This is the accessible text file for GAO report number GAO-03-386 
entitled 'Title I: Although Definitions of Administrative Expenditures 
Vary, Almost All Districts Studied Spent Less Than 10 Percent on 
Administration' which was released on April 07, 2003.



This text file was formatted by the U.S. General Accounting Office 

(GAO) to be accessible to users with visual impairments, as part of a 

longer term project to improve GAO products’ accessibility. Every 

attempt has been made to maintain the structural and data integrity of 

the original printed product. Accessibility features, such as text 

descriptions of tables, consecutively numbered footnotes placed at the 

end of the file, and the text of agency comment letters, are provided 

but may not exactly duplicate the presentation or format of the printed 

version. The portable document format (PDF) file is an exact electronic 

replica of the printed version. We welcome your feedback. Please E-mail 

your comments regarding the contents or accessibility features of this 

document to Webmaster@gao.gov.



Report to Congressional Committees:



United States General Accounting Office:



GAO:



April 2003:



Title I:



Although Definitions of Administrative Expenditures Vary, Almost All 

School Districts Studied Spent Less Than 10 Percent on Administration:



GAO-03-386:



GAO Highlights:



Highlights of GAO-03-386, a report to the Committee on Health, 

Education, Labor and Pensions, United States Senate and the Committee 

on Education and Workforce, House of Representatives



Why GAO Did This Study:



Because of concern about school district spending on administration, 

Congress directed GAO in two separate mandates in the No Child Left 

Behind Act of 2001 to (1) examine how school districts defined and 

spent Title I funds on administrative activities and (2) review Title 

I expenditures in at least six school districts. In response to these 

mandates, we are reporting on (1) how five studies define Title I 

administrative expenditures and what they found about the percentage of 

funds spent on these activities and (2) what proportion of Title I 

funds was spent on administrative activities compared with 

instructional and other activities in six school districts.



What GAO Found:



In defining local administrative expenditures, all studies reviewed 

always included the school district Title I coordinator’s salary and 

benefits but, beyond this, their definitions varied. District spending 

classified as administrative in these studies varied, from 4 percent to 

10 percent. In the six school districts we studied, definitions of

administrative expenditures varied, in part because of differing state 

and local requirements or practices. 



Because there is no common agreement on what constitutes administrative 

expenditures, GAO identified a set of categories as “administrative 

expenditures” for the purposes of this study and found that, in the six 

school districts, Title I expenditures for administrative activities 

ranged from 13 percent of total Title I expenditures to no Title I 

funds spent on administration. Most Title I funding—at least 84 percent 

in every district—was spent on activities related to instruction. In 

addition, most school districts spent a relatively small percentage of 

their Title I funds on other non-instructional expenditures, such as 

transportation. Title I expenditures represent allocation decisions 

made by the six school districts during a particular year and, because 

some administrative costs may have been covered by funds from sources 

other than Title I, do not necessarily reflect the total amount 

districts spent on Title I administration in that year.



www.gao.gov/cgi-bin/getrpt?GAO-03-386.

To view the full report, including the scope and methodology, click on 

the link above. For more information, contact Marnie Shaul at 

(202) 512-7215 or shaulm@gao.gov.



[End of section]



Contents:



Letter:



Results in Brief:



Background:



Select Studies Used Varying Definitions of Administrative Expenditures:



The Proportion of Title I Funding Spent on Administrative Activities 

Varied, but Most School Districts Spent Less Than

10 Percent:



Concluding Observations:



Agency Comments:



Appendix I: Scope and Methodology:



Objectives:



Scope and Methodology:



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



Appendix III: GAO Contacts and Staff Acknowledgments:



Contacts:



Acknowledgments:



Tables:



Table 1: Expenditure Categories Considered to be Title I Administrative 

Expenditures in Five Selected Studies:



Table 2: Summary of Studies Reviewed:



Table 3: Proportion of Title I Spending by Type of Expenditure, School 

Year 2000-01, by Size of Title I Expenditures:



Table 4: Number of Full-Time Equivalent Staff Funded by Title I and the 

Total Staff in the School Districts, School Year 2000-01:



Table 5: Characteristics of School Districts Selected, School Year 

2000-01:



Table 6: Six School Districts’ Views of Whether Three Categories of 

Expenditures Are Title I Administrative Expenditures:



Table 7: Description of Instructional, Administrative, and Other 

Noninstructional Expenditures Used in This Study:



Table 8: GAO Categories of Administrative Expenditures Compared with 

In$ite(TM) Administration-Related Expenditure Categories:



Figure:



Figure 1: Percents of Total Title I and Total School District 

Expenditures Spent on Administration, School Year

2000-01:



This is a work of the U.S. Government and is not subject to copyright 

protection in the United States. It may be reproduced and distributed 

in its entirety without further permission from GAO. It may contain 

copyrighted graphics, images or other materials. Permission from the 

copyright holder may be necessary should you wish to reproduce 

copyrighted materials separately from GAO’s product.



United States General Accounting Office:



Washington, DC 20548:



April 7, 2003:



The Honorable Judd Gregg, Chairman

The Honorable Edward M. Kennedy

Ranking Minority Member

Committee on Health, Education, Labor and Pensions

United States Senate:



The Honorable John A. Boehner, Chairman

The Honorable George Miller

Ranking Minority Member

Committee on Education and the Workforce

House of Representatives:



In 2001, the Congress passed the No Child Left Behind Act (NCLB) in 

part to improve the academic achievement of disadvantaged children. The 

act also provided additional funding to school districts with students 

from low-income families. For fiscal year 2002, $10 billion was 

available through Title I of the act[Footnote 1], the largest source of 

federal funding for elementary and secondary education. To ensure that 

most of these funds were spent on instructional activities that improve 

student learning, in the conference report accompanying NCLB, the 

Congress indicated that only the necessary and appropriate amount of 

funds be used for administrative activities. However, the law does not 

specifically define administrative activities or set specific limits on 

administrative spending by school districts.



We were directed in two separate mandates by the Congress to (1) 

examine how school districts defined and spent Title I funds on 

administrative activities and (2) review Title I expenditures in at 

least six school districts. In response to these mandates, we are 

reporting on (1) how five studies define Title I administrative 

expenditures and what they found about the percentage of funds spent on 

these activities and (2) what proportion of Title I funds was spent on 

administrative activities compared with instructional and other 

activities in six school districts.



In response to the first mandate, we examined five studies related to 

Title I that we found in our literature review which defined school 

district administrative expenditures and the percentage of funds school 

districts spent on administration. In response to the second mandate, 

we conducted site visits in six school districts and gathered 

information about Title I expenditures to assess what proportion of 

Title I funding was spent on administrative activities compared with 

instructional and other activities. We selected six school districts in 

the following locations to ensure variation in enrollment size, ethnic 

composition, economic condition, and geographic location: Portsmouth, 

Rhode Island; Douglas County, Nevada; Jefferson Parish, Louisiana; 

Indianapolis, Indiana; St. Louis, Missouri; and San Diego, California. 

