)(1) Fully implementing a statewide longitudinal data 
system. 

Criteria: (C)(2) Accessing and using state data. 

Criteria: (C)(3) Using data to improve instruction. 

Category: D. Great Teachers and Leaders; 

Criteria: (D)(1) Providing high-quality pathways for aspiring teachers 
and principals. 

Criteria: (D)(2) Improving teacher and principal effectiveness based 
on performance. 

Criteria: (D)(3) Ensuring equitable distribution of effective teachers 
and principals. 

Criteria: (D)(4) Improving the effectiveness of teacher and principal 
preparation programs. 

Criteria: (D)(5) Providing effective support to teachers and 
principals. 

Category: E. Turning Around the Lowest-Achieving Schools; 

Criteria: (E)(1) Intervening in the lowest-achieving schools and local 
educational agencies. 

Criteria:(E)(2) Turning around the lowest-achieving schools. 

Category: F. General Criteria; 

Criteria: (F)(1) Making education funding a priority. 

Criteria: (F)(2) Ensuring successful conditions for high-performing 
charter schools and other innovative schools. 

Criteria: (F)(3) Demonstrating other significant reform conditions. 

Source: 74 Fed. Reg. 59,688, 59,801-59,804 (Nov. 18, 2009). 

Note: In addition to these criteria, Education gave states the option 
to include other proposals in their plans, such as proposals to 
prepare more students for advanced study and careers in science, 
technology, engineering, and mathematics fields and proposals for 
states to work together to develop joint longitudinal data systems. 

[End of table] 

The criterion--improving teacher and principal effectiveness based on 
performance--established the RTT guidelines for teacher and principal 
evaluation systems. Reviewers evaluated the state's plan to ensure its 
participating RTT districts (1) measure student growth for each 
individual student; (2) design and implement evaluation systems, 
developed with teacher and principal involvement, that include 
multiple rating categories that take into account data on student 
growth as a significant factor; (3) evaluate teachers and principals 
annually and provide feedback, including student growth data; and (4) 
use these evaluations to inform decisions regarding professional 
development, compensation, promotion, retention, tenure, and 
certification.[Footnote 12] 

Education defines student growth as the change in student achievement 
for an individual student between two or more points in time. For 
students in grades and subjects that are tested by state standardized 
tests, Education defines student achievement as the score received on 
the state's assessments required under the ESEA. For students in 
grades and subjects that are not tested by state standardized tests, 
Education defines student achievement based on alternative measures of 
student learning and performance. These measures include student 
scores on pre-tests and end-of-course tests, student performance on 
English language proficiency assessments, and other measures of 
student achievement that are rigorous and comparable across 
classrooms. Student achievement for students in tested grades and 
subjects can also be assessed using other measures as appropriate, 
including the same measures as students in nontested grades and 
subjects. 

Education provided background information in its notice of proposed 
priorities, requirements, definitions, and selection criteria for RTT 
on why it included student growth as a factor in its criteria for 
teacher and principal evaluation.[Footnote 13] Education noted the 
difficulty in predicting teacher quality based solely on the 
qualifications that teachers bring to the job. The department cited 
research on the limited predictive power of measures such as 
certification, education, and years of experience, and research on the 
value of measuring student growth to assess teacher quality.[Footnote 
14] In response to public comments that expressed concern about the 
use of student growth data as the sole means to evaluate teachers and 
principals, Education revised its definitions of an effective teacher 
and effective principal to require that multiple measures be used to 
assess effectiveness, with student growth as a significant 
factor.[Footnote 15] Education also provided examples of these 
supplemental measures, such as multiple observation-based assessments 
of teacher performance and high school graduation rates as a measure 
for evaluating principals. 

Education also established criteria for peer reviewers to consider a 
state's capacity to sustain its reforms. The criterion--building 
strong statewide capacity to implement, scale up, and sustain proposed 
plans--required reviewers to assess the extent to which the state had 
a plan to ensure sufficient capacity and use stakeholder support to 
implement its plans. States were evaluated on, among other things, the 
extent to which they demonstrated that they would provide strong 
leadership and dedicated teams to implement the reforms and use their 
fiscal, political, and human capital resources to continue successful 
grant-funded reforms after RTT funds are no longer available. 
[Footnote 16] 

Role of the Department of Education: 

Education is responsible for fiscal and programmatic oversight of all 
aspects of RTT, reviewing and responding to states' requests to amend 
their RTT applications, and providing technical assistance. To monitor 
states' progress, Education established a program review process that 
includes ongoing conversations with grantees, on-site program reviews, 
grantee self-evaluations, and meetings with Education officials. As we 
reported previously, Education uses a common set of questions to 
oversee state progress and to address specific needs and challenges of 
each grantee.[Footnote 17] Education also publishes annual reports to 
the public summarizing the progress of each state. To provide 
technical assistance, Education established the Reform Support Network 
(RSN), a 4-year, $43 million technical assistance contract with ICF 
International, which works with Education to support RTT states. 
[Footnote 18] 

Education's process for reviewing and approving changes to a state's 
RTT plans includes reviewing the state's approved application, budget, 
and scope of work.[Footnote 19] According to Education's guidance, an 
RTT grantee must submit an amendment request for (1) a proposed 
revision that constitutes a change in activities from the approved 
grant project, regardless of budgetary impact; (2) budgetary changes, 
including transfers among categories or programs, that exceed $500,000 
of the current approved budget; or (3) changes to the list of 
districts participating with the grantee's RTT plan. Education will 
not approve amendment requests that would change the overall scope and 
objectives of the approved proposal, fail to comply with the terms of 
the award or the statutory and regulatory provisions of the program, 
or violate the general principles of the program.[Footnote 20] 

Education's Institute of Education Sciences' National Center for 
Education Evaluation and Regional Assistance is conducting two studies 
that relate to RTT teacher and principal evaluation systems. One study 
will assess the RTT and School Improvement Grant programs and whether 
these programs are related to improvement in student outcomes. The 
results of this study, which will not specifically assess the impact 
of teacher and principal evaluations on student outcomes, are expected 
in 2014. In the second study, experimental teacher and principal 
evaluation systems will be implemented in schools in eight districts 
in order to study their effects on factors such as student achievement 
and teacher and principal mobility.[Footnote 21] A report on this 
study is expected in 2015. 

Teacher and Principal Evaluation Systems in the RTT States: 

The RTT states provide districts with varying amounts of flexibility 
to develop their evaluation systems. For example, some RTT states 
developed evaluation systems for use by all districts, unless a 
district develops an alternate evaluation system that meets state 
requirements. In other states, districts can develop their own 
evaluation systems within guidelines provided by the state, and the 
state must approve each district's system.[Footnote 22] Whether the 
evaluation system is developed by the state or the district, districts 
evaluate teachers and principals using multiple measures that assess 
professional practice and student academic growth (see figure 1). 

Figure 1: Example Components of Race to the Top States' Evaluation 
Systems: 

[Refer to PDF for image: illustration] 

Example measures: 

* Classroom or school observation: Assessment of a teacher or 
principal on specific competencies with defined levels of performance. 

* Collection of evidence: Review of supporting documents, such as 
lesson or meeting plans. 

* Student perception or school climate survey: Assessment of school or 
classroom characteristics. 

Professional practice: 
Assessment of teachers or principals on specific areas of instruction
or leadership. 

Example measures: 

* Student academic growth model: Statistical model to measure a 
teacher’s or a principal’s effect on student learning, based on state 
standardized test scores. 

* State or district developed exams: Alternate assessments such as 
pre/post tests or end-of-course exams. 

* Student learning objectives (SLOs): Learning goals set by teachers 
or principals that use specific measures to track progress of groups 
of students. 