Because there is no agreement on a definition of administrative 

expenditures, in order to compare the six districts, we identified 

expenditure categories as “administrative” from our analysis of the 

five studies and consultations with school finance experts. The 

administrative expense categories include (1) the salaries and fringe 

benefits of Title I coordinators, managers, and administrative support 

staff; (2) support expenditures, such as equipment, for staff in 

category one, and (3) the salaries, fringe benefits and related 

expenditures for district-and school-level administrative leadership, 

such as principals. We then broke the districts’ total Title I spending 

into three subcategories: instruction and instructional support, 

administration, and other noninstructional activities, such as 

transportation. Because of the limited number of districts and other 

factors outlined in appendix I, our findings cannot be generalized to 

school districts nationwide. (Appendix I explains our methodology in 

more detail.) We conducted our work between April 2002 and January 2003 

in accordance with generally accepted government auditing standards.



Results in Brief:



All studies reviewed included the school district Title I coordinator’s 

salary and benefits in their definition of local administrative 

expenditures, but, beyond this, their definitions varied. For example, 

professional development activities were included in one definition but 

not in others. District spending classified as administration in these 

studies varied, from 4 percent to 10 percent.



Using a set of administrative expenditure categories developed for this 

study we found that, in the six school districts we studied, Title I 

expenditures for administrative activities ranged from 13 percent of 

total Title I expenditures to no Title I funds spent on administration. 

However, only in one district did Title I administrative expenditures 

exceed 10 percent. Most Title I funding--at least 84 percent in every 

district--was spent on activities related to instruction. However, the 

amount of Title I funds spent on administration reflects school 

district decisions about how expenses for administrative activities are 

allocated among various programs. For example, Portsmouth, Rhode 

Island, spent no Title I funds on administration but conducts Title I 

administrative activities. The district pays for them with local funds, 

according to district officials. Four of the school districts spent a 

relatively small percentage of their Title I funds on other 

noninstructional expenditures, including student transportation, 

building maintenance, and capital projects. The Title I expenditures on 

administration represent allocation decisions made by the six school 

districts for a particular year and do not represent school district 

spending in other years. Such decisions may change from one school year 

to the next.



Background:



States and localities provide most of the funding for public schools. 

In the 1998-99 school year, funds from state and local governments 

accounted for 93 percent of elementary and secondary school funding. 

Overall, states and localities contribute roughly an equal amount to 

educational programs, although individual state shares vary 

considerably. For example, in 1997, the state share in New Hampshire 

was 9 percent while in New Mexico it was 72 percent. The federal 

government also provides funding for elementary and secondary 

education, largely through the Elementary and Secondary Education Act 

(ESEA) of 1965.



The NCLB Act of 2001 reauthorized ESEA. Title I of NCLB is intended to 

help elementary and secondary schools establish and maintain programs 

that will improve the educational opportunities of low-income and 

disadvantaged children. Title I funds are intended to provide 

instruction and instructional support for these disadvantaged children 

so that they can master challenging curricula and meet state standards 

in core academic subjects. Although NCLB incorporated new or expanded 

requirements for the Title I program that related to such issues as 

strengthening accountability for results, it does not stipulate exactly 

how these funds are to be spent. Instead, the Title I program is an 

example of flexible funding for state educational agencies and school 

districts.



The Congress intended for most Title I funds to be spent on instruction 

and instructional activities, while limiting other costs, such as those 

on administrative activities. However, Title I does not contain a 

general definition of administrative expenses that school districts 

must use. Before the enactment of NCLB, ESEA required the U.S. 

Department of Education (Education) to conduct a study and report on 

the use of the funds for administration under the act and, based on the 

results of that study develop a definition of what types of activities 

constitute administration. Within 1 year of the study, which was 

required to have been completed by July 1, 1997, Education was required 

to promulgate final regulations or guidance regarding the use of funds 

for administration under ESEA, including limitations on the amount of 

funds that may be used for administration where no limit had been 

specified in law.[Footnote 2] Education did not develop a definition of 

administrative activities or issue regulations or guidance. However, 

these requirements were repealed by NCLB.



While Education has not developed a specific definition of 

administrative activities for Title I, the agency’s general 

administrative regulations and guidance address the issue of how 

grantees should identify administrative costs. Education’s general 

administrative regulations contain a statement that “administrative 

requirements mean those matters common to grants in general, such as 

financial management, kinds and frequency of reports, and retention of 

records. These are distinguished from programmatic requirements, which 

concern matters that can be treated only on a program-by-program or 

grant-by-grant basis, such as kinds of activities that can be supported 

by grants under a particular program.”[Footnote 3] (Emphasis in 

original.):



In response to the requirement in the ESEA that Education report on the 

results of its study, in 1998 the agency issued The Use of Federal 

Education Funds for Administrative Costs, which included a section 

entitled “Definitions of Administrative Spending.” The report includes 

a discussion of various definitions of administrative costs and 

activities described in law and guidance, definitions used by 

researchers, and “issues that should be considered in developing a 

definition of administrative costs for federal education programs.” The 

report refers to prior guidance issued by Education on what constitutes 

administrative costs where the term is not otherwise defined in statute 

or regulation.[Footnote 4] This guidance states that “[t]he costs of 

administration are those portions of reasonable, necessary and 

allowable costs associated with the overall project management and 

administration and which are not directly related to the provision of 

services to participants or otherwise allocable to the program cost 

objectives/categories. These costs can be both personnel and 

nonpersonnel costs and both direct and indirect.[Footnote 5] (Emphasis 

in original.)[Footnote 6] The guidance provides a list of examples of 

direct administration such as the salaries, benefits, and other 

expenses of staff who perform overall program management, program 

coordination, and office management functions.



Select Studies Used Varying Definitions of Administrative Expenditures:



All five studies we reviewed included the school district Title I 

coordinator’s salary and benefits in their definition of local 

administrative expenditures but, beyond this, the activities 

categorized as administration varied. District spending on 

administration in the five studies reviewed varied from 4 percent to 10 

percent. Several factors may contribute to this variation, such as the 

use of different definitions of administrative expenditures or reliance 

on different data types, such as budget numbers or actual expenditures.



In Five Studies, Definitions of Administrative Expenditures Varied:



Although they had common elements, the definitions of administrative 

expenditures used in the studies we reviewed varied. In all five of the 

studies, the salaries and benefits of school district Title I 

coordinators were considered to be administrative 

expenditures.[Footnote 7] However, four of the studies used a 

definition that encompassed more than this. For example, four of the 

studies also included supplies and equipment to support Title I 

administration in their definition. Table 1 highlights the similarities 

and differences among the various definitions of administrative 

expenditures used in the studies.