* Measures of collective performance: Schoolwide measures of academic 
growth. 

Student academic growth: 
Change in student achievement between two or more points in time. 

Overall effectiveness rating: 
Highly effective; 
Effective; 
Ineffective. 

Source: GAO analysis of RTT states’ documents. 

Note: This figure is intended to provide examples of the components 
used in RTT states' evaluation systems; some states may not use the 
components described, and some states may use other measures beyond 
those included. 

[End of figure] 

Six of 12 RTT States Fully Implemented Their Evaluation Systems by the 
2012-13 School Year: 

According to state officials, 6 of the 12 RTT states fully implemented 
both their teacher and principal evaluation systems by school year 
(SY) 2012-13 (see fig. 2), though their success in meeting their 
original target date for implementation varied. The states that fully 
implemented their systems evaluated all teachers and principals in RTT 
districts, according to state officials.[Footnote 23] The six states 
that fully implemented both teacher and principal evaluation systems 
targeted SY 2011-12 for full implementation in their RTT applications. 
Three of the six states met that target and SY 2012-13 was their 
second school year of full implementation. The other three states did 
not meet the targets set in their applications, but did fully 
implement their systems in SY 2012-13.[Footnote 24] According to 
Education's amendment approval letters, states shifted implementation 
time frames, in part, because they needed additional time to develop 
student academic growth measures. For example, Delaware required an 
additional year to develop measures for its student academic growth 
component, which state officials said resulted in a better evaluation 
system. 

Figure 2: Implementation Status for Race to the Top States' Evaluation 
Systems, School Year 2012-13: 

[Refer to PDF for image: illustrated table] 

Teacher evaluations: 
Delaware: Full implementation by all RTT districts; 
District of Columbia: Full implementation by all RTT districts; 
Florida: Full implementation by all RTT districts; 
Georgia: Pilot or partial implementation;
Hawaii: Pilot or partial implementation;
Maryland: Pilot or partial implementation;
Massachusetts: Pilot or partial implementation;
New York: Pilot or partial implementation;
North Carolina: Full implementation by all RTT districts; 
Ohio: Pilot or partial implementation;
Rhode Island: Full implementation by all RTT districts; 
Tennessee: Full implementation by all RTT districts. 

Principal evaluations: 
Delaware: Full implementation by all RTT districts; 
District of Columbia: Full implementation by all RTT districts; 
Florida: Full implementation by all RTT districts; 
Georgia: Pilot or partial implementation;
Hawaii: Full implementation by all RTT districts; 
Maryland: Pilot or partial implementation;
Massachusetts: Pilot or partial implementation;
New York: Pilot or partial implementation;
North Carolina: Full implementation by all RTT districts; 
Ohio: Pilot or partial implementation;
Rhode Island: Full implementation by all RTT districts; 
Tennessee: Full implementation by all RTT districts. 

Source: GAO analysis. 

Note: We categorized New York as partially implemented because the New 
York City Department of Education did not implement a state-approved 
evaluation system in SY 2012-13. According to state officials, the 
district accounts for approximately 34 percent of teachers and 
principals statewide. Officials from the New York City Department of 
Education stated they plan to implement their new evaluation system 
for the first time in SY 2013-14. 

[End of figure] 

The six states that did not fully implement both their teacher and 
principal evaluation systems in SY 2012-13 either piloted or partially 
implemented evaluation systems,[Footnote 25] according to state 
officials (see figure 2). Based on the targets set in their RTT 
applications, four of the six states originally planned to fully 
implement by SY 2012-13 but are instead piloting or partially 
implementing their systems.[Footnote 26] The proportion of teachers 
and principals participating in pilots varied. According to state 
officials, Hawaii's teacher evaluation pilot covered about 30 percent 
of its teachers, and Maryland's evaluation systems pilot covered about 
14 percent of its teachers and principals in RTT districts. Among the 
four districts we visited in Maryland, district officials said the 
percentage of teachers who participated in the districts' pilots 
ranged from about 4 percent to 100 percent.[Footnote 27] State or 
district officials in four of the six states expressed some concerns 
about their readiness for full implementation. For example, officials 
in one Maryland district that piloted with about 4 percent of teachers 
said they will move from learning about the system to full 
implementation without sufficient time to address issues that arose 
during the pilot. Similarly, officials in another Maryland district 
that piloted with about 5 percent of teachers and 19 percent of 
principals said the district did not have sufficient time to work with 
teachers and principals on the new evaluation systems and would have 
benefited from another pilot year. The Maryland district officials 
said that two individuals were responsible for all of the evaluation 
systems work. These officials added that they anticipate budget and 
staff reductions as they move from their pilot, in which about 100 
teachers and 10 principals were evaluated, to full implementation that 
will cover more than 3,000 people. 

According to RTT state officials, states are using or plan to use the 
results of their new teacher and principal evaluations to inform 
decisions regarding, among other things, professional development, 
compensation, and retention, in accordance with RTT.[Footnote 28] For 
example, North Carolina officials said districts used evaluation 
results to assign underperforming teachers to professional growth 
plans that are intended to help them improve their teaching abilities. 
If a teacher's evaluation results do not improve, that teacher may be 
dismissed or face other consequences. Officials in Delaware and 
Florida said their states used evaluation results in their first year 
of full implementation to inform personnel decisions for teachers and 
principals, such as retention rewards and dismissal. According to 
Hawaii officials, the state plans to fully implement its teacher 
evaluation system in SY 2013-14, but all consequences related to 
evaluations will be added the following school year. In several 
states, RTT districts decide how to use evaluation results to 
determine consequences. Ohio officials said that RTT districts were 
required to use evaluation results to inform some personnel decisions--
including professional development, retention, and pay for 
performance--and the state surveyed RTT districts to confirm that they 
did so. Tennessee officials said that RTT districts were required to 
use the results of evaluations to inform certain personnel decisions, 
such as employment, compensation, and dismissal, but that the state 
did not prescribe the consequences attached to different ratings. 

Most RTT States Cited Challenges with Developing and Using Certain 
Evaluation Measures, Addressing Teacher Concerns, and Building 
Capacity and Sustainability: 

RTT States Struggled to Develop and Use Student Learning Objectives 
and Assess Teacher Professional Practice Consistently: 

State or district officials in most RTT states (8 of the 12) said they 
had difficulty developing and using student learning objectives (SLOs) 
to assess student academic growth for teachers.[Footnote 29] SLOs 
measure student academic growth for teachers in nontested grades and 
subjects, which represent 65 to 75 percent of teachers nationwide, 
according to an RSN report. SLOs are learning objectives for groups of 
students, such as students in a social studies class, that use a 
specific measure, such as a course exam, to track academic progress 
throughout a school year.[Footnote 30] However, some RTT state and 
district officials said it can be difficult to ensure that these 
learning objectives are rigorous and accurately measure student 
learning. Tennessee officials said that while SLOs are popular and 
promising in theory, they are difficult to reliably implement because 
some teachers set non-rigorous goals in order to get high scores. 
Tennessee officials further explained that some teachers selected a 
schoolwide social studies score for their SLO measure--despite having 
no connection to the subject--because students did well on that exam, 
rather than selecting learning objectives relevant to their own 
subject matter. Officials in three Maryland districts said determining 
how to measure student academic growth using learning objectives was a 
challenge because, for example, they may have difficulty assessing 
students' abilities when they enter a class, not just when they leave. 
Officials in a New York district described the difficulty of 
implementing learning objectives in their small, rural district (see 
sidebar). Despite these challenges, RTT state and district officials 
said that SLOs improved their evaluation systems, in part by engaging 
teachers in the evaluation process and by leading to more in-depth 
discussions about teacher performance. To address some of their 
challenges, RTT states developed guidance, templates, or model 
learning objectives to help districts develop and use SLOs. In 
addition, states participated in an RSN-sponsored working group on 
developing SLOs. They could also access RSN guidance from Education's 
website that outlined the benefits of learning objectives and provided 
information about the elements that comprise rigorous, high-quality 
learning objectives.[Footnote 31] 

Side bar: 

Using Student Learning Objectives (SLOs) to Measure Student Academic 
Growth in a District with Few Students: 

Officials in a New York district explained that due to their 
district’s small student population, some teachers may work in several 
subjects and thus may require several SLOs for their different 
subjects. Other teachers who work in fewer subjects may only need one 
or two. District officials said this creates inequity among teachers 
because the evaluation process is more complex and time-consuming with 
each additional learning objective. In addition, district officials 
noted that teachers may be unable to meet the overall SLO goal if they 
have even one student who misses their student academic growth target. 
As a result, achieving the highest rating would be very difficult. 