Table 1: Expenditure Categories Considered to be Title I Administrative 

Expenditures in Five Selected Studies:



Expenditure categories: Salaries and benefits of Title I coordinators; 

Study 1[A]: X; Study 2[B]: X; Study 3[C]: X; Study 4[D]: X; Study 5[E]: 

X.



Expenditure categories: Supplies and equipment to support Title I 

administration; Study 1[A]: X; Study 2[B]: X; Study 3[C]: X; Study 

4[D]: [Empty]; Study 5[E]: X.



Expenditure categories: Salaries and benefits of Title I administrative 

support staff; Study 1[A]: X; Study 2[B]: X; Study 3[C]: X; Study 4[D]: 

[Empty]; Study 5[E]: X.



Expenditure categories: Professional development for Title I 

coordinators and administrative support staff; Study 1[A]: [Empty]; 

Study 2[B]: X; Study 3[C]: [Empty]; Study 4[D]: [Empty]; Study 5[E]: 

[Empty].



Expenditure categories: District administration (salaries and benefits 

for superintendents, school boards, senior administrators, and other 

central office staff); Study 1[A]: X; Study 2[B]: [Empty]; Study 3[C]: 

X; Study 4[D]: [Empty]; Study 5[E]: [Empty].



Expenditure categories: Researchers and program evaluators; Study 1[A]: 

[Empty]; Study 2[B]: [Empty]; Study 3[C]: X; Study 4[D]: [Empty]; Study 

5[E]: [Empty].



Expenditure categories: School administration (principals and 

assistant principals); Study 1[A]: X; Study 2[B]: [Empty]; Study 3[C]: 

X; Study 4[D]: [Empty]; Study 5[E]: [Empty].



Expenditure categories: Business services (payroll, personnel, 

purchasing, accounting, and data processing); Study 1[A]: [Empty]; 

Study 2[B]: [Empty]; Study 3[C]: X; Study 4[D]: [Empty]; Study 5[E]: 

[Empty].



Expenditure categories: Furniture, computers and supplies for school 

and district administrators; Study 1[A]: X; Study 2[B]: [Empty]; Study 

3[C]: X; Study 4[D]: [Empty]; Study 5[E]: [Empty].



Expenditure categories: Legal services; Study 1[A]: X; Study 2[B]: 

[Empty]; Study 3[C]: X; Study 4[D]: [Empty]; Study 5[E]: [Empty].



[SOURCE: GAO ANALYSIS.]



[A] U.S. Department of Education, Planning and Evaluation Service, 

Study of Education Resources and Federal Funding. (Washington, D.C.: 

2000).



[B] U.S. Department of Education Inspector General, Following Title I, 

Part A and Secondary School Vocational Education Program Dollars to the 

Schools in 36 LEAs Visited, (Atlanta, Ga.: 1998).



[C] U.S. Department of Education, Planning and Evaluation Service, 

Elementary and Secondary Education Division, The Use of Federal 

Education Funds for Administrative Costs, (Washington, D.C.: 1998).



[D] Abt Associates,Inc. The Chapter 1 Implementation Study, Interim 

Report, Cambridge, Mass., 1992.



[E] U.S. General Accounting Office, Compensatory Education-Most Chapter 

1 Funds in Eight Districts Used for Classroom Services, GAO/HRD-92-

136FS (Washington, D.C.: Sept. 30, 1992).



[End of table]



District Spending on Title I Administration Ranged from 4 Percent to 10 

Percent:



Using different definitions of administrative expenditures, estimates 

of Title I district spending on administration varied among the five 

studies that we reviewed (see table 2). The studies generally found 

that school districts spent between 4 percent and 10 percent of Title I 

funds on administrative activities. These estimates can also differ 

from school district to school district within a single study. For 

example, Education’s 1998 study of expenditure data from 41 school 

districts located in 3 states found that a school district in Milwaukee 

spent 4 percent of Title I funds on administrative activities, school 

districts in South Carolina spent an average of 6 percent on 

administrative activities, and school districts in Rhode Island spent 

an average of 10 percent on such activities.



Table 2: Summary of Studies Reviewed:



Study: U.S. Department of Education, Planning and Evaluation Service, 

Study of Education Resources and Federal Funding; 



School year of data reviewed: 1997-98; 



Number of school districts sampled: 180; 



Definition 

of administration: Although the study does not develop its own 

definition of administration, researchers used definitions developed 

for categorized district data in National Center for Education 

Statistics guidance contained in Financial Accounting for Local and 

State School Systems.



The National Center for Education Statistics definition includes two 

types of administration categories: general administration and school 

administration. Both categories include salaries, fringe benefits, 

furniture, equipment, and supplies associated with administrative 

activities.



General administration:; * Superintendent; * School board; * Labor 

relations and negotiations; * Central office expenditures for 

administering special programs (e.g., Title I) and other central office 

expenditures; * Legal services; * Election services; * Tax assessment 

and collection; * Community relations; * Grant procurement; 

School administration:; Principal’s office (including vice principals 

and administrative support) and full-time department chairpersons.; 



Estimate of Title I spending on administration (in percent): 8.



Study: U.S. Department of Education Inspector General, Following Title 

I, Part A and Secondary School Vocational Education Program Dollars to 

the Schools in 36 LEAs Visited; School year of data reviewed: 1996-97; 

Number of school districts sampled: 36; Definition of administration: 

Primarily included salaries, related benefits, and professional 

development for program coordinators and their administrative staff, as 

well as any materials and equipment used to support administrative 

functions.; Estimate of Title I spending on administration (in 

percent): 6.



Study: U.S. Department of Education, Planning and Evaluation Service, 

Elementary and Secondary Education Division, The Use of Federal 

Education Funds for Administrative Costs; 



School year of data reviewed: 1995-96; 



Number of school districts sampled: 41; 



Definition of 

administration: Based on Coopers & Lybrand Financial Analysis Model 

[currently called the In$ite model]. Divided administration into three 

categories: district and school administration and business services. 

Each of these three categories includes salaries and fringe benefits 

for administrative staff as well as non-personnel costs such as 

furniture, computers, and supplies. District administration includes 

superintendents, school boards, senior administrators, legal services, 

research and program evaluators, and other central office staff. School 

administration includes principals and assistant principals. Business 

services include payroll, purchasing, personnel, accounting, and data 

processing. For federal education programs, administrative costs will 

typically include salaries and expenses for district and school level 

federal program coordinators.; 



Estimate of Title I spending on 

administration (in percent): 4-10.



Study: Abt Associates, Inc. The Chapter 1 Implementation Study, Interim 

Report; 



School year of data reviewed: 1990-91; Number of school 

districts sampled: 1,600; 



Definition of administration: Salaries and 

benefits for Title I administrators, including district staff.; 



Estimate of Title I spending on administration (in percent): 4.



Study: U.S. General Accounting Office, Compensatory Education-Most 

Chapter 1 Funds in Eight Districts Used for Classroom Services, GAO/

HRD-92-136FS; 

School year of data reviewed: 1990-91; 



Number of school 

districts sampled: 8; 



Definition of administration: Primarily salaries 

and benefits for Title I coordinators and administrative staff, as well 

as supplies and equipment used to support the program.; Estimate of 

Title I spending on administration (in percent): 10.



Source: GAO analysis.



[A] The term “Chapter 1” was used until the 1994 reauthorization of 

ESEA to refer to what is now Title I. For clarity, this report will 

refer to the program as Title I even when discussing data collected 

prior to the 1994 reauthorization.



[End of table]



Several factors, such as different definitions of administration or 

data types, may have contributed to the variety of findings among the 

studies we reviewed. The study that found that school districts were 

using the smallest percent of Title I funds for administration used the 

most limited definition of administration, only including the salaries 

and benefits of Title I administrators. Also, the scope of the studies 

differed. Two studies produced national estimates by reviewing a large 

number of school districts nationwide, while the other three selected 

fewer school districts, and the findings were not generalizable to 

school districts nationwide. In addition, the studies’ data types for 

estimating administration spending were not the same. For example, two 

studies based their findings on budget estimates provided by school 

districts while the other three studies used expenditure reports from 

school districts. Finally, the studies reviewed expenditure data from 

different school years.



In Six School Districts We Studied, Definitions of Administrative 

Expenditures Varied:



The six school districts that we studied used different definitions of 

administrative expenditures, in part because of differing state and 

local requirements or practices. As a result, expenditures may be 

accounted for in different ways across the school districts we studied. 

Local officials in all six school districts agreed that salaries and 

benefits of Title I coordinators, managers, and administrative support 

staff who are engaged in basic program operation and management, such 

as office administration and program coordination, were administrative. 

However, beyond this, what district officials counted as administrative 

expenditures varied. For example, St. Louis school district officials 

considered staff time dedicated to the professional development of 

teachers as administration, while school district officials in 

Jefferson Parish, La., did not.



In some cases, states may develop definitions of Title I administrative 

expenditures for school districts to limit the amount charged to the 

program for administration. Varying state accounting requirements and 

use of different state accounting handbooks may influence the 

characteristics of school district expenditure data. Two of the school 

districts we visited described state requirements that affect how 

school districts define and track expenditures in their state. For 

example, as part of the Title I application process, the state of 

Indiana encouraged school districts to reserve a maximum of 4 percent 

for administration and a minimum of 62 percent for 

instruction.[Footnote 8] Taking a slightly different approach, the 

state of California education code directs school districts to spend at 

least 85 percent of their Title I allocation at schools for direct 

services to students, thereby limiting the amount that can be spent on 

other activities, including administration.[Footnote 9]



The Proportion of Title I Funding Spent on Administrative Activities 

Varied, but Most School Districts Spent Less Than 10 Percent:



Because there is no common agreement on what constitutes administrative 

expenditures, we identified a set of expenditure categories as 

“administrative” for the purposes of this study and found that, in the 

six school districts, Title I expenditures for administrative 

activities ranged from 0 percent to 13 percent of total Title I 

expenditures for the 2000-01 school year.[Footnote 10] However, only in 

one district did Title I administrative expenditures exceed 10 percent. 

Most Title I expenditures--at least 84 percent in every district--were 

spent on instructional activities. Instructional expenditures include 

spending on instruction and instructional support. Spending on 

instruction included the salaries of instructional teachers, 

paraprofessionals and substitutes. Spending on instructional support 

included classroom materials and pupil and teacher support.



Administration for the purposes of this study include the following 

expenditure categories that we developed:



* The salaries and fringe benefits of Title I coordinators, managers, 

and administrative support staff who are engaged in basic program 

operation and management, such as office administration and program 

coordination.

:



* The related expenditures of coordinators, managers, and 

administrative support staff of Title I, such as equipment, supplies, 

furniture and business services required to support the administrative 

function, and auditing and legal services and data processing.

:



* Salaries, fringe benefits, and related indirect expenditures for 

district or school-level administrative leadership (including school 

board, superintendent, superintendent’s cabinet, school principal, and 

vice principal) involved in directing and supervising staff who are 

providing instruction or instruction-related services for Title I 

programs.



The Proportion of Title I Funding Spent on Administration Varied among 

Six School Districts:



In the six school districts, the proportion of Title I funding spent on 

administrative activities varied, though most Title I funds were spent 

on instruction and instructional support. Of the six school districts, 

San Diego spent the largest percentage of Title I funds on 

administration (13 percent), while Portsmouth, Rhode Island, spent none 

of its Title I funds on administration. Title I expenditures on 

administration represent allocation decisions made by the six school 

districts for a particular year. The amount of Title I funds spent on 

administration reflects school district decisions about what funds to 

use for administrative activities and not necessarily how much total 

funding was dedicated to the administration of Title I. For example, 

the Portsmouth school district does conduct Title I administrative 

activities, but pays for them with local funds. In all six school 

districts, the share of total Title I spending on administration was 

less than the share of total district spending on administration (see 

fig. 1).



Figure 1: Percents of Total Title I and Total School District 

Expenditures Spent on Administration, School Year 2000-01:



[See PDF for image]



Note: Expenditure data from Indianapolis are from calendar year 2000.



[End of figure]

:



Though they spent different percentages of their Title I funds on 

administration, the types of administrative activities the six school 

districts chose to pay for with Title I funds were similar. In five of 

the six school districts, Title I coordinators were funded by Title I 

during the 2000-01 school year. In all but the Portsmouth school 

district, Title I funds supported other district staff with Title I 

responsibilities, such as staff who provided technical assistance to 

the schools in specific areas such as finance, professional 

development, and technology. None of the school districts we visited 

used Title I funds to pay for activities by principals and vice 

principals.



Most Title I Funds Were Spent on Activities Related to Instruction:



In all six school districts, most Title I funding was spent on 

activities related to instruction. Each school district spent at least 

84 percent of its Title I funds on instruction and instructional 

support (see table 3). (See appendix I for details on what constitutes 

each type of expenditure.):



Table 3: Proportion of Title I Spending by Type of Expenditure, School 

Year 2000-01, by Size of Title I Expenditures:



School district: Portsmouth, R.I.; Total Title I expenditures: 

$110,912; Instructional: Instruction: 100%; Instructional: 

Instructional support: 0%; Instructional: Total: 100%; Administration: 

Total: 0%; Other noninstructional: Operations: 0%; Other 

noninstructional: Other: 0%; Other noninstructional: Total: 0%.



School district: Douglas County, Nev.; Total Title I expenditures: 

$377,233; Instructional: Instruction: 85%; Instructional: 

Instructional support: 8%; Instructional: Total: 93%; Administration: 

Total: 7%; Other noninstructional: Operations: 0%; Other 

noninstructional: Other: 0%; Other noninstructional: Total: 0%.