[End of side bar] 

Some RTT state and district officials said it was difficult to ensure 
that principals assess teacher professional practice consistently. For 
example, officials said it was challenging to ensure consistency in 
how principals use classroom observations and other evidence, such as 
lesson plans, to assess a teacher's instructional methods.[Footnote 
32] State or district officials in 6 of the 12 RTT states expressed 
concerns that, for example, some principals may not be appropriately 
identifying teachers who were ineffective and rating them accordingly. 
[Footnote 33] Officials in a few of these states attributed this to 
principals lacking the skill to differentiate between effective and 
ineffective teachers, or the will to rate teachers in lower categories 
or to rate them lower than under the prior evaluation system. 
Officials in Tennessee and in two North Carolina districts said 
evaluation data have shown that some teachers with low scores on their 
student academic growth component received high professional practice 
ratings. They said this may indicate that some principals are 
inflating scores or not identifying lower-performing teachers and 
providing critical feedback. Officials in another North Carolina 
district described a different concern about the mismatch in 
professional practice ratings and student academic growth. They noted 
that student academic growth data are not available until the 
following year and might influence how some principals assess teachers 
in the year in which the data become available. For example, after 
receiving data that shows a teacher demonstrated good student academic 
growth the prior year, a principal might overlook poor classroom 
management when observing the teacher. Organizations representing 
teachers and principals also raised concerns about evaluation 
consistency (see sidebar). 

Side bar: 

Union Perspective on Evaluation Consistency: 

Officials from a state teachers’ union said they had concerns about 
whether the evaluations of principals will include measures that 
address a principal’s ability to appropriately evaluate teachers. 
Union officials noted that in general, teachers were concerned about 
how principals would be held accountable (i.e., who would be 
evaluating the principals). On the other hand, officials from a state 
principals’ association said that principals are concerned that their 
peers might evaluate teachers less rigorously so that their school 
report cards, which provide aggregate information on teacher ratings 
for individual schools, reflect higher scores. 

[End of side bar] 

State, district, or union officials in six RTT states described 
efforts to improve consistency in principals' evaluations of teachers, 
generally through training. In New York, officials from a state 
teachers' union said they provided training to more than 750 
principals on ensuring consistency when conducting teacher 
evaluations. Tennessee officials said that during the first year of 
implementation, principals participated in 4 days of training and had 
to pass a test in order to perform classroom observations. During the 
second year, Tennessee identified principals who did not evaluate 
teachers appropriately and provided them with additional support and 
coaches. Officials also said that Tennessee plans to make its 
certification test more rigorous. Officials in one North Carolina 
district said that, in addition to providing state training and 
workshops on evaluation consistency, district administrators conduct 
informal classroom walk-throughs to observe teachers and then discuss 
rating consistency while comparing their notes with the principal's 
observation ratings. 

Concerns about Magnitude of Change Challenged States' Efforts: 

State or district officials in 11 of the 12 RTT states discussed the 
difficulty of addressing teacher concerns about the scale of 
evaluation reform. According to these officials, teachers were 
concerned about some of the significant changes in the new systems, 
such as the use of student academic growth data in evaluations and 
using evaluation results to make personnel decisions (e.g., retention 
or compensation).[Footnote 34] For example, state, district, and union 
officials in Maryland said that teachers did not trust the validity of 
the state test scores used in some of the student academic growth 
measures. Officials in one New York district were concerned generally 
about the rise in annual testing and its use in evaluations to inform 
personnel decisions. District and union officials in New York said the 
release of teacher evaluation ratings to parents added to concerns 
about evaluation systems. Officials in one small district said their 
teachers were particularly concerned because protecting their 
anonymity might be difficult even if data are aggregated and not 
linked to individual teachers. Officials in three states and one 
district said they had difficulty convincing teachers that evaluation 
systems were focused on professional development, rather than 
consequences. Some RTT state and district officials said the 
simultaneous transition to new state assessments and the Common Core 
curriculum--a single set of educational standards in language arts and 
math--increased teacher concerns about consequences.[Footnote 35] For 
example, North Carolina officials said teachers were concerned about 
the fairness of measuring student academic growth while schools are 
implementing a new curriculum. In some RTT states, according to state 
and union officials, lengthy collective bargaining processes or 
lawsuits slowed implementation efforts.[Footnote 36] 

State and district officials said they took steps to address teacher 
concerns, in part by involving teachers in the design and 
implementation of the evaluation systems and through ongoing 
communication with teachers. State or district officials in 10 of the 
12 RTT states highlighted efforts such as teacher participation on 
committees that designed the systems, teacher involvement in national 
training workshops, and regular communication and feedback from 
teachers on implementation. In addition, officials from all three 
state organizations representing teachers said they helped develop the 
legal framework or overarching standards for their states' evaluation 
systems and participated on committees or provided training to 
teachers and principals to support their state's efforts. To reduce 
teacher concerns once reform efforts were under way, officials in 
Maryland regularly distributed a document to key stakeholders that, 
among other things, provided updates related to evaluation components. 
Officials in Georgia said they made presentations in the community, 
held focus groups in districts, and provided training to help manage 
the culture shift to the new evaluation system. 

State or district officials in most RTT states (9 of the 12) said they 
faced fewer concerns related to principal evaluations due to greater 
principal support, the smaller scale of implementation, or because 
principals were used to being evaluated based on student performance. 
According to North Carolina officials, superintendents used student 
academic growth in principal evaluations prior to RTT, so principals 
did not have the same level of concern as teachers. In addition, North 
Carolina officials noted that the state had 2,600 administrators 
compared to 95,000 teachers, which made principal evaluation easier to 
implement. Hawaii officials said implementing principal evaluations 
was a generally collaborative and productive process for several 
reasons. For instance, they said principal associations were 
relatively easy to work with, administrator assessments already 
existed, and principals understood the need for a new evaluation 
system and contributed significantly to its design. In another state, 
officials from a principals' association echoed the view that 
principals were accustomed to being evaluated on student academic 
growth and added that principals in their state were more concerned 
about teacher evaluations than their own evaluations. 