School district: Jefferson Parish, La.; Total Title I expenditures: 

$9,096,895; Instructional: Instruction: 71%; Instructional: 

Instructional support: 14%; Instructional: Total: 85%; Administration: 

Total: 6%; Other noninstructional: Operations: 4%; Other 

noninstructional: Other: 5%; Other noninstructional: Total: 9%.



School district: Indianapolis, Ind.; Total Title I expenditures: 

$15,060,344; Instructional: Instruction: 57%; Instructional: 

Instructional support: 27%; Instructional: Total: 84%; Administration: 

Total: 3%; Other noninstructional: Operations: 0%; Other 

noninstructional: Other: 12%; Other noninstructional: Total: 12%.



School district: St. Louis, Mo.; Total Title I expenditures: 

$18,658,131; Instructional: Instruction: 81%; Instructional: 

Instructional support: 8%; Instructional: Total: 90%; Administration: 

Total: 8%; Other noninstructional: Operations: 0%; Other 

noninstructional: Other: 2%; Other noninstructional: Total: 2%.



School district: San Diego, Calif.; Total Title I expenditures: 

$32,547,153; Instructional: Instruction: 57%; Instructional: 

Instructional support: 28%; Instructional: Total: 85%; Administration: 

Total: 13%; Other noninstructional: Operations: 0%; Other 

noninstructional: Other: 2%; Other noninstructional: Total: 2%.



Source: GAO’s data analysis of Title I spending.



Notes: (1) Percentages do not represent total district spending on 

instructional, administrative, and other noninstructional activities. 

(2) Percentages reflect local Title I allocation decisions and not 

necessarily total expenditures in those spending categories, as state 

and local funds my be used in addition to or in place of Title I funds 

in any category. (3) The proportions of Title I funding spent on 

various activities reflect the decisions and circumstances of school 

districts for a particular year and do not represent school district 

spending in other years. (4) The proportion of Title I expenditures 

spent on instructional, administrative, and other noninstructional 

activities take into account direct and indirect expenditures. (For 

more information about how indirect expenditures were included in the 

analysis, see appendix I.) (5) Total Instructional, Administration, and 

Other Noninstructional percentages of total Title I expenditures may 

not sum to 100 percent due to rounding. (6) Expenditure data from 

Indianapolis are from calendar year 2000.



[End of table]:



In addition, four of the school districts spent a relatively small 

percentage of their Title I funds on other noninstructional 

expenditures, such as out-of-district obligations, student 

transportation, building maintenance, and capital projects. 

Indianapolis spent the largest proportion of Title I funds on other 

noninstructional expenditures, a majority of which were Title I 

payments to parochial, private, and charter schools.[Footnote 11]



Title I funds were used to support staff in all of the school districts 

we studied. Table 4 provides the number of full-time equivalent 

teachers and teacher aides and other district staff funded by Title I 

as compared with the total full-time equivalent staff working in the 

school district. Title I staff represented between less than 1 percent 

and about 7 percent of total staff in the school districts. In 

districts with the smallest Title I grants, other district staff were 

funded only partially or not at all with the Title I grant. However, in 

the districts with the largest grants, other district staff, such Title 

I coordinators, were funded entirely by Title I.



Table 4: Number of Full-Time Equivalent Staff Funded by Title I and the 

Total Staff in the School Districts, School Year 2000-01:



Total district staff: School districtPortsmouth, R.I.: [Empty].



School district: Portsmouth, R.I.; Funded by Title I: Teachers & 

teacher aides: 2.33; Funded by Title I: Other staff: 0.00; Funded by 

Title I: Total staff: 2.33; Total district staff: 345.50.



School district: Douglas County, Nev.; Funded by Title I: Teachers & 

teacher aides: 4.80; Funded by Title I: Other staff: 0.30; Funded by 

Title I: Total staff: 5.10; Total district staff: 599.00.



School district: Jefferson Parish. La.; Funded by Title I: Teachers & 

teacher aides: 220.60; Funded by Title I: Other staff: 43.80; Funded by 

Title I: Total staff: 264.40; Total district staff: 7,913[A].



School district: Indianapolis, Ind.; Funded by Title I: Teachers & 

teacher aides: 205.68; Funded by Title I: Other staff: 56.49; Funded by 

Title I: Total staff: 262.17; Total district staff: 5,800[A].



School district: St. Louis, Mo.; Funded by Title I: Teachers & teacher 

aides: 329.50; Funded by Title I: Other staff: 96.50; Funded by Title 

I: Total staff: 426.00; Total district staff: 6,324.00.



School district: San Diego, Calif.; Funded by Title I: Teachers & 

teacher aides: 175.17; Funded by Title I: Other staff: 126.09; Funded 

by Title I: Total staff: 301.26; Total district staff: 15,059.49.



Source: GAO’s analysis of school district staffing.



[A] Total district staff for Jefferson Parish and Indianapolis 

represents the number of employees rather than full-time equivalent 

staff.



[End of table]



The proportions of Title I funding spent on various activities reflect 

the decisions and circumstances of school districts for a particular 

year. For example, in school year 2000-01 San Diego invested in teacher 

training in literacy at the start of a districtwide reform effort, 

which accounts for much of the high proportion (28 percent) spent on 

instructional support in that year. Similarly, Indianapolis spent 27 

percent on instructional support in calendar year 2000, investing in 

pupil, teacher, and program support.



Some school district officials noted that spending decisions might 

change in the future due to new federal requirements. They pointed out 

that a larger proportion of Title I funds may be needed for 

administrative and other noninstructional activities due to new 

requirements in the NCLB Act. For example, officials from two school 

districts said that the implementation of the school choice provisions 

in NCLB may increase transportation costs. A new requirement in NCLB 

stipulates that school districts must offer students in Title I schools 

that do not perform adequately for 2 consecutive years the option of 

transferring to another public school. School districts must provide 

transportation for, or pay the transportation costs of, the students 

who choose this option.



Concluding Observations:



This report provides insights from studies about administrative 

expenditures and a snapshot of Title I expenditures in six school 

districts for 1 year. Although definitions of administrative 

expenditures varied, the studies and our work in six districts suggest 

that despite the flexibility school districts have in the use of these 

federal funds, they limited Title I spending for administration and 

spent most Title I funds on instruction.



Agency Comments:



We received comments from Education on a draft of this report, which 

are reprinted in appendix II. Education found the report to be 

informative and noted that the report should be useful to the Congress, 

Education itself, and state and local grantees.



We are sending copies of this report to the Secretary of Education, 

appropriate congressional committees, and other interested parties. 

Copies will also be made available at no charge on GAO’s Web site at 

http://www.gao.gov. If you or your staff have any questions or wish to 

discuss this material further, please call me at (202) 512-7215.