States Took Steps to Address Insufficient Capacity: 

Insufficient state and district capacity challenged RTT states' 
efforts to design and implement their evaluation systems (see figure 
3).[Footnote 37] State or district officials in most of these states 
said they lacked either sufficient staff or needed expertise when they 
began to reform their evaluation systems. Some state officials also 
said they faced capacity challenges related to supporting district 
efforts, such as reviewing and approving district evaluation systems 
and providing technical assistance. For example, Florida officials 
said that, because their RTT districts had the flexibility to design 
their own systems, it was difficult to develop solutions to challenges 
that would be applicable to all RTT districts.[Footnote 38] State and 
district officials said that at the local level, districts had 
difficulty managing principal workloads or prioritizing evaluation 
reform amid multiple educational initiatives. For example, officials 
in a New York district said that the time commitment required for 
observing and evaluating teachers prevented some principals from 
thoroughly reviewing evidence submitted for evaluations or providing 
meaningful feedback to teachers. District officials in New York and 
Maryland told us that their evaluation reform efforts took precedence 
over other initiatives, such as implementation of the Common Core 
curriculum. Building capacity to enact education reforms has been a 
recurring challenge for states and districts, as we have discussed in 
previous reports.[Footnote 39] 

Figure 3: Capacity Challenges Faced by Race to the Top States: 

[Refer to PDF for image: horizontal bar graph] 

Difficulty with Building staff size or expertise: 11 states; 
Difficulty with Supporting district efforts: 5 states; 
Difficulty with Managing principal workloads: 8 states; 
Difficulty with Prioritizing evaluation reform amid multiple 
educational initiatives: 6 states. 

Source: GAO analysis of state and district interviews. 

Note: Officials in 8 of the 12 districts we spoke with discussed 
building staff size or expertise, managing principal workloads, and 
prioritizing evaluation reform as challenges. State officials noted 
that supporting district efforts was a challenge. 

[End of figure] 

While RTT was designed to encourage education innovation and reform--
rather than covering all costs of reform efforts--several state and 
district officials cited the high cost of designing and implementing 
evaluation systems as a challenge.[Footnote 40] For example, officials 
in Hawaii and Delaware (see sidebar) noted that they underestimated 
how much it would cost to develop these systems. Similarly, officials 
in 7 of the 12 districts we spoke with said their RTT funds did not 
cover the costs of reforming their evaluation systems. For example, 
one small, rural New York district spent about $62,400 on its teacher 
and principal evaluation systems in addition to the $22,856 it 
received in RTT funds. Other New York districts faced similar 
challenges. A 2011 survey conducted by the New York State Council of 
School Superintendents shows that 81 percent of responding 
superintendents were concerned that cost considerations might prevent 
their districts from soundly implementing new evaluation requirements. 
Cost may have been more of a challenge for some districts because they 
were responsible for a significant part of the design and 
implementation work. Six of the 7 districts in which officials raised 
cost as a capacity challenge were in Maryland and New York, both of 
which provide RTT districts with significant flexibility to design 
their own systems. Officials in Tennessee explained that some RTT 
districts in their state did not have funding concerns because they 
used the evaluation system and data system provided by the state. 

Side bar: 

One Race to the Top State’s Cost Challenge: 

According to Delaware officials, the state underestimated the cost of 
designing its evaluation system, particularly the development of 
student academic growth measures. Because the state’s initial plan did 
not require the development of additional measures, the state did not 
budget any funds for that work. However, the state later revised its 
approach and decided to create assessments or growth goals for all 
courses taught throughout the state. Education approved the state’s 
amendment request to shift $600,000 from other projects for this 
effort and to delay full implementation of the state’s evaluation 
systems by 1 year. The state also contributed an additional $1.1 
million in state funds to do this work. 

[End of side bar] 

States and districts responded to capacity challenges through 
different efforts to supplement their staff and resources (see figure 
4). Several RTT states also submitted amendment requests and received 
approval from Education to shift funds among RTT projects to provide 
additional funding for particular aspects of their evaluation systems. 
For example, Tennessee shifted approximately $1.1 million to support, 
among other things, additional training on evaluation systems because 
the state did not originally estimate sufficient funds for this 
purpose. Similarly, New York increased its budget for its evaluation 
systems by $11.9 million by shifting funds to develop its student 
academic growth model, pilot evaluation system software, and provide 
additional resources to districts. 

Figure 4: Examples of Race to the Top State and Selected District 
Efforts to Address Capacity Challenges: 

[Refer to PDF for image: illustration] 

New York: Used the state’s regional educational organizations to lead 
networking and professional development, as well as to encourage 
regional approaches and collaboration in developing evaluation systems. 

Massachusetts: Shifted existing staff to evaluation work, hired 
additional staff, and submitted amendment request and received 
approval from Education to reallocate funds from other Race to the Top 
projects to support additional staff for evaluation systems work. 

Rhode Island: Established intermediate service providers to support 
specific implementation tasks (e.g., developing student learning 
objectives). 

Georgia: Submitted amendment request and received approval from 
Education to reallocate funds from other Race to the Top projects to 
support additional staff for evaluation systems work. 

North Carolina: Two districts used retired principals or district 
headquarters staff to help principals that fell behind on observations. 

Hawaii: Added labor relations staff to assist principals. 

Source: GAO analysis of state and district interviews. 

[End of figure] 

Finding Resources to Replace RTT Funds Challenges States' 
Sustainability Efforts: 

State or district officials in most RTT states (10 of the 12) said 
that fewer staff or other resources after RTT grant funds are no 
longer available could affect their ability to sustain their 
evaluation systems. For example, Rhode Island officials said they will 
likely lose staff that they hired using RTT funds because the state 
may not be able to use other education funds to make these positions 
permanent. Officials in New York said that with the loss of RTT 
funding, the state will have fewer staff to review district evaluation 
plans every year and to provide technical assistance to districts, as 
well as to manage the analysis of statewide evaluation data. District 
of Columbia officials were concerned that without RTT funds, they 
would be unable to pay the contractor that operates the student 
academic growth model used by its charter school districts. 

Officials from all 12 RTT states said they are considering how to 
sustain their evaluation systems after RTT grant funds are no longer 
available. Officials in a few of these states discussed some of the 
difficulties they have faced in preparing for sustainability, such as 
turnover in state leadership and uncertainty over future funding 
levels, and a few officials provided examples of how they might 
address sustainability. For example, Hawaii officials said they are 
considering how to reallocate funds to sustain the systems but are 
concerned about the availability of other federal and state funds to 
do so. Georgia officials said they are collaborating with stakeholders 
to develop a sustainability plan--to be completed in summer 2013. In 
addition, Florida officials said they were working to ensure that they 
have in-house expertise on all aspects of the evaluation systems. For 
example, contractors who assisted with the state's student academic 
growth component will train state staff on how to run the models. 

Officials in 5 of the 12 RTT states told us more information from 
Education could help address their concerns about sustaining their 
evaluation systems and other reforms after RTT grant funds are no 
longer available. Specifically, state and district officials from some 
of these states told us they were concerned about or would like 
guidance on how to use other federal funds to support their evaluation 
systems. For example, officials in one state said Education issued 
some guidance on acceptable uses of ESEA funding, but could provide 
more concrete information on how best to leverage those funds for RTT 
initiatives. In addition, Education officials told us a few states 
have requested technical assistance to support their sustainability 
planning. Officials from four states told us it was too soon for them 
to know whether they would need Education's assistance with 
sustainability. 

Education Supports RTT State Implementation Efforts through Monitoring 
and Technical Assistance: 

Education Monitors States Using a New Process to Hold Them Accountable 
for Quality of Implementation: 

Education developed a new process to monitor RTT states' progress 
toward meeting their RTT goals, including those related to teacher and 
principal evaluation systems.[Footnote 41] Education officials said 
that the RTT monitoring process differs from the department's other 
monitoring efforts in that Education has more frequent contact with 
the states in order to identify and address implementation challenges. 
In addition, the new process emphasizes states' continuous improvement 
and quality of RTT reforms, rather than focusing solely on compliance 
with laws and regulations and the ability of states to meet their time 
frames.[Footnote 42] Officials said the intensity of communication 
with RTT states and the quality standards are greater for RTT than for 
Education's previous monitoring efforts. Education developed the new 
process to provide assistance to RTT states as they implement 
comprehensive reforms and to differentiate support based on individual 
state needs. 

Education officials said they work to identify and address obstacles 
to the goals states established in their RTT plans through ongoing 
communication, including monthly monitoring calls, the amendment 
consideration process, and other contacts with RTT state officials. To 
assess the quality of implementation efforts, officials said they 
consider each state's progress toward its goals and timelines, risk 
factors and strategies for addressing them, and the state's own 
assessment of its quality of implementation, among other factors. For 
example, in addition to verifying that a state implemented an 
evaluation tool, such as a test or performance measure, Education 
officials work with the state to ensure that the tool is meeting the 
state's needs. Instead of focusing solely on RTT compliance, program 
officers also help identify areas in which Education can assist states 
in meeting their goals, according to Education officials. 

Officials from 8 of the 12 RTT states expressed generally positive 
views about Education's RTT monitoring activities. Some said, for 
example, that Education officials were collaborative, well-informed, 
and that they generally provided useful feedback. For example, 
officials from one state said that Education staff were very detailed 
and thorough in monthly monitoring calls and that they usually 
provided actionable feedback. Officials from another state said they 
spoke almost daily with Education officials and received strong 
support. They noted that, as a result, monitoring reviews were not 
stressful, and they were not surprised by the results. Officials from 
another state said they appreciated the discussion with Education 
officials about the state's amendment requests and how Education 
worked with them to ensure that the state maintained its original RTT 
goals. 

While RTT state officials expressed generally positive views about the 
monitoring process overall, officials in nine states expressed 
concerns about specific aspects of the process, including delays in 
the amendment process, time-consuming monthly calls and related 
requirements, and slow feedback from Education after site visits. 
Officials from one state said monitoring requirements seemed more 
burdensome than those for other federal education programs. Education 
officials stated that they have revised some aspects of their 
monitoring process in response to state feedback. For example, they 
modified the monthly monitoring call and onsite review protocols, 
revised the amendment process and dollar threshold amounts that 
require approval, and worked to explain the rationale and use of the 
information Education requests. 

To ensure that states are held accountable for meeting their RTT goals 
for teacher and principal evaluation systems, Education may take the 
following corrective actions for states that have not demonstrated 
adequate progress in implementing their systems: 

* Conditional amendment approval. If Education has concerns about a 
state's requested amendments to its RTT plans, it may grant 
conditional approval, requiring the state to provide additional 
information over a period of time. For example, Rhode Island submitted 
a proposed amendment requesting a change related to its use of SLOs. 
Education approved the request on the condition that the state provide 
additional information, such as quarterly progress updates during SY 
2012-13 and additional reports.[Footnote 43] In addition, Maryland 
received approval to decrease the percentage of the evaluation 
component that is based on student academic growth models on the 
condition that the state provide Education a plan for a statewide 
field test of its evaluation systems. Maryland was also required to 
commit to measuring student academic growth using common assessments 
of high school teachers and principals when those assessments are 
available, among other requirements. Education may also elect not to 
approve an amendment request. 

* High-risk status. Education placed 2 of the 12 RTT states--Georgia 
and Hawaii--on high-risk status because officials determined that the 
states required intensive attention and support in order to meet their 
RTT goals.[Footnote 44] In July 2012, Education placed the teacher and 
principal evaluation portion of Georgia's RTT grant on high-risk 
status because officials were concerned about the overall strategic 
planning, evaluation, and project management of the evaluation system. 
Education officials also expressed concern that Georgia had requested 
two major amendments that seemed to constitute significant changes to 
the evaluation system in the state's approved plan. As a result of the 
high-risk designation, Georgia was required to provide Education a 
revised work plan for its system, monthly updates in accordance with 
the work plan, and related information. As of July 2013, Education 
officials said the evaluation system portion of Georgia's RTT grant 
remains on high-risk status because of Education's continued concerns 
about the quality of implementation. In December 2011, Education 
designated Hawaii's entire RTT grant as high-risk because the state 
experienced major delays and made inadequate progress on implementing 
its systems and because the scope and breadth of amendment requests 
indicated a potentially significant shift in the state's approved 
plans. Education temporarily placed Hawaii on a cost-reimbursement 
basis, which required the state to submit receipts for expenditures to 
the department prior to drawing down grant funds. The state was also 
required to submit documentation prior to obligating funds and to 
submit a revised scope of work and budget. As of July 2013, Education 
had removed Hawaii's high-risk designation based on the state's 
demonstrated progress in implementing its RTT reforms, including its 
evaluation systems. 

* Additional information. Education has required certain reporting or 
follow-up information, other than that included in conditional 
approval of amendments or high-risk status, and has used other 
measures deemed appropriate. For example, according to Education 
officials, one state that experienced procurement problems is required 
to provide monthly procurement information to Education. 

* Withholding of funds. Although Education may withhold grant funds 
from states if they do not comply with the terms of the award, 
[Footnote 45] Education officials said they have not withheld funds 
from any RTT state. Officials added that states have always 
demonstrated progress toward addressing Education's concerns. 

Education Provides Technical Assistance to Help States Resolve 
Implementation Issues: 

Education helps states meet their RTT goals and implement high-quality 
reforms by providing technical assistance, including access to experts 
and information on options for evaluation systems. Education officials 
said technical assistance helps states resolve implementation issues, 
including those identified through the monitoring process. Most RTT 
federal assistance is provided by the contractor-supported RSN, and 
Education also provides some technical assistance to RTT states. 
[Footnote 46] RSN officials said they work closely with Education 
staff to learn about the types of technical assistance that might be 
useful to states on teacher and leader effectiveness, including 
teacher and principal evaluations, as well as other RTT topics. 

From 2010 through March 2013, RSN provided technical assistance on 
teacher and leader effectiveness in group settings--such as webinars 
and in-person meetings--to RTT states, as well as individualized 
technical assistance (see figure 5). RSN officials said they provide 
individualized assistance to states when requested, particularly for 
states in more advanced stages of implementation with needs that could 
not be met through larger group technical assistance activities. RSN 
also developed publications related to teacher and leader 
effectiveness, including case studies, tool kits, and lessons learned, 
and has provided them through the RTT grantee web portal. These 
publications included longer reports on school reform and shorter 
briefs, such as a paper that described rules governing classroom 
observations used in teacher evaluations in selected RTT states. 

Figure 5: Cases of Technical Assistance Provided by the Reform Support 
Network to Race to the Top States on Teacher and Leader Effectiveness, 
Calendar Years 2010-2013: 

[Refer to PDF for image: vertical bar graph] 

Group assistance: 19: 
Working groups: 4; 
In-person meetings: 4; 
Webinars: 11. 

Individualized assistance: 15. 

Publications: 12. 

Source: GAO analysis of Reform Support Network data. 

Note: Figure reflects assistance provided through March 2013. RSN 
provided the 15 cases of individualized technical assistance to 6 of 
12 RTT states upon request. 

[End of figure] 

RSN has worked to strengthen the quality of its technical assistance 
and adapt to states' changing needs, according to Education and RSN 
officials. They said that early in the contract, RSN revised its 
approach to better meet the needs of states. For example, in response 
to state feedback, RSN provided states with access to education 
practitioners who had worked in schools rather than experts without 
hands-on experience, as they had done in the initial stages of the 
contract. RSN officials also said issues for which states requested 
technical assistance changed as implementation progressed, and RSN 
adapted its technical assistance accordingly. For example, early in 
implementation, states often requested assistance with designing 
evaluation systems, communicating with stakeholders, working with 
unions, and measuring growth in nontested grades and subjects, 
according to RSN officials. As implementation progressed, states 
requested assistance with issues such as the consistency of 
observations and the sustainability of evaluation systems. 