Marnie S. Shaul:



Director, Education, Workforce, and Income Security Issues:



Signed by Marnie S. Shaul:



[End of section]



Appendix I: Scope and Methodology:



Objectives:



The objectives of our review were to report on (1) how five studies 

define Title I administrative expenditures and what they found about 

the percentage of funds spent on these activities and (2) what 

proportion of Title I funds was spent on administrative activities 

compared with instructional and other activities in six school 

districts.



Scope and Methodology:



To assess how selected studies define Title I administrative 

expenditures, we conducted a literature review of studies and reports 

related to Title I and what they found about the percentage of funds 

spent on these activities. Each of these studies included an estimate 

of the percentage of Title I funds that school districts spent on 

administrative activities. Because there is no common agreement on what 

constitutes administrative expenditures, for the purposes of this 

study, we identified a set of expenditure categories as 

“administrative” based on federal guidance, previous studies, and 

interviews with subject matter experts. To assess what proportion of 

Title I funding specific school districts spent on administrative 

activities compared with instructional and other activities, we 

conducted site visits to five school districts and telephone interviews 

with officials from an additional school district. We gathered 

information about Title I administrative expenditures for the 2000-01 

school year[Footnote 12] and analyses of expenditure reports from six 

school districts. Officials in six school districts we surveyed 

provided us with feedback on which of our three expenditure categories 

they considered to be administrative expenditures. We contracted with a 

consulting firm to analyze school district Title I expenditures using 

the three expenditure categories. Due to the limited number of 

districts, however, our findings cannot be generalized to school 

districts nationwide. We conducted our review between April 2002 and 

January 2003 in accordance with generally accepted government auditing 

standards.



Literature Review:



To assess how selected studies define Title I administrative 

expenditures, we conducted a literature review of studies and reports 

related to Title I. Literature was gathered by conducting bibliographic 

searches of major educational databases[Footnote 13] and through 

consultation with experts in school finance. We examined five studies 

that met the following criteria: (1) included data on school district 

Title I spending on administration; (2) reviewed school districts 

located in more than one state; and (3) was published after 1990. Each 

of the studies reviewed included an estimate of the percentage of Title 

I funds that school districts spent on administrative activities. The 

studies we examined include:



* U.S. Department of Education, Planning and Evaluation Service, Study 

of Education Resources and Federal Funding (Washington, D.C.: 2000).

:



* U.S. Department of Education Office of Inspector General, Following 

Title I, Part A and Secondary School Vocational Education Program 

Dollars to the Schools in 36 LEAs Visited (Atlanta, Ga.: 1998).

:



* U.S. Department of Education, Planning and Evaluation Service, 

Elementary and Secondary Education Division, The Use of Federal 

Education Funds for Administrative Costs (Washington, D.C.: 1998).

:



* Abt Associates Inc., The Chapter 1 Implementation Study, Interim 

Report (Cambridge, Mass.: 1992).

:



* U.S. General Accounting Office, Compensatory Education-Most Chapter 1 

Funds in Eight Districts Used for Classroom Services, GAO/HRD-92-136FS 

(Washington, D.C.: Sept. 30, 1992).

:



Site Visits:



To assess what proportion of Title I funding spent by specific school 

districts on administrative activities compared with instructional and 

other activities, we gathered information about Title I administrative 

expenditures for the 2000-01 school year through site visits to five 

school districts and analysis of their expenditure reports. We gathered 

information about a sixth school district through telephone interviews 

with district officials and analysis of its expenditure reports.



We selected the school districts based on the characteristics described 

in our congressional mandates, including variation in enrollment size, 

ethnic composition, economic condition, and geographic location. We 

also considered the ability of the consultant to analyze the 

expenditures of school districts selected. All school districts, with 

the exception of San Diego, California, used a financial reporting 

model called In$ite(tm), which is used by Fox River Learning, the 

consulting firm we worked with to categorize expenditures. Although the 

school district did not use the model, we selected San Diego because it 

added to the geographic dispersion of the sample and represented a 

large metropolitan area. See table 5 for characteristics of the school 

districts selected. In addition to San Diego, we selected school 

districts in the following locations: Portsmouth, Rhode Island; Douglas 

County, Nevada; Jefferson Parish, Louisiana; Indianapolis, Indiana; and 

St. Louis, Missouri. Because of the limited number of districts 

selected, our findings cannot be generalized to school districts 

nationwide.



Table 5: Characteristics of School Districts Selected, School Year 

2000-01:



School district: Portsmouth, R.I.; Student enrollment: 2,869; Locale & 

region: Small town, northeast; % Minority enrollment: 4%; % Eligible 

for free/reduced price lunch: 7%.



School district: Douglas County, Nev.; Student enrollment: 7,022; 

Locale & region: Rural, west; % Minority enrollment: 14%; % Eligible 

for free/reduced price lunch: 21%.



School district: Jefferson Parish, La.; Student enrollment: 51,413; 

Locale & region: Urban fringe of a large city, south; % Minority 

enrollment: 61%; % Eligible for free/reduced price lunch: 68%.



School district: Indianapolis, Ind.; Student enrollment: 41,108; Locale 

& region: Large central city, midwest; % Minority enrollment: 68%; % 

Eligible for free/reduced price lunch: 76%.



School district: St. Louis, Mo.; Student enrollment: 41,400; Locale & 

region: Large central city, midwest; % Minority enrollment: 83%; % 

Eligible for free/reduced price lunch: 83%.



School district: San Diego, Calif.; Student enrollment: 141,804; Locale 

& region: Large central city, west; % Minority enrollment: 73%; % 

Eligible for free/reduced price lunch: 62%.



Source: Locale and region from National Center for Education Statistics 

Common Core of Data. Student enrollment, percent minority enrollment, 

percent eligible for free and reduced price lunch reported by the 

school districts for school year 2000-01.



[End of table]



Our Categorization of Administrative Activities:



To compare the six school districts, we identified a set of expenditure 

categories as “administrative,” based on federal guidance, previous 

studies, and interviews with experts in school finance.[Footnote 14] We 

identified those administrative activities mentioned most frequently by 

experts or identified in the documents we reviewed. See table 6, which 

illustrates which of these three categories each district included in 

its definition of Title I administrative expenditures.



During our interviews, school district officials stated whether they 

considered our three categories of expenditures to be administrative 

expenditures under the program. School district officials in all six 

school districts agreed that salaries and benefits of Title I 

coordinators and administrative support staff were administrative 

expenditures under the Title I program. However, agreement on the other 

two categories of expenditures was not unanimous.



Table 6: Six School Districts’ Views of Whether Three Categories of 

Expenditures Are Title I Administrative Expenditures:



Three categories of expenditures:

Category 1; The salaries and fringe benefits of Title I 

coordinators[A] managers and administrative support staff who are 

engaged in basic program operation and management, such as office 

administration and program coordination.; 



Three categories of 

expenditures: Category 2; The related costs of coordinators, 

managers, and administrative support staff of Title I, such as 

equipment, supplies, furniture and business services required to 

support the administrative function, and auditing and legal services 

and data processing.; 



Three categories of expenditures: Category 3; 

Salaries, fringe benefits, and related indirect expenditures for 

district or school level administrative leadership (including school 

board, superintendent, school principal, and vice principal) involved 

in directing and supervising staff who are providing instruction or 

instruction-related services for Title I programs.

.



School district: 

Portsmouth, R.I.; Yes; Three categories of expenditures: Yes,[B] with 

exceptions; Three categories of expenditures: Yes,[B ,E] with 

exceptions.



School district: Douglas County, Nev.; Yes; Three categories of 

expenditures: No; Three categories of expenditures: No.



School district: Jefferson Parish, La.; Yes; Three categories of 

expenditures: Yes; Three categories of expenditures: Yes,[C] with 

exceptions.



School district: Indianapolis, Ind.; Yes; Three categories of 

expenditures: Yes; Three categories of expenditures: Yes,[D,E] with 

exceptions.



School district: St. Louis, Mo.; Yes; Three categories of expenditures: 

Yes; Three categories of expenditures: Yes[E].



School district: San Diego, Calif.; Yes; Three categories of 

expenditures: Yes; Three categories of expenditures: No.



[SOURCE: GAO ANALYSIS.]



[A] For these categories, Title I coordinators are responsible for 

managing the Title I program for the district and are equivalent to 

managers or directors.



[B] Portsmouth agreed with Category 2, with the exception of 

coordinators and managers, and Category 3, with the exception of school 

board.



[C] Jefferson Parish agreed with Category 3, with the exception of 

school principals and vice principals.



[D] Indianapolis agreed with Category 3, with the exception of school 

board and superintendent.



[E] Although Portsmouth, Indianapolis, and St. Louis considered 

expenditures associated with principals and vice principals to be 

allowable Title I expenditures, none charged any of their salaries to 

Title I in 2000-01.



[End of table]



Table 7 summarizes how we classified instructional, administrative, and 

other noninstructional expenditures for this study.



Table 7: Description of Instructional, Administrative, and Other 

Noninstructional Expenditures Used in This Study:

[See PDF for image]



[End of table]



Source: GAO analysis.



Education Consulting Firm Contract:



To expedite data collection and analysis, we contracted with a 

consulting firm selected via a competitive bidding process to analyze 

school district Title I expenditures. The expenditure reports were 

produced by Fox River Learning, an education consulting firm using 

their analytical tool, the In$ite(tm) model, formerly known as the 
Coopers 

and Lybrand Finance Analysis Model. The model is used by 400 school 

districts across the country. Five of the six school districts we 

selected for this study used the model in the past for a variety of 

purposes, such as calculating the cost per student by school and 

identifying the proportion of funds spent on instruction and schools 

with the greatest needs. One school district, San Diego, did not use 

the model, but the consultant worked with the district to categorize 

its Title I expenditures using the model. Table 8 shows how our set of 

administrative expenditure categories relates to the model.



Table 8: GAO Categories of Administrative Expenditures Compared with 

In$ite(tm) Administration-Related Expenditure Categories:



GAO categories of administrative expenditures: The salaries and fringe 

benefits of Title I coordinators, managers, and administrative support 

staff who are engaged in basic program operation and management, such 

as office administration and program coordination.

In$ite(tm) model administration-related expenditure categories: 
Program 

development/management; Salaries and related employment costs of staff 

who manage and coordinate the Title I program. Includes office costs 

and clerical costs associated with the administrator’s activities..



GAO categories of administrative expenditures: The related expenditures 

of coordinators, managers, and administrative support staff of Title I, 

such as equipment, supplies, furniture, and business services required 

to support the administrative function, and auditing and legal services 

and data processing.

In$ite(tm) model administration-related expenditure categories: 

Business services; Salaries and related employment costs associated 

with data processing, payroll, human resources, accounting and finance, 

auditing, and procurement..



GAO categories of administrative expenditures: Salaries, fringe 

benefits, and related indirect expenditures for district or school-

level administrative leadership (including school board, 

superintendent, superintendent’s cabinet, school principal, and vice 

principal) involved in directing and supervising staff who are 

providing instruction or instruction-related services for Title I 

programs.; In$ite(tm) model administration-related expenditure 

categories: School management; Salaries and related employment costs of 

principals, assistant principals, and administrative support staff for 

the principal and assistant principals.

District management; Salaries and related employment costs of the 

superintendent, the superintendent’s cabinet (deputies, senior 

administrators, researchers, and program evaluators), the school board, 

and the legal department.



[End of table]



Source: GAO analysis.

:



We did not verify the reliability of the data collected from school 

districts that were entered into the model. However, to assess the 

accuracy of the data school districts provided to the consultant, we 

reviewed the district’s most recent independent audit report related to 

the internal control structure. These reports did not disclose any 

material weaknesses in internal controls. In addition, all school 

districts reported how they monitored Title I funds spent at the school 

level.



We did not verify the reliability of the expenditure reports. However, 

we took steps to ensure the reliability of the consulting firm, 

including interviewing a current and a former user of the firm’s model 

and reviewing descriptions of the process the firm uses to input, 

categorize, and perform quality assurance on the data provided by 

school districts. The U.S. Department of Education worked with this 

finance analysis model when it was known as the Coopers and Lybrand 

Finance Analysis Model. In addition, all six school districts confirmed 

that the data from the expenditure reports included in this report were 

accurate.



Indirect Cost Rates:



The proportion of Title I expenditures spent on instructional, 

administrative, and other noninstructional activities take into account 

direct and indirect expenditures. Direct expenditures are those that 

can be specifically identified with a program, such as the salaries and 

benefits of program administrators. Indirect expenditures are those 

that cannot be specifically identified with a program, such as general 

administrative services.



The indirect cost rate represents the ratio of the school district’s 

total indirect costs to some element of its direct costs. The rates are 

calculated by state education agencies using a methodology that is 

approved by Education. Indirect cost rates may vary among school 

districts due to differing financial management and accounting 

policies. It is difficult to compare indirect cost rates among school 

districts. Under Title I, school districts must use a restricted 

indirect cost rate, which is a rate that does not include state and 

local costs that would be incurred with or without the existence of the 

federal program.



Administrative expenditures were determined by adding the indirect 

administrative expenditures to the direct administrative expenditures. 

During the 2000-01 school year or fiscal year, three of the six school 

districts we reviewed did not charge indirect costs to Title I. For 

example, in Portsmouth, Rhode Island, district officials said that they 

used their allocation solely for salaries of teachers and teacher 

aides, leaving no additional dollars to charge to Title I. Three school 

districts, San Diego, Douglas County, and Indianapolis, did charge 

indirect costs to Title I. The indirect cost rates used by these school 

districts during the 2000-01 school year or fiscal year were 4.15 

percent, 2.60 percent, and 2.01 percent applied to direct expenditures, 

respectively. Since accounting for indirect expenditures varies among 

school districts, the consultant worked with school district officials 

to determine the category most appropriate for indirect expenditures.