Officials from 10 of the 12 RTT states told us that Education's 
technical assistance related to teacher and principal evaluation 
systems was generally helpful, and officials in several states said 
assistance had improved since the start of the contract. Officials 
from Hawaii said RSN had helped states by sharing existing knowledge 
and developing new information. Officials in Massachusetts told us 
that RSN's in-person meetings had been especially helpful because they 
provided a platform for states to share best practices. Although most 
states were complimentary of RSN assistance, officials in some states 
said RSN and Education could improve technical assistance by providing 
additional information on specific topics, such as information about 
states that have successfully implemented evaluation systems and more 
opportunities to share lessons learned. 

A recent survey by RSN also indicates that states are generally 
satisfied with the contractor's technical assistance on teacher and 
principal evaluation systems. In March 2013, RSN surveyed and obtained 
responses from officials in all RTT states regarding their perception 
of technical assistance, including assistance provided through the 
teacher and leader effectiveness community of practice.[Footnote 47] 
Sixteen of the 18 states that participated in teacher and leader 
effectiveness assistance reported that they were satisfied or very 
satisfied with the assistance, and the remaining states were neutral. 
On multiple dimensions, the state officials rated assistance with 
teacher and leader effectiveness higher than other areas and higher 
than RSN activities overall.[Footnote 48] States also identified 
opportunities for strengthening technical assistance by ranking 
potential topics on the basis of impact and urgency. For teacher and 
leader effectiveness, states ranked continuous improvement of teacher 
evaluation as one of the top areas of interest, according to RSN. 
Officials in a few states mentioned that they would like more 
opportunities to collaborate and learn from one another. 

Education Plans to Provide RTT States and Nongrantees Additional 
Information to Support State Efforts: 

Education plans to provide information to RTT states on sustaining 
teacher and principal evaluation systems and other reforms, but 
Education officials said they have not yet done so. Education planned 
to launch a new workgroup in the summer of 2013 to help states 
consider how to sustain their evaluation systems after the RTT grant 
ends. Draft plans for the work group included providing expert and 
peer-to-peer support and developing a sustainability rubric. The plans 
also included providing workshops on sustainability efforts, including 
ones on state capacity, performance management, and communication, and 
eventually developing and sharing case studies. In July 2013, 
Education officials said they had postponed work in this area until 
fall 2013. Although Education has not asked states to provide specific 
plans for addressing sustainability, department officials said they 
have learned about state plans through ongoing communication with 
states. For example, a few states discussed their sustainability 
planning during monthly monitoring calls. In addition, Education 
obtained information on state sustainability strategies through RTT 
applications. In general, states provided this information on RTT 
reforms as a whole. We did not identify any states as having provided 
a sustainability strategy specific to teacher and principal evaluation 
systems. 

To allow states more time to accomplish the goals and deliverables 
they committed to in their RTT plans, Education officials will 
consider requests for no-cost extensions, but they have not determined 
how to provide technical assistance during the extension period. 
States may request extensions on a case-by-case basis for more time to 
spend awarded funds for those aspects of their RTT reforms that 
require additional work. If approved, a state could have until 
September 30, 2015 to obligate and liquidate its remaining RTT grant 
funds.[Footnote 49] According to Education officials, states that 
request no-cost extensions will be required to provide to Education 
their plans to address sustainability, among other information. As of 
July 2013, Education officials had approved two no-cost extensions 
related to teacher and principal evaluation systems, and officials in 
an additional state told us they had submitted an extension request 
related to their evaluation systems. Officials in 6 more of the 12 RTT 
states told us they are considering requesting extensions related to 
their evaluation systems. However, it is not clear what technical 
assistance would be available to states approved for no-cost 
extensions. The current contract for technical assistance ends in 
September 2014, and RSN officials said they do not have plans to 
sustain technical assistance beyond the duration of the current 
contract. Education officials said they were working to identify 
options for providing continued technical assistance. 

Education has provided some information on RTT lessons learned to RTT 
and nongrantee states, including information on certain aspects of 
evaluation systems. Education has taken steps to provide nongrantee 
states with access to promising practices through the department's 
existing mechanisms, including the secure RTT grantee website and 
communities of practice, as we recommended in our 2011 
report.[Footnote 50] RSN officials said they were in the process of 
developing public access to the RSN web portal to allow nongrantee 
states to access some, but not all, materials. In the meantime, 
nongrantees can access some information through Education's website, 
including materials generated through communities of practice and 
individualized technical assistance. Education posts to its website 
annual reports for each RTT state that include information on lessons 
learned. Education's RTT staff also said they collaborated with other 
Education program officials on a series of webinars for all states, 
including one on SLOs and another on schoolwide student academic 
growth data. In addition to the materials currently available, 
Education officials told us that they were developing additional 
resources and materials on topics such as SLOs, observation rubrics, 
rating inflation, teacher engagement, data analytics, and leadership 
development. Education identified some products for targeted 
dissemination and presented them in conferences, cross-program 
meetings, and to organizations such as the National Governors 
Association, in order to promote awareness of the resources available. 
Education is also working to develop a more robust dissemination plan 
that includes ways to reach people other than state-level leaders, 
according to officials. 

Concluding Observations: 

Education created the RTT grant program to encourage sweeping changes 
in K-12 education. RTT spurred changes to the way states and districts 
evaluate their teachers and principals, particularly with the addition 
of student academic growth data as a factor in assessing 
effectiveness. Education has been proactive in monitoring states' 
progress in implementing their evaluation systems, and the 
department's continued monitoring and assistance will be important to 
help RTT states overcome challenges and implement the reforms to which 
they committed. In addition, Education's new monitoring process has 
resulted in a wealth of information on states' efforts. As a result, 
Education is uniquely positioned to use the lessons learned from RTT 
states to inform other states' efforts to improve teacher 
effectiveness and ultimately raise student academic achievement. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Department of Education for 
review and comment. Their comments are reproduced in appendix I. 
Education also provided technical comments, which we incorporated into 
the report. 

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

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

Sincerely Yours, 

Signed by: 

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

[End of section] 

Appendix I: Comments from the U.S. Department of Education: 

United States Department of Education: 
Office of The Deputy Secretary: 
400 Maryland Ave. S.W. 
Washington, DC 20202: 

August 28, 2013: 

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

Dear Mr. Scott: 

I am writing in response to the Government Accountability Office (GAO) 
draft report, "Race to the Top: States Implementing Teacher and 
Principal Evaluation Systems despite Challenges" (GAO-13-777). We 
appreciate the time that your office devoted to preparing this report 
and, in particular, the efforts that were made to describe the 
Department's work in ensuring that states are held accountable for 
meeting their Race to the Top goals, including those for teacher and 
principal evaluation systems. 

We also appreciate the opportunity to provide comments on this draft 
report. We provide technical comments in the enclosure. We hope you 
find these helpful. Thank you again for your work and the 
opportunities we have had to provide clarifying comments throughout 
your process. We look forward to receiving the final report. 

Sincerely, 

Signed by: 

Ann Whalen: 
Director, Policy and Program Implementation: 
Implementation and Support Unit: 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George A. Scott, Director (202) 512-7215 or scottg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Elizabeth Morrison, Assistant 
Director, Nisha R. Hazra, Marissa Jones, and Michael Kniss made 
significant contributions to this report. Also contributing to this 
report were Deborah Bland, Sarah Cornetto, Jamila Jones Kennedy, Amy 
Moran-Lowe, Jean McSween, Mimi Nguyen, Jason Palmer, Kathleen van 
Gelder, and Rebecca Woiwode. 

[End of section] 

Related GAO Products: 

Department of Education: 

School Improvement Grants: Education Should Take Additional Steps to 
Enhance Accountability for Schools and Contractors. [hyperlink, 
http://www.gao.gov/products/GAO-12-373]. Washington, D.C.: April 11, 
2012. 

Race to the Top: Characteristics of Grantees' Amended Programs and 
Education's Review Process. [hyperlink, 
http://www.gao.gov/products/GAO-12-228R]. Washington, D.C.: December 
8, 2011. 

Race to the Top: Reform Efforts are Under Way and Information Sharing 
Could Be Improved. [hyperlink, 
http://www.gao.gov/products/GAO-11-658]. Washington, D.C.: June 30, 
2011. 

Department of Education: Improved Oversight and Controls Could Help 
Education Better Respond to Evolving Priorities. [hyperlink, 
http://www.gao.gov/products/GAO-11-194]. Washington, D.C.: February 
10, 2011. 

Grant Monitoring: Department of Education Could Improve Its Processes 
with Greater Focus on Assessing Risks, Acquiring Financial Skills, and 
Sharing Information. [hyperlink, 
http://www.gao.gov/products/GAO-10-57]. Washington, D.C.: November 19, 
2009. 

Student Achievement: Schools Use Multiple Strategies to Help Students 
Meet Academic Standards, Especially Schools with Higher Proportions of 
Low-Income and Minority Students. [hyperlink, 
http://www.gao.gov/products/GAO-10-18]. Washington, D.C.: November 16, 
2009. 

No Child Left Behind Act: Enhancements in the Department of 
Education's Review Process Could Improve State Academic Assessments. 
[hyperlink, http://www.gao.gov/products/GAO-09-911]. Washington, D.C.: 
September 24, 2009. 

Teacher Quality: Sustained Coordination among Key Federal Education 
Programs Could Enhance State Efforts to Improve Teacher Quality. 
[hyperlink, http://www.gao.gov/products/GAO-09-593]. Washington, D.C.: 
July 6, 2009. 

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.: September 
30, 2004. 

Recovery Act: 

Recovery Act: Opportunities to Improve Management and Strengthen 
Accountability over States' and Localities' Uses of Funds. [hyperlink, 
http://www.gao.gov/products/GAO-10-999]. Washington, D.C.: September 
20, 2010. 

Recovery Act: One Year Later, States' and Localities' Uses of Funds 
and Opportunities to Strengthen Accountability. [hyperlink, 
http://www.gao.gov/products/GAO-10-437]. Washington, D.C.: March 3, 
2010. 

Recovery Act: Status of States' and Localities' Use of Funds and 
Efforts to Ensure Accountability. [hyperlink, 
http://www.gao.gov/products/GAO-10-231]. Washington, D.C.: December 
10, 2009. 

[End of section] 

Footnotes: 

[1] The American Recovery and Reinvestment Act of 2009 (Recovery Act) 
established the State Fiscal Stabilization Fund and required Education 
to use it for, among other purposes, "State Incentive Grants" to 
states that make significant progress in meeting specified education-
related objectives. Pub. L. No. 111-5, §14006, 123 Stat. 115, 283. 
Education subsequently established the Race to the Top grant fund to 
implement this provision. 

[2] Throughout this report, we use the term student academic growth to 
mean student growth, as defined by Education for the purposes of RTT. 
In addition, we use the term school districts or districts to refer to 
local educational agencies. 

[3] Under the ESEA, as amended, states and school districts may 
request a waiver of certain ESEA requirements from the Secretary of 
Education. 20 U.S.C. § 7861. To receive the waivers, Education 
requires states and districts to implement certain programs and 
policies, including the development and implementation of teacher and 
principal evaluation and support systems that meet criteria similar to 
those used for RTT. As of August 5, 2013, in addition to the 12 RTT 
states in our review, 28 states were approved for ESEA waivers, and 
requests from 8 additional states (including Puerto Rico and the 
Bureau of Indian Education) were under review, according to 
information on the Department of Education's website, [hyperlink, 
http://www.ed.gov/esea/flexibility]. 

[4] GAO, Race to the Top: Reform Efforts are Under Way and Information 
Sharing Could Be Improved, [hyperlink, 
http://www.gao.gov/products/GAO-11-658] (Washington, D.C.: June 30, 
2011). 

[5] GAO, Race to the Top: Characteristics of Grantees' Amended 
Programs and Education's Review Process,,AO-12-228R (Washington, D.C.: 
Dec. 8, 2011). 

[6] Throughout this report, we refer to the District of Columbia as a 
state. 

[7] We used the National Center for Education Statistics' Common Core 
of Data to examine these different characteristics. We assessed 
relevant documentation to determine that these data were sufficiently 
reliable for our purposes. 

[8] Pub. L. No. 111-5, § 901, 123 Stat. 115, 191. 

[9] In 2011, Education granted funds to seven additional states in 
Phase 3 of RTT. Phase 3 grantees were chosen from those that applied 
for but did not receive funds in Phase 2. Education has also awarded 
other RTT grants since the inception of RTT, including those under the 
Assessment, Early Learning Challenge, and District programs. 
Subsequent appropriations provided funding for some of these 
additional RTT grants. See, for example, Department of Education 
Appropriations Act, 2012, Pub. L. No. 112-74, div. F, tit. III, 125 
Stat. 786, 1093 (2011) and Department of Defense and Full-Year 
Continuing Appropriations Act, 2011, Pub. L. No. 112-10, § 1832(a)(2), 
125 Stat. 38, 163. This study only includes states funded through 
Phases 1 and 2 because these states have had more time to design and 
implement their evaluation systems. 

[10] 34 C.F.R. § 80.23. 

[11] Race to the Top Fund, 74 Fed. Reg. 59,688 (Nov. 18, 2009). In 
awarding the RTT grants, Education used a peer review process to 
evaluate applications. At Education's invitation, over 1,500 
prospective reviewers applied or were nominated to review Phase 1 RTT 
applications. Education ultimately selected 58 reviewers. 

[12] In their RTT applications, states provided a narrative response 
and other supporting information, such as a budget and implementation 
timelines. See 74 Fed. Reg. 59,688, 59,803 (Nov. 18, 2009), criterion 
(D)(2) for Education's complete criteria related to teacher and 
principal evaluation. 

[13] Race to the Top Fund, 74 Fed. Reg. 37,804 (July 29, 2009). 

[14] See 74 Fed. Reg. 37,804, 37,806 (July 29, 2009) for the specific 
studies Education cited. We did not assess the validity of these 
studies. 

[15] 74 Fed. Reg. 59,688, 59,750-51 (Nov. 18, 2009). 

[16] See 74 Fed. Reg. 59,688, 59,801 (Nov. 18, 2009), criterion (A)(2) 
for Education's complete criteria related to state capacity. 

[17] [hyperlink, http://www.gao.gov/products/GAO-11-658]. 

[18] ICF International is a consulting firm that provides professional 
services and technology solutions to government and commercial clients. 

[19] Education's regulations require grantees to obtain prior written 
approval from the department for certain changes. 34 C.F.R. § 80.30. 
In addition, Education provided specific guidance to RTT grantees on 
the circumstances for and types of allowable amendment requests for 
the program. 

[20] For more information on Education's RTT amendment process, see 
[hyperlink, http://www.gao.gov/products/GAO-12-228R]. 

[21] Officials from the Institute of Education Sciences said they 
chose districts that did not have in place or did not plan to 
implement evaluation systems similar to the experimental evaluation 
systems. 

[22] In this report, when we discuss a state's evaluation systems, we 
are referring to the evaluation systems implemented by RTT districts 
in that state. 

[23] We considered a state's evaluation systems to be fully 
implemented if, according to state officials, all districts 
participating in RTT evaluated all of their teachers or principals 
using the major components of their new evaluation systems, even if 
not all assessment measures within the major components were used for 
every teacher or principal. We also considered evaluation systems to 
be fully implemented even if they were not used to inform personnel 
decisions or if some nonacademic staff, such as music teachers or 
district administrators, were evaluated differently while the state 
determined how to assess student academic growth for them. 

[24] All three of these states--Delaware, North Carolina, and Rhode 
Island--submitted amendment requests to Education regarding timeline 
shifts, and Education approved these changes. 

[25] We considered an evaluation system to be piloted if, according to 
state officials, a state was field-testing part or all of its 
evaluation system. We considered a state evaluation system to be 
partially implemented if a state implemented all major components of 
the new evaluation system for some, but not all, teachers or 
principals in RTT districts. 

[26] Georgia received Education's approval to shift implementation 
time frames due, in part, to changes in state leadership. Maryland 
received Education's approval to pilot district evaluation systems in 
SY 2012-13--rather than fully implementing them--in part so that 
districts would have more time to improve their systems before using 
them for personnel decisions and to provide additional training on the 
systems. New York and Massachusetts did not submit amendment requests 
for their timeline shifts. As noted previously, we categorized New 
York as partially implemented because the New York City Department of 
Education did not have a state-approved evaluation system in SY 2012-
13. According to Education officials, they are working with 
Massachusetts to clarify the state's plan for moving forward with full 
implementation and expect the state to submit a related amendment 
request. 

[27] In Maryland, RTT districts had flexibility with how to pilot 
their evaluation systems (e.g., with some teachers in all schools or 
with all teachers in some schools). 

[28] Due in part to the difficulty of managing many changes 
simultaneously, including new curriculum and assessments in many 
states, in June 2013 Education offered states that have received ESEA 
waivers or RTT grants the option to request permission from Education 
to delay the use of their new evaluation systems to inform personnel 
determinations and consequences for up to 1 year. Education officials 
noted that many states are already successfully implementing these 
changes or have requirements in state law about implementation 
timeframes and thus may not need to request the waiver. 

[29] RTT state and district officials generally discussed challenges 
related to student academic growth measures, particularly SLOs, in the 
context of teacher evaluation systems. Officials in one Maryland 
district said developing SLOs for principals was difficult because 
their learning goals sometimes covered few students. For example, a 
principal's goal of improving special education outcomes might be 
based on only a few special education students within a large school. 

[30] Reform Support Network, The View from the States: A Brief on Non-
Tested Grades and Subjects, accessed June 11, 2013, [hyperlink, 
http://www2.ed.gov/about/inits/ed/implementation-support-unit/tech-
assist/resources.html]. Teachers in nontested grades and subjects 
would not have student scores on state-administered standardized tests 
that could be individually attributed to them. SLOs may be developed 
at the state, district, or school level and may be used as alternative 
student academic growth measures for evaluating teachers in nontested 
grades and subjects, or as additional student academic growth measures 
for evaluating teachers in tested grades and subjects. In some cases, 
scores on standardized tests may be used for SLOs. Principals may also 
be evaluated using SLOs. 

[31] Reform Support Network, Targeting Growth: Using Student Learning 
Objectives as a Measure of Educator Effectiveness, accessed June 11, 
2013, [hyperlink, http://www2.ed.gov/about/inits/ed/implementation-
support-unit/tech-assist/resources.html]. 

[32] In some cases, other school or district staff may conduct teacher 
observations or help with evaluations. 

[33] RTT state and district officials generally discussed challenges 
related to evaluation consistency in the context of teacher evaluation 
systems. Officials in one North Carolina district said that using the 
same rubric to evaluate principals and assistant principals is 
challenging when evaluators interpret the roles of assistant 
principals differently in different schools. 

[34] According to officials, measuring student academic growth for 
teacher evaluations was new to several states. 

[35] The Common Core State Standards Initiative is a state-led effort, 
and all but five states have voluntarily adopted the standards. 

[36] Officials in two RTT states identified union lawsuits as a factor 
that contributed to delays or uncertainty during implementation. In at 
least one state, litigation is ongoing, in both state and federal 
court. Other states may have also faced lawsuits but did not discuss 
them in our interviews. 

[37] Capacity challenges were generally related to the design and 
implementation of both teacher and principal evaluation systems. 
Officials in four RTT states said that capacity challenges pertained 
to both evaluation systems, but were more pronounced with teacher 
evaluations. Officials in one state said that capacity challenges 
pertained only to the teacher evaluation system. 

[38] As noted previously, the degree of flexibility districts had in 
designing their evaluation systems varied. 

[39] See [hyperlink, http://www.gao.gov/products/GAO-11-658], 
[hyperlink, http://www.gao.gov/products/GAO-12-228R], and GAO, School 
Improvement Grants: Education Should Take Additional Steps to Enhance 
Accountability for Schools and Contractors,,AO-12-373 (Washington, 
D.C.: April 11, 2012). 

[40] As previously noted, capacity challenges were generally related 
to the design and implementation of both teacher and principal 
evaluation systems. 

[41] See Race to the Top Program Review Guide. The same monitoring 
process is used for teacher and principal evaluation systems and other 
reforms funded through RTT grants. 

[42] We found that the RTT monitoring process exceeds the minimum 
requirements established in Education's 2009 Handbook for the 
Discretionary Grant Process. While Education requires its offices to 
prepare annual monitoring reports and conduct quarterly fiscal reviews 
of all of its discretionary grant programs, the RTT process also 
requires monthly progress updates, annual on-site program reviews, and 
progress reports updated on an ongoing basis, among other components. 

[43] We previously found that Education applied greater scrutiny to 
requests that involved significant changes to RTT grantees' planned 
activities, often by requiring that grantees provide additional 
information or seek consultation from issue-area experts within the 
department. See [hyperlink, http://www.gao.gov/products/GAO-12-228R]. 

[44] Under Education's regulations, if Education determines that a 
grantee is "high-risk," it may impose special conditions or 
restrictions on the grantee. Among other reasons, a grantee may be 
considered high-risk if the grantee has a history of unsatisfactory 
performance, is not financially stable, or is otherwise not 
responsible. 34 C.F.R. § 80.12. 

[45] If a grantee materially fails to comply with any term of an 
award, Education may take one or more of the following actions, as 
appropriate in the circumstances: (1) temporarily withhold cash 
payments pending correction of the deficiency or more severe 
enforcement action; (2) disallow (i.e., deny both use of funds and 
matching credit for) all or part of the cost of the activity or action 
not in compliance; (3) wholly or partly suspend or terminate the 
current award for the grantee's program; (4) withhold further awards 
for the program; or (5) take other remedies that may be legally 
available. 34 C.F.R. § 80.43. 

[46] Some states said they also obtained technical assistance from 
entities outside the federal government, such as other states and 
nonprofit organizations. 

[47] RSN surveyed all 19 RTT states, including the 12 Phase 1 and 
Phase 2 RTT states and the 7 Phase 3 states. RSN surveyed RTT state 
leads--officials with primary responsibility for administering RTT. 

[48] Other areas of assistance provided through RSN communities of 
practice include instructional improvement/ data systems, school 
turnaround, state educational agency capacity building, and 
stakeholder communications and engagement. States were asked to rate 
the impact of RSN technical assistance on RTT implementation on a 
scale of 1 to 5, with 1 representing low impact and 5 representing 
high impact. States rated the impact of teacher and leader 
effectiveness assistance on RTT implementation an average of 3.4 out 
of 5, compared to 2.4 for all RSN activities and 2.1 for state 
education agency capacity building. When asked about the extent to 
which RSN support has helped build state capacity, states rated the 
impact of teacher and leader effectiveness assistance higher than they 
did other RSN efforts. 

[49] The actual extension date for each state, if requested and 
approved, will vary. 

[50] [hyperlink, http://www.gao.gov/products/GAO-11-658]. 

[End of section] 

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