[End of section]



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



UNITED STATES DEPARTMENT OF EDUCATION:



THE UNDER SECRETARY:



March 25, 2003:



Ms. Mamie S. Shaul:



Director, Education, Workforce, and Income Security Issues U.S. General 

Accounting Office Washington, D.C. 20548:



Dear Ms. Shaul:



Thank you for transmitting to this Department for comment, the General 

Accounting Office (GAO) draft report “Title I: Although Definitions of 

Administrative Expenditures Vary, Almost All Districts Studied Spent 

Less Than 10 Percent on Administration.” In this report, GAO provides 

information on Title I expenditures in six school districts, how these 

school districts define Title I administrative activities, and the 

findings of five previous studies on administrative costs, including 

several studies done by this Department.



The report’s findings indicate that across virtually all districts 

studied, less than 10 percent of Title I funds were being used for 

administrative purposes, and, in one district, no Title I funds were 

used for administrative costs. According to the report, most Title I 

funding --at least 84 percent in every district studied --was spent on 

activities related to instruction.



We found the information in the draft report informative. When it is 

published, “Title I: Although Definitions of Administrative 

Expenditures Vary, Almost All Districts Studied Spent Less Than 10 

Percent on Administration” should be useful to the Congress, this 

Department, and State and local grantees. We appreciate the opportunity 

to review and comment on the draft.



Sincerely,



Eugene W. Hickok:



Signed by Eugene W. Hickok:



400 MARYLAND AVE., S.W., WASHINGTON, D.C. 20202 www.ed.gov:



[End of section]



Appendix III: GAO Contacts and Staff Acknowledgments:



Contacts:



Eleanor L. Johnson, (202) 512-7209:



Acknowledgments:



In addition to the staff named above, Virginia Vanderlinde and 

Catherine Roark made major contributions in leading and staffing this 

assignment. Julianne Hartman-Cutts and Corinna Nicolaou also made key 

contributions to this report.



[End of section]



FOOTNOTES



[1] Throughout this report, we refer to Title I, Part A of the No Child 

Left Behind Act as “Title I.” Part A of Title I in the act is directed 

at improving basic programs operated by local education agencies, which 

we refer to as “school districts” in this report.



[2] P.L. 103-382, title I,§101 (Oct. 20, 1994), amending ESEA. These 

requirements were repealed by NCLB.



[3] 34 C.F.R. §80.3.



[4] U.S. Department of Education, Indirect Cost Determination: Guidance 

for State and Local Government Agencies, (Washington, D.C., 1997) pp. 

72.



[5] Direct expenditures are those that can be specifically identified 

with a program, such as the salaries and benefits of program 

administrators. Indirect expenditures are for resources that cannot be 

specifically identified with a program, such as the portion of 

expenditures for data processing or accounting that support the 

program.



[6] While this document is termed “Guidance,” such guidance issued by 

the agency authorized to administer the program is generally binding in 

determining the allowability of costs. See California v. U.S., 547 F.2d 

1388 (9th Cir. 1977). The overallocation of indirect costs, for 

example, would be considered unauthorized and, therefore, unallowable. 

Principles of Federal Appropriations Law, 2nd ed, vol. II, pps. 10-75. 



[7] One study we examined did not include a definition of 

administration in their report. However, researchers used definitions 

developed by the National Center for Education Statistics when 

categorizing district expenditures. See table 2 for the center’s 

definition. This study is: U.S. Department of Education, Planning and 

Evaluation Service, Study of Education Resources and Federal Funding, 

(Washington, D.C.: 2000).



[8] Title I Application Review Questions, Indiana Department of 

Education.



[9] California Education Code sec. 63001 (2000).



[10] Expenditure data from five of the six districts are from the 2000-

01 school year. Expenditure data from Indianapolis, however, are from 

calendar year 2000. Hereafter, we will refer to the year of our data 

collection as school year 2000-01.



[11] These payments may be used for instructional activities in 

parochial, private, or charter schools. However, because these payments 

are not for instruction at public schools they are, therefore, 

categorized as other noninstructional expenditures. 



[12] Expenditure data from five of the six districts are from the 2000-

01 school year. Expenditure data from Indianapolis, however, are from 

calendar year 2000. Hereafter, we will refer to the year of our data 

collection as school year 2000-01.



[13] Databases searched include Pro Quest, Education Resource 

Information Center, and the Database of Department of Education 

Publications in ERIC.



[14] We consulted with the following school finance experts: Dr. 

Lawrence Picus, University of Southern California; Dr. Jay Chambers, 

American Institutes for Research; Stephanie Stullich, Planning and 

Evaluation Service, U.S. Department of Education; Dr. Donald Tetreault, 

University of South Carolina; and Dr. William Fowler, National Center 

for Education Statistics, U.S. Department of Education.



GAO’s Mission:



The General Accounting Office, the investigative arm of Congress, 

exists to support Congress in meeting its constitutional 

responsibilities and to help improve the performance and accountability 

of the federal government for the American people. GAO examines the use 

of public funds; evaluates federal programs and policies; and provides 

analyses, recommendations, and other assistance to help Congress make 

informed oversight, policy, and funding decisions. GAO’s commitment to 

good government is reflected in its core values of accountability, 

integrity, and reliability.



Obtaining Copies of GAO Reports and Testimony:



The fastest and easiest way to obtain copies of GAO documents at no 

cost is through the Internet. GAO’s Web site ( www.gao.gov ) contains 

abstracts and full-text files of current reports and testimony and an 

expanding archive of older products. The Web site features a search 

engine to help you locate documents using key words and phrases. You 

can print these documents in their entirety, including charts and other 

graphics.



Each day, GAO issues a list of newly released reports, testimony, and 

correspondence. GAO posts this list, known as “Today’s Reports,” on its 

Web site daily. The list contains links to the full-text document 

files. To have GAO e-mail this list to you every afternoon, go to 

www.gao.gov and select “Subscribe to daily E-mail alert for newly 

released products” under the GAO Reports heading.



Order by Mail or Phone:



The first copy of each printed report is free. Additional copies are $2 

each. A check or money order should be made out to the Superintendent 

of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. 

Orders should be sent to:



U.S. General Accounting Office



441 G Street NW,



Room LM Washington,



D.C. 20548:



To order by Phone: 	



	Voice: (202) 512-6000:



	TDD: (202) 512-2537:



	Fax: (202) 512-6061:



To Report Fraud, Waste, and Abuse in Federal Programs:



Contact:



Web site: www.gao.gov/fraudnet/fraudnet.htm E-mail: fraudnet@gao.gov



Automated answering system: (800) 424-5454 or (202) 512-7470:



Public Affairs:



Jeff Nelligan, managing director, NelliganJ@gao.gov (202) 512-4800 U.S.



General Accounting Office, 441 G Street NW, Room 7149 Washington, D.C.



20548: