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entitled 'No Child Left Behind Act: Additional Assistance and Research 
on Effective Strategies Would Help Small Rural Districts' which was 
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Report to Congressional Requesters:

United States Government Accountability Office:

GAO:

September 2004:

No Child Left Behind Act:

Additional Assistance and Research on Effective Strategies Would Help 
Small Rural Districts:

GAO-04-909:

GAO Highlights:

Highlights of GAO-04-909, a report to congressional requesters

Why GAO Did This Study:

To improve the academic achievement of the nation’s 48 million school-
aged children, the No Child Left Behind Act (NCLBA) introduced 
significant changes to how states, districts, and schools are held 
accountable for student performance and teacher qualifications. 
Congress has raised concerns about whether rural districts face 
difficulties implementing NCLBA. GAO is providing information on (1) 
key challenges rural states and districts face in implementing NCLBA, 
(2) strategies rural districts have developed to implement NCLBA, (3) 
expenditures and resources related to rural districts’ compliance with 
NCLBA, and (4) guidance and assistance that the Department of Education 
(Education) is providing.

To address these objectives, GAO conducted a nationally representative 
survey of rural school districts. GAO also surveyed nonrural districts 
to provide a context for the survey results. In addition, GAO visited 
and interviewed officials in rural states and districts and Education 
officials.

What GAO Found:

Rural districts faced some challenges in meeting NCLBA provisions to a 
greater extent than nonrural districts. For example, rural district 
officials were more likely than nonrural district officials to report 
challenges presented by a large enrollment of economically 
disadvantaged students who may live in communities lacking resources 
such as libraries. Rural districts also identified small school size 
and geographic isolation as greatly affecting their ability to 
implement NCLBA. Rural officials we interviewed said that limited 
access to teacher training facilities and Internet line maintenance 
difficulties impeded NCLBA implementation efforts.

[See PDF for image]

[End of table]

Rural district officials reported using some strategies, such as 
training for teachers, to the same extent as nonrural respondents, to 
help meet student proficiency provisions and implement teacher 
qualification requirements of NCLBA. Rural districts were more likely 
to increase computer capacity than nonrural districts. However, small 
rural districts were less likely than other rural districts to report 
using certain strategies, such as teacher mentoring.

Rural state and district officials we interviewed identified some 
specific expenditures related to NCLBA, such as those related to 
analyzing assessment results and providing tutoring services to 
students. However, district officials were unable to determine total 
expenditures made to implement NCLBA, in part because their accounting 
records were not maintained in a way that tracked expenditures by 
NCLBA categories; states we contacted did not require districts to 
report separately on NCLBA expenditures. Besides state and local 
funds, officials reported using multiple federal programs to implement 
NCLBA, such as the Rural Education Achievement Program (REAP). 

Since 2002, Education has provided NCLBA guidance and assistance to 
all states and districts, and since April 2003, it has focused on 
rural education issues by issuing new guidance, establishing a task 
force on rural issues, and planning for a rural education research 
center. However, rural officials indicated that further assistance 
would be helpful for small rural districts that are experiencing 
difficulties in providing teacher development opportunities and 
identifying effective remedial services to improve student achievement. 
Currently, research on the effectiveness of different strategies to 
improve student performance is limited.

What GAO Recommends:

GAO recommends that Education provide additional assistance on 
implementation approaches small rural districts can use to address 
their unique challenges and support research on effective strategies 
that can be applied to improve student performance in small rural 
districts through its new center.

www.gao.gov/cgi-bin/getrpt?GAO-04-909.

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

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Rural Districts and States Faced Challenges in Implementing NCLBA:

Rural and Nonrural Districts Generally Reported Using Similar 
Strategies to Implement NCLBA, but Small Rural Districts Were Less 
Likely to Use Them:

Rural Districts Identified Some Specific Expenditures Made for NCLBA 
Implementation and Used Multiple Funding Sources to Support 
Implementation Efforts:

Education Provided Many Types of Assistance, but Rural Officials Said 
Additional Assistance Would Be Helpful:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Other Methodology:

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

Appendix III: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Related GAO Products:

Tables:

Table 1: Characteristics of Small Rural, Other Rural, and Nonrural 
Districts, 2001-02:

Table 2: Percentages of Rural and Nonrural District Superintendents 
Reporting Challenges in Implementing NCLBA's Teacher Qualification 
Requirements:

Table 3: Percentages of Small Rural and Other Rural District 
Superintendents Reporting Additional Challenges in Implementing 
Various NCLBA Provisions:

Table 4: Percentages of Rural and Nonrural District Superintendents 
Reporting Specific Strategies to Meet Student Proficiency Goals:

Table 5: Percentages of Rural and Nonrural District Superintendents 
Reporting Specific Strategies to Implement NCLBA's Highly Qualified 
Teacher Provisions:

Table 6: Percentages of Rural and Nonrural District Superintendents 
Reporting the Use of Distance Learning Technology in Implementing 
NCLBA's Highly Qualified Teacher Provisions:

Table 7: Percentages of Rural District Superintendents Reporting the 
Use of REAP Funds for Purposes Associated with NCLBA Implementation:

Table 8: Actions Taken by Education to Assist States with 
Implementation of NCLBA and Their Intended Purpose:

Table 9: Site Visit States and School Districts:

Figures:

Figure 1: Small Rural and Other Rural Districts:

Figure 2: Rural States Contacted:

Figure 3: Percentages of Small Rural District Superintendents Reporting 
Use of Specific Strategies to Help Schools Meet Student Proficiency 
Goals Compared with Percentages of Other Rural District 
Superintendents:

Figure 4: Percentages of Small Rural District Superintendents Reporting 
Use of Specific Strategies to Meet NCLBA's Teacher Qualification 
Requirements Compared with Percentages of Other Rural District 
Superintendents:

Abbreviations:

AYP: adequate yearly progress:

CCD: Common Core of Data:

ESA: educational service agency:

K-12: kindergarten through 12th grade:

LEA: local education agency:

NCLBA: No Child Left Behind Act:

NCES: National Center for Education Statistics:

REAP: Rural Education Achievement Program:

United States Government Accountability Office:

Washington, DC 20548:

September 23, 2004:

The Honorable Kent Conrad: 
Ranking Minority Member: 
Committee on the Budget: 
United States Senate:

The Honorable Susan Collins: 
Chairman: 
Committee on Governmental Affairs: 
United States Senate:

The Honorable Michael Enzi: 
United States Senate:

The Honorable Tim Johnson: 
United States Senate:

In an effort to improve the academic achievement of all of the nation's 
48 million school-aged children, the No Child Left Behind Act (NCLBA) 
introduced significant changes to how states, districts, and schools 
are held accountable for their students' academic performance and 
teachers' qualifications. The Congress, as well as state and district 
education officials, has expressed concerns that many rural districts 
are encountering difficulties in implementing NCLBA provisions. NCLBA 
requires districts and schools to assess students' reading, math and 
science abilities and measure the results against a level of 
proficiency that has been established by the state. As a condition for 
receiving federal funds, NCLBA currently requires states to ensure that 
every student becomes proficient in reading and math by school year 
2013-14. NCLBA also requires that teachers of core academic subjects, 
such as English, meet teacher qualification requirements, and most of 
these teachers must do so by the end of the 2005-06 school year. To 
meet requirements teachers must have a bachelor's degree, be state-
certified to teach, and demonstrate subject matter competence in each 
core academic subject that they teach. Because of the small size and 
geographic isolation of many rural districts and schools, there is a 
concern that these districts and schools may find it difficult to 
implement some NCLBA provisions. In the 2001-02 school year, rural 
districts comprised 25 percent of all school districts in the country.

As a result of concerns that rural states and districts may have 
difficulties meeting some NCLBA requirements, we are providing you with 
information about implementation issues. This study addresses the 
following questions:

1. What key challenges do rural states and districts face in meeting 
student proficiency provisions and teacher qualification requirements 
of NCLBA?

2. What strategies have rural districts developed to meet student 
proficiency provisions and teacher qualification requirements of NCLBA?

3. What expenditures and funding sources are related to rural 
districts' compliance with NCLBA?

4. What guidance and assistance is the Department of Education 
(Education) providing?

To answer these questions, we used multiple methodologies, including a 
survey, site visits, and interviews with Education officials. We 
conducted a survey of a stratified, nationally representative sample of 
1,215 school districts and received a response rate of 86 percent. We 
surveyed rural and nonrural districts so that we could determine 
whether and to what extent rural districts differed from nonrural 
districts. We used a definition of rural that focused on places that 
were distant from metropolitan areas. We categorized our sample as 
follows:

* Rural districts. We defined districts as rural if they were 55 miles 
or farther from a metropolitan statistical area.

* Nonrural districts. We defined districts as nonrural if they were 
located less than 55 miles from a metropolitan statistical area.

To obtain information from the most rural school districts, we further 
stratified our sample by size. The literature suggests that smaller 
districts may face unique challenges.

* Small rural districts. We defined districts as small rural if they 
were 55 miles or farther from a metropolitan area and had 300 or fewer 
students.

* Other rural districts. We defined districts as other rural if they 
were 55 miles or farther from a metropolitan statistical area but had 
more than 300 students.

We used Education's Common Core of Data (CCD) to draw the sample of 
school districts for our survey. Figure 1 presents the distribution of 
small rural and other rural districts based on the definition we use 
that incorporated distance from metropolitan area.

Figure 1: Small Rural and Other Rural Districts:

[See PDF for image]

[End of figure]

In addition to the survey, we made site visits to six states--Maine, 
Mississippi, Montana, Nebraska, North Dakota, and South Dakota. In 
addition, we conducted telephone interviews with officials in four 
states--Alaska, Iowa, Kansas, and Vermont. We selected these states 
because they were the most rural states in the country, based on the 
percentage of their school districts in rural communities, the 
percentage of their students attending schools in rural communities, 
and the average distance between the school district in the state and 
the nearest metropolitan statistical area as a measure of geographic 
isolation. In addition, we included Wyoming because of the large 
geographic distance that its school districts cover. We selected school 
districts to visit in these states based on variation in student 
enrollment, geographic isolation, school proficiency, and demographic 
characteristics. Figure 2 shows the rural states that we visited and 
contacted by telephone.

Figure 2: Rural States Contacted:

[See PDF for image]

[End of figure]

We also conducted telephone interviews with educational association 
representatives and other experts, met with Education officials, and 
reviewed guidance and data from Education. In some cases, our survey 
and site visits predated Education's guidance that addressed some 
issues relevant to rural schools and districts. When this occurred, it 
was identified in the report in the context of related findings. For a 
more detailed explanation of our methodology, see appendix I. We 
conducted our work in accordance with generally accepted government 
auditing standards between August 2003 and August 2004.

Results in Brief:

Rural districts we surveyed faced challenges in meeting NCLBA student 
proficiency goals and implementing teacher qualification requirements 
and faced some of these challenges to a greater extent than nonrural 
districts. In terms of meeting NCLBA's student proficiency goals, 
officials in rural districts were more likely than those in nonrural 
districts to report that a large enrollment of economically 
disadvantaged students created challenges. These students may not have 
the community resources, such as libraries and computers, that may be 
associated with improved academic performance. Rural districts were 
more likely to report difficulties in offering competitive salaries to 
teachers, limiting their ability to recruit teachers; 52 percent of 
officials in rural districts reported this as a challenge compared with 
36 percent of officials in nonrural districts. In our analysis of small 
rural districts, we found that they were more likely than other rural 
districts to report that school size and geographic isolation were 
factors that affected NCLBA implementation. About half of small rural 
districts, compared with about a quarter of other rural districts, 
reported school size as greatly affecting their ability to implement 
student proficiency provisions. For example, officials in small rural 
districts told us that limited personnel made it difficult to release 
teachers and administrators for attending Education's conferences and 
training. These conferences and training are designed to help teachers 
and administrators better understand what student proficiency goals are 
and how they can help their students meet them. In addition, rural 
district officials indicated that they typically had few staff, which 
created difficulties completing tasks associated with meeting NCLBA 
requirements, such as developing and disseminating reports on school 
progress.

Rural and nonrural districts generally reported using some similar 
strategies, such as teacher training to increase subject matter 
knowledge, to meet student proficiency provisions and implement teacher 
qualification requirements of NCLBA. However, differences between rural 
and nonrural districts were found in the extent to which they reported 
the use of other strategies. For example, rural districts were more 
likely to use distance learning, such as receiving training online, for 
providing instruction to teachers in implementing teacher qualification 
requirements. Small rural districts were less likely to report the use 
of some strategies, such as teacher mentoring programs, than other 
rural districts. For example, about half of small rural districts 
reported offering mentoring programs for teachers, compared with about 
three-quarters of other rural districts. Factors such as having very 
few teachers, existing teachers having to teach multiple subjects and 
grade levels, and large distances to other rural districts limit small 
rural districts' pool of teachers available to serve as mentors for 
other teachers.

Rural state and district officials we interviewed identified some 
specific NCLBA related expenditures such as some teacher training and 
paying for staff to supervise students while they received instruction 
from online tutors. However, officials found it difficult to determine 
all expenditures made to implement NCLBA, primarily because their 
accounting records were not maintained in a way that categorized 
expenditures according to whether or not they were associated with 
NCLBA requirements. NCLBA does not require states or districts to 
report separately on expenditures related to implementation. Further, 
projecting expenditures that will be needed in the future to meet the 
goals of NCLBA is difficult because necessary data are often not 
available to produce such estimates. For example, it is difficult to 
project expenditures needed for meeting student proficiency provisions 
because there is insufficient research on what strategies will help all 
students reach academic proficiency goals. State and rural district 
officials reported using multiple funding sources to support their 
NCLBA implementation efforts. Besides state and local funds, they 
relied on federal appropriations under NCLBA, and the majority of rural 
districts reported receiving funds provided under the Rural Education 
Achievement Program (REAP).

Education has provided all states and districts with guidance and 
assisted them in a variety of ways; however, officials from rural 
states and districts, including small rural districts, told us further 
assistance would be helpful in addressing their issues. Beginning in 
2002, after the passage of NCLBA, Education provided guidance 
applicable to all states and districts, and communicated with state 
officials through site visits and conferences. For example, Education 
sent a team of experts to every state to obtain information on their 
challenges and provide assistance on implementing the teacher 
qualifications requirements of NCLBA. Since April 2003, Education's 
actions have focused more directly on rural education issues. Education 
introduced new flexibilities that were intended, among other things, to 
assist rural states with meeting student proficiency provisions and 
implementing teacher qualification requirements. For example, under 
some circumstances, teachers in rural districts are allowed extra time-
-up to 3 years--to meet teacher qualification requirements. Also, 
states can now use a single state test for teachers to demonstrate 
subject matter competency for core academic subjects that they teach 
instead of a separate test for each subject taught. This could be 
especially helpful to rural districts and schools where a single 
teacher might have to teach multiple subjects. Education also 
established a Rural Education Taskforce to coordinate and focus rural 
education efforts within the department. Further, Education has 
recently awarded a grant to establish a National Center for Research 
and Development in Rural Education. In addition, states we contacted 
provided districts with guidance and assistance to help them implement 
NCLBA, and most rural districts surveyed found state assistance 
helpful. However, even with state and Education assistance, a majority 
of the rural districts surveyed reported that their implementation 
issues have not been fully addressed. For example, almost three-
quarters of rural district officials responding to our survey reported 
the need for information on remedial services that will help students 
meet academic proficiency goals. In addition, small rural districts and 
those that may be very isolated continued to face unique challenges in 
recruiting, retaining, and training teachers, and lacked strategies to 
address them. Education officials told us they are continuing to work 
on rural issues and provide more guidance in an effort to assist rural 
states.

To assist rural states in meeting the provisions of NCLBA, we are 
recommending that Education provide additional assistance on 
implementation approaches small rural districts can use to address 
their unique challenges and direct its National Research and 
Development Center on Rural Education to focus on effective, 
scientifically based methods that can be applied to improve student 
performance in small rural districts.

In its comments on a draft of this report, the department discussed but 
did not explicitly agree or disagree with our recommendations. For both 
recommendations, Education provided new information that was 
incorporated, as appropriate, in the report.

Background:

The NCLBA of 2001 amended and reauthorized the Elementary and Secondary 
Education Act, the largest and most comprehensive federal education 
law.[Footnote 1] Title I of NCLBA provides funds to states for 
educating students from low-income families and is the single largest 
federal program supporting education in kindergarten through 12th (K-
12) grade.[Footnote 2] Districts receive Title I funds based on a 
formula that incorporates, among other things, the number of children 
in poverty. Approximately 56 percent of all schools are eligible to 
receive Title I funds, compared with 65 percent of rural schools.

Rural districts comprised 25 percent of all school districts in the 
country. Rural schools and districts, on average, have fewer students 
than nonrural schools and districts and tend to be more geographically 
isolated. Moreover, rural school districts are more likely to be 
comprised of one, two, or three schools, whereas the number of schools 
in urban and suburban districts is typically higher. Further, in our 
analysis we found that 11 percent of all school districts are small 
rural districts. (See table 1 for comparisons between very small rural, 
other rural, and nonrural districts.)

Table 1: Characteristics of Small Rural, Other Rural, and Nonrural 
Districts, 2001-02:

Characteristics: Percentage of districts; 
Small rural: 11%; 
Other rural: 14%; 
Nonrural: 75%.

Characteristics: Average number of students in district; 
Small rural: 126; 
Other rural: 1741; 
Nonrural: 4015.

Characteristics: Average school enrollment; 
Small rural: 77; 
Other rural: 368; 
Nonrural: 560.

Characteristics: Average number of schools in district; 
Small rural: 2; 
Other rural: 5; 
Nonrural: 7.

Characteristics: Average number of students per teacher; 
Small rural: 11; 
Other rural: 16; 
Nonrural: 17.

Characteristics: Percentage of minority students; 
Small rural: 16%; 
Other rural: 33%; 
Nonrural: 40%.

Characteristics: Percentage of students participating in the free and 
reduced school lunch program; 
Small rural: 41%; 
Other rural: 42%; 
Nonrural: 36%.

Characteristics: Average per pupil cost; 
Small rural: $9,420; 
Other rural: $6,970; 
Nonrural: $7,820. 

Source: GAO analysis of Education's 2001-02 Common Core of Data and 
2001 U.S. Census Bureau's Public Elementary-Secondary Education Finance 
Data.

Note: Valid data on students' participation in the free and reduced 
school lunch program were not available for Arizona, Connecticut, 
Tennessee, and Wyoming.

[End of table]

In addition to the characteristics listed in Table 1, small rural 
districts may have unique geographic characteristics that distinguish 
them from other districts. Small rural districts can exist in unique 
locations, such as small islands off the coasts of states, usually 
making air or sea transportation a necessity. Small rural districts can 
also be located in mountainous areas with difficult terrain and roads 
that may not be passable for some part of the year because of extreme 
weather conditions. These weather conditions can also affect 
accessibility to electrical power. Small rural districts can also be 
located long distances from other districts, towns, and universities.

In recent years, the Congress and other parts of the federal government 
have demonstrated a growing interest in rural schools. The House and 
Senate Rural Education Caucuses, consisting of bipartisan groups of 
members of Congress, were formed to advance the education interests of 
rural schools and districts. Further, the Congress authorized a Rural 
Education Achievement Program (REAP) to help rural districts compete 
for and make more effective use of federal grants. REAP was designed to 
help rural districts that may lack the personnel and resources to 
compete effectively for federal competitive grants. It is comprised of 
two programs: (1) The Small, Rural School Achievement program 
authorizes the Secretary of Education to award formula grants directly 
to eligible school districts; (2) The Rural and Low-Income Schools 
program is designed to address the needs of rural, low-income schools, 
and authorizes the Secretary to award formula grants to state 
educational agencies, which in turn award subgrants to eligible school 
districts either competitively or on a formula basis. The funds can be 
used for many activities, including teacher recruitment and retention, 
professional development, and educational technology. The Congress 
appropriated approximately $168 million for REAP funding in fiscal year 
2003. Finally, the National Center for Education Statistics (NCES) has 
made improvements in its classification of schools to accommodate more 
information about location, making it possible to develop more refined 
information about rural education.[Footnote 3] NCES also established a 
rural education data section on its Website, called Navigating 
Resources for Rural Schools.

NCLBA was designed to raise the academic achievement of students and 
the qualifications of teachers, and states, districts, and schools are 
currently in their third year of its implementation. Key provisions of 
the law included the following:

Academic content standards and yearly academic assessments. NCLBA 
requires that states develop and implement academic content and 
achievement standards in math, reading/language arts, and science, and 
that annual assessments are aligned to these standards. States must 
administer annual student assessments that are aligned with state 
standards. Beginning in the 2005-06 school year, state assessments in 
math and reading/language arts must be administered every year in 
grades 3 through 8 and once in high school, and by 2007-08, states must 
also measure students' science achievement. All students, including 
students with limited English proficiency and those with disabilities, 
are required to participate in assessments.

Adequate yearly progress and student proficiency goals. NCLBA requires 
states to develop annual goals for adequate yearly progress (AYP) that 
schools and districts must meet to ensure that every student becomes 
proficient in math and reading/language arts by school year 2013-14. 
The annual goals on state assessments and the final target of 100 
percent student proficiency applies to all students and those in 
designated groups, including economically disadvantaged students, 
major racial and ethnic groups, students with disabilities, and 
students that have limited English proficiency. Schools must also show 
that 95 percent of their students--overall and within each subgroup--
participated in the assessments. In addition to including annual 
assessment results, high schools must include students' graduation 
rate, and elementary and middle schools must include one other academic 
indicator determined by the state to assess whether they made annual 
progress.

Teacher qualification requirements. Teachers of core academic subjects 
must be certified to teach by their state, have a bachelor's degree, 
and demonstrate subject matter competency in each core academic subject 
they teach by the end of school year 2005-06. Subject matter competency 
can be demonstrated in either of two ways: (1) successful completion of 
an academic major, coursework equivalent to a degree, or advanced 
certification in each subject or (2) passing a high, objective, uniform 
state standard of evaluation developed by the state to certify 
teachers' knowledge of the subjects they teach. In addition to 
teachers, paraprofessionals are required to have two years of college, 
or an associate's degree, or a rigorous standard of quality on formal 
state or local assessment. Improving teacher qualifications is 
identified in the NCLBA as a strategy to raise student academic 
achievement. For example, by learning new instructional approaches and 
enhancing subject matter expertise, teachers will be better equipped to 
help students learn.

School choice. After 2 years of not making adequate progress toward 
reaching student proficiency goals, schools receiving Title I funds 
must offer all their students the option to transfer to a higher-
performing public school within the district. Under circumstances where 
no viable transfer options exist-as in districts with only one school 
serving all grade levels, districts are expected, to the extent 
practicable, to make arrangements with other districts to accept their 
transfer students and may offer supplemental educational services.

Supplemental educational services. After 3 or more years of not making 
adequate progress toward reaching student proficiency goals, schools 
receiving Title I funds must offer supplemental educational services, 
such as tutoring in reading and math, to low-income students in the 
school. States are required to provide a list of acceptable providers 
of supplemental educational services to school districts and monitor 
the performance of the provider, including success in improving student 
performance.

In addition, NCLBA requires that all federally funded instruction, 
technical assistance, and professional development activities be 
supported by scientifically based research. However, this type of 
research is limited in the education field. For example, this body of 
research does not generally include the use of control groups and 
randomly assigned subjects in experiments, techniques used in physical 
science research to show that outcomes are caused by program 
interventions and not other factors. Education is currently expanding 
its grant awards to support scientifically based research in education.

State education officials play a major role in the implementation of 
NCLBA in their states and districts. Some key decisions to be made by 
state officials include:

* Developing academic content standards and assessments for math, 
reading/language arts, and science, and determining the level of 
proficiency each student must reach on assessments.

* Defining the criteria for state certification of teachers and 
identifying tests teachers are required to take to demonstrate subject 
matter competence.

* Determining the smallest number of students that must be enrolled in 
a school, as well as in designated student groups, necessary for their 
test results to be used in determining whether a school has met 
proficiency goals. States have selected a wide range of numbers for 
this purpose; the majority of states set their group size minimums at 
between 25 and 45 students.

* Deciding whether or not they will accept NCLBA funding and thus agree 
to the implementation of NCLBA requirements in their state.

* Developing a plan for submission to Education that, among other 
things, demonstrates how the state will meet requirements for setting 
annual goals and measuring student progress.

Education provides technical assistance to help states understand the 
law and for monitoring their progress in meeting the law's student 
proficiency provisions and teacher qualification requirements. The 
Secretary of Education is required to report to the Congress annually 
regarding state progress in implementing various requirements, 
including how many of their schools were identified for improvement.

Rural Districts and States Faced Challenges in Implementing NCLBA:

Rural districts faced challenges in meeting student proficiency goals 
and implementing teacher qualification requirements of NCLBA and faced 
some of them to a greater extent than nonrural districts. State 
officials we interviewed also cited challenges to implementing student 
proficiency provisions on both the state and the district level. Rural 
districts also identified small school size and geographic isolation as 
greatly affecting their ability to implement NCLBA.

Rural Districts Reported Similar Challenges as Nonrural Districts in 
Meeting Student Proficiency Goals but Faced Some of Them to a Greater 
Extent than Nonrural Districts:

Rural districts were more likely than nonrural districts to report some 
challenges in meeting student proficiency goals. For example, officials 
in about 52 percent of rural districts surveyed reported that a large 
enrollment of economically disadvantaged students created challenges to 
meeting student proficiency goals; about 40 percent of nonrural 
districts reported this as a challenge.[Footnote 4] During our site 
visits, several rural district officials with large numbers of 
economically disadvantaged students told us that these students 
generally did not have structures in their communities or homes that 
are typically associated with improved academic performance. For 
example, some communities did not have libraries near where many of 
their students lived. As a result, during our site visits rural 
district officials noted their economically disadvantaged students 
often required more resources and instruction time at the school than 
other students to meet student proficiency goals. Another challenge 
reported to a greater extent by officials in rural districts than 
nonrural districts was declining student enrollment. This could result 
in reducing the number of teachers in a school or district, and the 
remaining teachers assuming additional responsibilities for subjects 
taught.

Rural and nonrural districts reported some challenges to the same 
extent, such as a large enrollment of students with disabilities. About 
half of both rural and nonrural district officials reported large 
enrollment of students with disabilities to be affecting their ability 
to meet student proficiency goals. Students with disabilities often 
require more services and assistance to help them achieve academic 
proficiency. For example, students with learning disabilities may 
require additional services from a reading resource teacher. Further, 
several rural state and district officials explained that although most 
students with disabilities participated in the standard state 
assessment tests, they may require extended time and other 
accommodations to take these tests. Officials noted that offering such 
accommodations or services in rural areas may be difficult due to 
limited staff available to provide them or the increased cost of 
transporting students to sites where services could be received. A 
quarter of both rural and nonrural districts noted that it was 
challenging to provide services, such as tutoring or after-school 
enrichment, to help students achieve proficiency.

Rural state officials we interviewed also identified several 
difficulties in implementing student proficiency provisions. For 
example, rural state officials cited difficulties performing 
administrative duties, such as developing state plans and notifying 
districts of improvement actions required under the law. Most rural 
state officials we contacted noted that their state education offices 
had few staff yet were responsible for meeting the same requirements as 
all other states. In addition to having a limited number of staff 
responsible for multiple tasks, most state officials said that they did 
not always have the information on and explanation of the latest 
guidance from Education. Although Education was making efforts to get 
information to the states, rural state officials told us that they had 
few administrative staff to act on that information once it arrived.

Rural Districts Faced Some Challenges to a Greater Extent than Nonrural 
Districts in Implementing Teacher Qualification Requirements:

Rural districts were more likely than nonrural districts to identify 
certain challenges to implementing NCLBA's teacher qualifications 
provisions. (See table 2.)

Table 2: Percentages of Rural and Nonrural District Superintendents 
Reporting Challenges in Implementing NCLBA's Teacher Qualification 
Requirements:

NCLBA's highly qualified teacher provision: 

Challenges: Competing in salary with other school districts for highly 
qualified teachers; 
Percentage of rural district superintendents: 52%; 
Percentage of nonrural district superintendents: 36%.

Challenges: Few professional development opportunities for teachers; 
Percentage of rural district superintendents: 15%; 
Percentage of nonrural district superintendents: 6%.

Source: GAO survey data.

Notes: Percentages above show the proportion of respondents who 
reported being affected by a particular factor to a great or a very 
great extent.

Each difference between rural and nonrural districts in this table is 
significant at the 95 percent confidence level.

[End of table]

More than half of officials in rural districts reported that it was a 
challenge to offer competitive salaries to teachers, compared with 
about one-third of officials in nonrural districts. According to rural 
district officials, as well as organization representatives we spoke 
with, it was often difficult for school districts to recruit and retain 
teachers when the salaries they offered were low. One rural district 
official we spoke with told us that it was difficult for her district 
to recruit new teachers because teacher salaries in her state were so 
low; average teacher salaries in her state were among the lowest in the 
nation. Recent data show that teacher salaries in the 10 most rural 
states, excluding Alaska, rank among the lowest in the nation, 
generally reflecting regional differences in the cost of 
living.[Footnote 5] However, officials in rural districts noted that 
other factors, such as geographic isolation, also affected their 
ability to recruit and retain teachers. Additionally, 15 percent of 
rural district superintendents reported having few professional 
development opportunities for teachers as a factor that affected their 
ability to implement NCLBA's highly qualified teacher requirements, 
while 6 percent of nonrural district superintendents reported this as a 
factor. In rural districts it is not uncommon for schools to be 
separated by long distances from the nearest college or training 
facility and have limited access to the Internet. Some district staff, 
such as those in isolated communities, may have to travel three or more 
hours to reach training facilities; others, such as those located on 
island districts, must use planes or boats to travel to training. Rural 
state officials we interviewed also expressed concerns about 
implementing teacher qualification requirements similar to those 
reported by survey respondents. In particular, they noted the challenge 
of ensuring that all teachers demonstrate subject matter competency in 
the subject that they teach by the deadline in the law. Even though 
states had several options for teachers to demonstrate subject matter 
competency, including a state-developed test, officials did not know 
whether these alternatives could be developed within the required time 
frames.

Rural Districts Faced Additional Implementation Challenges Related to 
Small Size and Isolation:

Rural districts also identified small school size and geographic 
isolation as greatly affecting their ability to meet student 
proficiency provisions and implement teacher qualification 
requirements of NCLBA, with the small rural districts more likely than 
other rural districts to report these factors. (See table 3.) According 
to our definition of rural districts, all were isolated, that is, 55 
miles or farther from metropolitan areas. However, those rural 
districts that were also small--fewer than 300 students--were more 
likely to report isolation as a challenge. The majority of nonrural 
districts did not report these factors as challenges.

Table 3: Percentages of Small Rural and Other Rural District 
Superintendents Reporting Additional Challenges in Implementing 
Various NCLBA Provisions:

NCLBA's student proficiency provision: 

Challenges: Very small school size; 
Percentage of small rural district superintendents: 52%; 
Percent of other rural district superintendents: 23%.

Challenges: Geographic isolation; 
Percentage of small rural district superintendents: 39%; 
Percent of other rural district superintendents: 28%.

Challenges: NCLBA's highly qualified teacher requirement: 

Challenges: Very small school size; 
Percentage of small rural district superintendents: 54%; 
Percent of other rural district superintendents: 29%.

Challenges: Geographic isolation; 
Percentage of small rural district superintendents: 51%; 
Percent of other rural district superintendents: 38%. 

Source: GAO survey data.

Notes: Percentages above show the proportion of respondents who 
reported being affected by a particular factor to a great or a very 
great extent.

We calculated confidence intervals for our study using methods that are 
appropriate for a stratified, probability sample. For the percentages 
presented in this report, we are 95 percent confident that the results 
we would have obtained if we had studied the entire population are 
within plus or minus 10 percentage points of our results.

[End of table]

Small school size:

Small school size was associated with several difficulties for schools 
trying to implement NCLBA's student proficiency provisions, according 
to survey results and our site visit interviews. About half of small 
rural district officials we surveyed reported school size as a factor 
affecting their ability to implement student proficiency provisions, 
compared with about one-fourth of officials in other rural districts. 
Officials we visited also cited difficulties related to small school 
size, such as having fewer administrative staff and limited expertise 
that reduced their capacity to perform tasks associated with NCLBA 
provisions. For example, for small administrative staff, completing the 
paperwork associated with NCLBA--such as preparing and distributing 
reports on assessment results--was a substantive addition to their 
workload. Further, district staff often had to assume multiple roles, 
which reduced the amount of time they could spend on collecting and 
disseminating information on promising implementation strategies, as 
well as designing and implementing them to raise student performance. 
Some school district superintendents in single K-12 school districts 
explained that they had to fulfill the duties of superintendent as well 
as those of principal and teacher at their K-12 schools. Furthermore, 
limited personnel made it difficult to release teachers and 
administrators to attend conferences and receive training that might 
help them address student proficiency goals. One rural district 
official told us that he could not afford to allow his staff to take 
off time to attend training on assessments because substitute teachers 
were difficult to find. Moreover, officials told us that rural states 
in which these districts were located had few staff themselves, which 
limited their ability to provide assistance to the districts. In 
addition, districts not meeting student proficiency goals faced 
difficulties in offering supplemental educational services to students 
because of the small school size. According to some rural officials, 
providers were reluctant to provide services in rural districts because 
the small number of children who may need these services do not provide 
a profitable business opportunity.

Small school size also created difficulties for schools trying to 
implement NCLBA's teacher qualification requirements, which slightly 
more than half of small rural districts reported as a challenge, 
compared with about one-quarter of other rural districts. On average, 
77 students are enrolled in schools in small rural districts and rural 
state and district officials told us that some small rural schools 
might have only two or three students in each grade, requiring teachers 
to take responsibility for teaching multiple subjects across different 
grade levels. For example, officials in one rural district we contacted 
explained that its three teachers were responsible for teaching every 
subject to 15 students enrolled in grades K-12. Many district officials 
we spoke with said that such small student enrollment made it more 
challenging for teachers to meet the definition of highly qualified in 
each core academic subject they teach. It also made it difficult for 
teachers to take time off to attend professional development classes 
because substitutes were generally not available in small districts.

In March 2004, Education issued new guidance allowing states to 
administer a single evaluation to determine competency in multiple core 
academic subjects. However, some state officials told us that 
developing a test to gauge teachers' competency in every core subject 
was a formidable task that would require time, expertise, and other 
resources. Additionally, while guidance extended the time for obtaining 
subject matter competency to existing teachers in some rural districts, 
extending time for teachers to meet the requirements did not address 
the underlying problem of a lack of professional development 
opportunities.[Footnote 6]

Geographic isolation:

Geographic isolation created difficulties for districts to implement 
NCLBA provisions, particularly the supplemental educational services 
component. During our site visits, district officials explained that 
they were often unable to use supplemental educational service 
providers on approved state lists. Officials stated that traveling long 
distances to meet the providers was generally not a viable option for 
students, and thus they choose not to offer them. For example, when one 
rural district made an effort to offer supplemental educational 
services, it took students 3 hours to reach the provider's site. 
According to state and district officials, the use of online service 
providers as an option was difficult in some small rural districts, 
especially those where severe weather conditions and physical features 
such as mountains made it difficult to establish and maintain Internet 
lines. Many of the rural school district superintendents we interviewed 
in states such as Montana, Alaska, South Dakota, North Dakota, and 
Maine noted that frequent power outages and poor transmissions hindered 
the use of distance learning. Other officials explained that even when 
Internet capabilities were established, it was difficult to recruit 
technical maintenance personnel to isolated rural areas.

Geographic isolation was also associated with difficulties in 
implementing teacher qualification requirements, according to district 
officials. About half of small rural districts identified geographic 
isolation as greatly affecting their ability to implement teacher 
qualifications provisions, compared with about one-third of other rural 
districts. Several district officials we interviewed also said that 
geographic isolation made it difficult for current teachers to obtain 
the training they need to become certified in every subject taught. 
Because long distances and boundaries such as mountains or bodies of 
water can separate small rural districts from training opportunities, 
rural districts may need to rely on atypical means to get there. For 
example, the superintendent of one very small and isolated rural 
district we spoke with reported that traveling by air or boat was the 
only option to reach the nearest college where his teachers could 
receive appropriate training. In another district, officials said that 
the nearest college where teachers and paraprofessionals could obtain 
the necessary credentials was more than 600 miles away.

Additionally, the remote environment could be a deterrent to new 
teachers seeking employment. During our site visits, districts 
officials explained that geographic remoteness impeded the ability of 
rural districts to recruit and retain teachers because of the lack of 
social opportunities, severe weather conditions, and long distances to 
the nearest metropolitan area. For example, officials from several very 
isolated districts we spoke with explained that at times weather was so 
severe that teachers and other school staff were forced to live in the 
school until severe weather conditions subsided.

Rural and Nonrural Districts Generally Reported Using Similar 
Strategies to Implement NCLBA, but Small Rural Districts Were Less 
Likely to Use Them:

Rural and nonrural districts used similar strategies, such as providing 
training for teachers, to meet student proficiency provisions and 
teacher qualification requirements of NCLBA. However, small rural 
districts were less likely than other rural districts to use the 
strategies for implementation of these provisions.

Rural and Nonrural Districts Used Some Similar Strategies in 
Implementing Student Proficiency Provisions:

The primary strategies used to meet student proficiency goals, reported 
by about 90 percent of both rural and nonrural district superintendents 
surveyed, were remedial services, such as tutoring for students, and 
additional training for teachers. (See table 4.)

Table 4: Percentages of Rural and Nonrural District Superintendents 
Reporting Specific Strategies to Meet Student Proficiency Goals:

Strategy: Provided remedial services to students at risk of failing[A]; 
Percentage of rural district superintendents: 89%; 
Percentage of nonrural district superintendents: 94%. 

Strategy: Provided additional training for teachers; 
Percentage of rural district superintendents: 90%; 
Percentage of nonrural district superintendents: 93%. 

Strategy: Provided test opportunities for students[A]; 
Percentage of rural district superintendents: 77%; 
Percentage of nonrural district superintendents: 86%. 

Strategy: Provided additional computer capability[A]; 
Percentage of rural district superintendents: 76%; 
Percentage of nonrural district superintendents: 68%. 

Strategy: Provided teacher mentoring[A]; 
Percentage of rural district superintendents: 62%; 
Percentage of nonrural district superintendents: 75%. 

Source: GAO survey data.

[A] We calculated confidence intervals for our study using methods that 
are appropriate for a stratified, probability sample. For the 
percentages presented in this report, we are 95 percent confident that 
the results we would have obtained if we had studied the entire 
population are within plus or minus 10 percentage points of our 
results.

[End of table]

Among rural districts we contacted, most offered tutoring, extended day 
and summer programs, or other remedial services to help students 
improve academically. For example, one rural district we visited made 
after-school tutoring in reading and math available to students four 
nights per week, while another rural district extended its academic 
program by two hours and introduced Saturday programs to help raise 
students' academic achievement. Officials told us that such in-school 
programs were particularly valuable in rural areas lacking other 
enrichment opportunities. Furthermore, to help meet adequate yearly 
progress provisions related to high school graduation rates, one school 
district implemented a mentoring program for students in grades 6-12 by 
district staff, while another was establishing an alternative high 
school for recent dropouts on the campus of a local community college; 
officials in both districts indicated that the purpose of these 
programs was to help increase graduation rates among high school 
students. Consistent with what the survey respondents reported, some 
rural districts we visited also provided additional training for 
teachers to help improve the level of instruction to students. Those 
strategies included, for example, training on ways to more effectively 
teach reading and math, as well as training on assessments required 
under NCLBA. However, many of the strategies cited by district 
officials were used even before NCLBA, and officials were uncertain 
about the effectiveness of these strategies in helping all students 
meet academic proficiency goals.

Although they reported doing so to a lesser extent, rural and nonrural 
districts also used other strategies to implement student proficiency 
provisions, and differences were found in the extent to which rural and 
nonrural districts used many of them. (See table 4.) For example, rural 
districts were less likely than nonrural districts to offer mentoring 
for teachers--62 percent of rural district superintendents reported the 
use of this strategy compared with 75 percent of nonrural district 
superintendents. Mentoring programs, which employ the skills and 
experience of a more senior teacher to assist newer teachers, can serve 
a variety of purposes. One rural district we visited, for example, 
offered mentoring to better familiarize teachers with standards-based 
curriculum and to enhance the quality of instruction they provide to 
students. However, several officials noted that rural districts might 
experience difficulties offering such mentoring opportunities due to 
their limited resources and small staff. On the other hand, rural 
districts were more likely to increase computer capacity, such as 
adopting distance learning technology in order to provide video class 
instruction, than nonrural districts. Officials in some rural states 
also reported on their efforts to invest in statewide technology 
initiatives to help districts improve their technological capability 
and use technology, such as distance learning, for raising students' 
academic achievement. One rural state we visited, for example, launched 
an initiative to provide every 7th and 8th grader in the state with a 
laptop computer, thus enabling students in even the most remote rural 
areas in that state to gain access to a wide array of academic 
opportunities available through the Internet. Several officials, 
however, were concerned about the effectiveness of online instruction 
for low-achieving and younger students who may need direct teacher 
contact.

Additionally, other strategies for meeting student proficiency goals 
were reported, although they were used by less than half of rural and 
nonrural superintendents. For example, less than half of both rural and 
nonrural district superintendents reported coordinating with regional 
educational service agencies (ESA) in an effort to help students attain 
academic proficiency goals.[Footnote 7]

Rural and Nonrural School Districts Used Similar Strategies in 
Implementing Teacher Qualification Requirements:

Rural districts also used a variety of strategies to implement NCLBA 
teacher qualification requirements; the use of most of these strategies 
by rural districts was not different from their use by nonrural 
districts, according to survey results. The primary strategies used by 
the majority of all districts were teacher and paraprofessional 
training and dissemination of information to schools on exemplary 
practices. (See table 5.)

Table 5: Percentages of Rural and Nonrural District Superintendents 
Reporting Specific Strategies to Implement NCLBA's Highly Qualified 
Teacher Provisions:

Strategy: Provided training for teachers; 
Percentage of rural district superintendents: 83%; 
Percentage of nonrural district superintendents: 81%.

Strategy: Disseminated information on exemplary practices to schools; 
Percentage of rural district superintendents: 74%; 
Percentage of nonrural district superintendents: 80%.

Strategy: Encouraged paraprofessionals to meet teacher qualification 
requirements and become teachers; 
Percentage of rural district superintendents: 58%; 
Percentage of nonrural district superintendents: 63%.

Strategy: Obtained services from ESAs; 
Percentage of rural district superintendents: 50%; 
Percentage of nonrural district superintendents: 48%.

Source: GAO survey data.

Note: The differences between rural and nonrural districts in this 
table are not significant at the 95 percent confidence level.

[End of table]

Likewise, these strategies were cited by rural state and district 
officials that we visited. Many rural states and districts we visited 
provided teachers and paraprofessionals with professional development 
opportunities to help them obtain the necessary qualifications. For 
example, in one rural state we visited, officials said they developed 
training programs for teachers to obtain subject area certifications. 
They also said that most of their teachers who needed to become highly 
qualified chose to take advantage of these state-funded programs 
because they could obtain the necessary coursework free of charge. In 
another rural state, one small and isolated rural district offered 
courses in the school to paraprofessionals for which they could receive 
credits from a local community college. Several rural districts we 
visited were collecting and sharing information on exemplary practices 
in raising students' academic performance with district staff. For 
example, in one rural district visited, officials learned of another 
state developing individualized education programs for each student, 
not just students with disabilities, and disseminated information on 
this approach for staff in their own district to adopt.[Footnote 8]

The strategy for implementing teacher qualification requirements that 
rural districts were more likely to use than nonrural districts was 
distance learning for providing instruction to teachers and 
paraprofessionals, as well as for students to receive instruction from 
a highly qualified teacher in another location. (See table 6.)

Table 6: Percentages of Rural and Nonrural District Superintendents 
Reporting the Use of Distance Learning Technology in Implementing 
NCLBA's Highly Qualified Teacher Provisions:

Strategy: Used distance learning for teacher training; 
Percentage of rural district superintendents: 47%; 
Percentage of nonrural district superintendents: 35%.

Strategy: Used distance learning to provide a highly qualified teacher 
in the classroom; 
Percentage of rural district superintendents: 35%; 
Percentage of nonrural district superintendents: 18%.

Source: GAO survey data.

Note: Each difference between rural and nonrural districts in this 
table is significant at the 95 percent confidence level.

[End of table]

Among rural districts contacted, some used distance learning for 
teachers or paraprofessionals to take classes to meet NCLBA's 
qualification requirements, an approach that officials indicated was 
very helpful in rural districts located far away from higher learning 
institutions. Officials also cited rural districts using distance 
learning to provide courses to students by a highly qualified teacher 
when one was not available in the school. However, rural state and 
district officials, although citing advantages of distance learning, 
faced challenges in using technology, such as limited capacity or 
Internet connection difficulties. Moreover, small rural districts did 
not always know how to make best use of available technology and were 
unaware of ways in which this technology could be used to meet the 
requirements and the goals of NCLBA. For example, one small rural 
district we visited had distance learning technology and high-speed 
Internet connections in place, but officials indicated that none of the 
students were taking online classes yet, and at the time of our visit, 
they did not have the information on online professional development 
options for teachers.

Other strategies for meeting teacher qualification requirements were 
reported as well, although less than half of rural and nonrural 
district superintendents reported using them. For example, about 40 
percent of both rural and nonrural district superintendents reported 
establishing partnerships with higher education institutions to train 
teachers, and more than 10 percent of rural and nonrural districts 
created agreements with other school systems for purposes such as 
sharing highly qualified teachers. Officials indicated that some of 
these strategies might be difficult to implement in rural areas. For 
example, even though some districts were making attempts to share 
teachers, large distances made it difficult for rotating teachers to 
travel from one district to the next.

Small Rural Districts Were Less Likely to Use Some Strategies than 
Other Rural Districts:

Among rural districts, small rural districts were less likely to report 
using some strategies, such as teacher mentoring and remedial services, 
to meet student proficiency goals than other rural districts. (See fig. 
3.)

Figure 3: Percentages of Small Rural District Superintendents Reporting 
Use of Specific Strategies to Help Schools Meet Student Proficiency 
Goals Compared with Percentages of Other Rural District 
Superintendents:

[See PDF for image]

Note: Each difference between small rural and other rural districts in 
this table is significant at the 95 percent confidence level.

[End of figure]

For example, about half of small rural districts reported offering 
mentoring to teachers, compared with about three-quarters of other 
rural districts. Small rural districts may experience greater 
difficulties offering mentoring programs for teachers than other rural 
districts since they typically have even fewer teachers, those they 
have are more likely to teach multiple subjects and grade levels, and 
they are located farther from other districts--factors that limit their 
pool of teachers to serve as mentors to other teachers. Likewise, 
although most rural districts used remedial services such as tutoring, 
a smaller percentage of superintendents from small rural districts than 
superintendents from other rural districts reported offering these 
services to meet districts' student proficiency goals--81 percent 
compared with 95 percent. Rural district officials noted that offering 
remedial services to students was difficult because the distances 
students had to travel home were large and road conditions were poor, 
thus minimizing the amount of time that students could spend in school 
to participate in remedial programs. Other strategies for meeting 
student proficiency goals were generally as likely to be reported by 
superintendents from small rural as by those from other rural 
districts, and included coordinating with ESAs, providing additional 
computer capacity, and offering incentives or bonuses for teachers.

Small rural districts were also less likely than other rural districts 
to use certain strategies for meeting teacher qualification 
requirements. (See fig. 4.)

Figure 4: Percentages of Small Rural District Superintendents Reporting 
Use of Specific Strategies to Meet NCLBA's Teacher Qualification 
Requirements Compared with Percentages of Other Rural District 
Superintendents:

[See PDF for image]

Note: Each difference between small rural and other rural districts in 
this table is significant at the 95 percent confidence level.

[End of figure]

For example, about a quarter of small rural districts established 
partnerships with higher education institutions to help teachers become 
highly qualified, compared with almost half of other rural districts. 
Similarly, fewer than half of superintendents from small rural 
districts reported encouraging paraprofessionals to become highly 
qualified in order to increase their supply of teachers who met NCLBA's 
qualification requirements, compared with almost 70 percent of 
superintendents from other rural districts. Officials indicated that 
establishing partnerships with higher education institutions or sending 
paraprofessionals for training was difficult in small and isolated 
rural areas, since the nearest institutions were far away. According to 
one official working with many small rural districts, it was also not 
cost-effective for higher education institutions to send their 
representatives to these districts to offer training on-site, given a 
very small number of staff in small rural areas. Other strategies for 
ensuring that teachers met NCLBA's qualifications requirements were 
generally as likely to be reported by superintendents from small rural 
districts as by those from other rural districts, and included 
provision of training to teachers, increases of teacher salaries, and 
the use of services for teachers offered by ESAs, among others.

Rural Districts Identified Some Specific Expenditures Made for NCLBA 
Implementation and Used Multiple Funding Sources to Support 
Implementation Efforts:

Rural state and district officials identified some specific 
expenditures that they associated with implementation of NCLBA, such as 
those related to assessments and services to help students meet 
academic proficiency goals. However, officials were unable to determine 
all NCLBA implementation expenditures, in part because their accounting 
records were not maintained in a way that tracked expenditures by NCLBA 
categories. States are not required to report separately on 
expenditures related to NCLBA implementation, nor have any of the 
states we contacted required their districts to do that. Officials 
reported relying on various funding sources to support their 
implementation efforts, including different federal programs, as well 
as state and local funds.

Officials Cited Specific Expenditures Made for Implementing NCLBA:

Officials in states and districts we visited cited specific assessment-
related expenditures, including the cost of administering assessments 
and collecting and analyzing assessment results in order to identify 
students' academic needs and to inform parents and the community of 
schools' progress. For example, officials in one district visited 
indicated that they had to add 2 additional days into teachers' 
contracts to allow teachers enough time to administer and score 
assessments. Officials also indicated that assessment-related 
expenditures involved those for training teachers on new assessments. 
For example, officials in one district said that the district paid for 
a trainer to conduct a 2-day training to familiarize staff with new 
assessments.

Officials also identified expenditures related to schools' and 
districts' efforts to meet student proficiency goals, including those 
for providing remedial services to students and improving the 
curriculum. For example, one rural district we visited invested in a 
remedial reading program, after-school tutoring sessions, and a summer 
program to improve students' proficiency. Another rural district paid 
an educational research organization to review the district's math 
curriculum and make recommendations for improvement.

In addition, officials in states and districts we contacted cited some 
expenditures related to meeting NCLBA's teacher qualifications 
requirements, including the direct costs of classes and professional 
development programs that teachers and paraprofessionals attended, as 
well as other costs associated with teachers and paraprofessionals 
taking steps to meet the necessary qualifications. For example, one 
small, isolated district we visited paid for teachers to enroll in a 
semester-long distance learning class, while several others reimbursed 
paraprofessionals for taking college courses to meet NCLBA 
requirements. Officials also indicated that sending teachers to 
training led to other expenditures, such as hiring substitutes while 
teachers attended training or covering travel expenses for teachers who 
were sent to training.

Finally, officials identified expenditures related to the provision of 
supplemental educational services and school choice in districts and 
schools not meeting student proficiency goals. In addition to covering 
providers' fees, expenditures for supplemental educational services 
included those used to purchase supplies and pay staff to supervise 
students. For example, in one rural district, where only online 
providers were available, officials said that expenditures would have 
to be made to cover the cost of software and an on-site staff person to 
monitor students while they received online instruction. Rural state 
and district officials also indicated that they expected the cost of 
transportation for students eligible for public school choice under 
NCLBA to be very high, but those expenses have generally not 
materialized because choice options have been so limited in rural 
areas.

Difficulties Exist in Determining and Projecting NCLBA Implementation 
Expenditures:

Although state and district officials identified specific expenditures 
associated with NCLBA implementation, difficulties exist in determining 
all NCLBA implementation expenditures. District officials were unable 
to identify all of their current expenditures made for NCLBA purposes, 
since their accounting records were not maintained in a way that 
categorized current expenditures according to whether or not they were 
associated with NCLBA requirements. NCLBA does not require states to 
report separately on expenditures related to NCLBA implementation, and 
none of the states we contacted required their districts to do so. Our 
review of the accounting records for one district we visited disclosed 
that for fiscal years 2002 and 2003 expenditures were placed in general 
expense categories. For example, supplies purchased for use in 
providing extended day programs, which were expanded due to NCLBA, were 
placed in the same "Supplies" category as supplies purchased for 
typical school day instruction. Similarly, salaries paid for teaching 
during the extended day programs were placed in the same "Salaries" 
category as salaries paid for teaching during the regular school day; 
overtime pay and substitute costs, which officials often attributed to 
NCLBA, were also placed in this "Salaries" category. An official in 
that district indicated that it might be possible to report on NCLBA-
specific expenditures if the district changed the way accounting 
records were maintained, but doing this would be time-consuming.

In addition to the difficulties identifying all current expenditures 
associated with NCLBA implementation efforts, it is also difficult to 
determine what expenditures would have to be made in the future to meet 
NCLBA goals. One reason for this difficulty is that research and data 
needed to project total expenditures for meeting NCLBA goals are often 
not available. For example, research does not consistently suggest what 
strategies will help all students meet student proficiency goals. In 
fact, district officials told us they did not know which of the 
existing strategies would enable students to improve academic 
performance to the extent sufficient to reach NCLBA's student 
proficiency goals. As a result, projected NCLBA expenditures based on 
expanding current strategies, such as those made for tutoring or after-
school programs, may not represent the actual expenditures needed to 
meet student proficiency goals if these strategies prove to be either 
insufficient to help students meet these goals or are more than what is 
needed. Similarly, states and districts currently do not know how many 
students will use the school choice option under NCLBA and attend a 
different school within their district. Consequently, the true number 
of students who would require transportation could be higher or lower 
than what may be currently assumed, resulting in a potentially 
inaccurate estimate of transportation-related expenditures that 
districts might incur.

Another reason why projecting total NCLBA expenditures is difficult is 
that different assumptions are made about what costs should be 
included. Currently, a consensus does not exist on whether expenditures 
that originated prior to NCLBA but are now being used to help meet 
NCLBA goals should be included in the estimate of total NCLBA 
expenditures. For example, officials often cited remedial programs for 
students and professional development for teachers as being related to 
NCLBA, but these programs may already have been in place prior to 
passage of the law. This may have been true particularly for states 
that implemented systems for measuring student proficiency prior to 
NCLBA or in states that were already striving for goals and outcomes 
similar to those associated with NCLBA. In addition, it may be 
difficult to determine the extent to which NCLBA may lead some 
districts to redirect expenditures to more efficient purposes--such as 
identifying and providing services to at-risk students in earlier 
grades to reduce the need for subsequent services.

The accounting and conceptual difficulties we identified have affected 
the total expenditure estimates produced by existing studies, resulting 
in a wide range of estimates across the studies.[Footnote 9] For 
example, one study included expenditures for various strategies that 
will be provided to help students meet proficiency goals, including 
summer school, in-school tutoring, and extended day programs; on the 
other hand, another study included expenditures for 6 additional weeks 
of academic instruction to help students meet these goals. As a result, 
the studies resulted in different estimates of the total expenditures 
that would be needed to meet student proficiency provisions of NCLBA.

As states and districts have more time to implement NCLBA or if the 
studies estimating NCLBA expenditures become more focused on either 
specific provisions of the law or on particular locations in which the 
law is implemented, these difficulties may be mitigated. For example, 
as districts have more time to identify which of their schools are 
required to offer school choice to their students and as more parents 
learn about this option, data will become available on how many 
students will make use of school choice. In addition, instead of trying 
to estimate the total expenditures associated with implementing NCLBA, 
it may be less difficult to focus on individual NCLBA provisions, such 
as assessments and teacher qualification requirements. Given the 
differences in approaches that states and districts can use to meet the 
requirements of the law, it may be less difficult to determine NCLBA 
expenditures incurred by a particular district, rather than to try to 
determine expenditures for all districts in the state or for all states 
across the country. For example, some school districts required to 
offer school choice might have a school available for students to 
transfer to within their own district, while other districts might 
choose to enter into agreements with other districts to offer school 
choice; depending on whether students will have to travel within their 
own district or outside of it to attend a different school, 
transportation expenditures associated with offering school choice may 
be different across districts.[Footnote 10] Thus, focusing on 
expenditures associated with the school choice provision in one 
particular district at a time may be less difficult than attempting to 
determine a single estimate for school choice expenditures across the 
entire state. States, researchers, and education organizations have 
been working on developing methodologies to identify NCLBA 
expenditures. Some states and districts told us they are trying to find 
a method to document NCLBA expenditures separately from their 
expenditures on other state initiatives. Researchers in the education 
finance area have also been exploring methods for estimating 
expenditures. Education organizations, such as the Council of Chief 
State School Officers have also been working on developing approaches 
to identify specific activities used to implement NCLBA, as well as 
expenditures made for each of those activities.

Officials Used Multiple Funding Sources to Support NCLBA Implementation 
Efforts:

Rural district officials responding to the survey identified various 
funding sources as being very helpful in the implementation of NCLBA, 
including different federal programs, as well as state and local funds. 
Although the Congress has appropriated billions of dollars for 
education--more than $37 billion for K-12 education in fiscal year 
2004--the largest portion of district revenue typically comes from 
state and local sources of funds. According to the U.S. Census Bureau's 
Public Elementary-Secondary Education Finance Data, districts 
received, on average, roughly 7 percent of their revenues from federal 
funds in 2001, but federal funds tended to make up a slightly higher 
proportion of total revenue for rural districts than they did for 
nonrural districts. Other major district revenues included state funds 
(approximately 50 percent) and local funds (approximately 40 percent). 
Rural districts received a somewhat larger portion of their revenues 
from state funds and a smaller portion from local funds than nonrural 
districts.

Officials reported using various federal funding sources for their 
implementation efforts. According to survey results, Title I was one of 
the primary sources of federal funds, and more than 60 percent of rural 
district superintendents reported this source of funds as being very 
helpful for implementing NCLBA. In rural states and districts 
contacted, Title I funds were used for various initiatives designed to 
improve student achievement and teacher qualifications. For example, in 
one state contacted, officials indicated that Title I funds were used 
by the rural districts for remedial services in reading and math, 
initiatives to help increase academic achievement of students with 
limited English proficiency, and professional development programs for 
teachers.

More than half of rural district superintendents responding to the 
survey also reported that Title II funds for improving teacher 
qualifications were very helpful with NCLBA implementation efforts, and 
officials contacted reported using these funds to help their staff meet 
NCLBA's qualification requirements.[Footnote 11] For example, in one 
state visited, officials indicated that Title II funds were used to 
develop a portfolio-based assessment for teachers to demonstrate 
subject matter competency, as required under NCLBA.[Footnote 12] In 
addition, while the survey results showed that only 14 percent of rural 
district superintendents reported that Impact Aid was very helpful for 
NCLBA implementation, it played a large role among rural districts we 
visited that had a large proportion of Native American students; in two 
districts visited, officials told us that Impact Aid constituted almost 
half of the districts' budgets.[Footnote 13] In rural districts 
visited, Impact Aid funds were used for purposes such as providing 
remedial services for students and tuition for paraprofessionals to 
take college courses and become qualified under NCLBA.

Rural districts also used REAP funds for a variety of purposes 
associated with NCLBA implementation, including providing remedial 
services to students and professional development to teachers.[Footnote 
14] Almost 70 percent of rural district superintendents responding to 
the survey indicated that they received REAP, and the majority of them 
reported using or having plans to use REAP to address technology needs 
of students and teachers, provide remedial and supplemental educational 
services to students, and offer professional development for teachers 
to help them meet NCLBA's qualification requirements. (See table 7.)

Table 7: Percentages of Rural District Superintendents Reporting the 
Use of REAP Funds for Purposes Associated with NCLBA Implementation:

Purpose: Technology needs of students and teachers; 
Percentage of rural district superintendents: 86.

Purpose: Supplemental educational services to students; 
Percentage of rural district superintendents: 66%.

Purpose: Remedial services to students in preparation for annual 
assessments; Percentage of rural district superintendents: 60%.

Purpose: Professional development to help teachers meet NCLBA 
qualification requirements; 
Percentage of rural district superintendents: 64%.

Purpose: Annual assessments (e.g., developing and administering 
assessments, preparing report cards, disseminating information on 
assessment results, data management for reporting results); 
Percentage of rural district superintendents: 49%.

Purpose: Professional development to help paraprofessionals meet NCLBA 
qualification requirements; 
Percentage of rural district superintendents: 46%.

Purpose: After-school or extended day programs; 
Percentage of rural district superintendents: 37%.

Purpose: Recruitment of highly qualified teachers; 
Percentage of rural district superintendents: 31%.

Purpose: Recruitment of qualified paraprofessionals; 
Percentage of rural district superintendents: 19%.

Purpose: School choice; 
Percentage of rural district superintendents: 5%.

Source: GAO survey data.

[End of table]

In rural states and districts visited, officials reported that REAP 
funds have been of great assistance in implementing various initiatives 
to meet the goals of NCLBA. For example, some rural districts visited 
used REAP to provide tutoring and after-school programs for students 
falling behind, while others used REAP for programs to improve 
students' reading skills. Some districts also used REAP for teacher 
qualifications initiatives, such as sending teachers to training, 
offering signing bonuses to attract teachers to a rural location, or 
funding distance learning and video conferencing infrastructure to 
enable teachers in geographically isolated areas to take classes to 
raise their qualifications.

In addition to making additional funds available to eligible rural 
districts, REAP also allows eligible districts to spend funds under 
certain programs, such as the Safe and Drug-Free School Program, for 
activities beyond what those programs intended. For example, districts 
may choose to use funds allocated under technology and antidrug 
programs for initiatives to help students reach academic 
proficiency.[Footnote 15] In many rural states contacted, officials 
indicated that this flexibility facilitated their efforts to implement 
NCLBA by allowing them to direct funds to areas where they were most 
needed to meet NCLBA's goals. For example, in one rural state 
contacted, officials reported that many of their districts used Safe 
and Drug-Free School Program funds to support their technology 
initiatives, which, in turn, helped with implementing some of the 
provisions of NCLBA.

Among rural district superintendents responding to the survey, 84 
percent reported receiving E-Rate funds since the passage of 
NCLBA.[Footnote 16] Rural officials we contacted indicated that these 
funds facilitated their efforts to implement the law. For example, 
beginning with school year 2004-05, some rural districts in a state 
that we contacted will use E-Rate funds to finance distance learning 
infrastructure for offering professional development to teachers. In 
another rural state, the technology infrastructure created with the 
help of E-Rate helped ensure that students in isolated rural areas 
could take classes taught by highly qualified teachers in other 
locations. Several district officials noted that E-Rate discounts 
enabled them to provide or sustain Internet access, thus offering 
learning opportunities to students that may have otherwise been 
unavailable in rural areas.

In addition to using federal funds, rural districts used state and 
local funds to implement NCLBA. For example, a few rural districts we 
visited used state funds to improve technology and offer programs to 
students via mechanisms such as interactive TV. In another rural 
district visited, local property taxes were used to reimburse staff for 
taking college courses to raise their qualifications.

Education Provided Many Types of Assistance, but Rural Officials Said 
Additional Assistance Would Be Helpful:

Since the passage of NCLBA, Education has provided guidance and 
assisted all states in a variety of ways, but officials from rural 
states and districts, including small rural districts, stated that more 
assistance would be helpful to fully address their issues. Education 
has posted on its Website current NCLBA implementation guidance and 
communicated with state officials in all states through telephone 
calls, conferences, and visits. Education has employed an evolving 
approach to assistance by providing more information and expanded 
guidance as it learned more from state officials regarding questions 
and issues they had difficulty addressing. Since April 2003, Education 
has devoted more attention to rural issues. However, officials in rural 
states we interviewed told us that additional assistance addressing 
their unique challenges, such as the extreme challenges faced by small 
and isolated rural districts, would be beneficial.

Education Provided Many Types of Assistance:

Since the passage of NCLBA, Education has provided general assistance 
and guidance to all states in several ways in order to help them 
implement the legislation. (See table 8.)

Table 8: Actions Taken by Education to Assist States with 
Implementation of NCLBA and Their Intended Purpose:

Efforts to assist states: Websites providing current guidance on 
implementation, promising practices, and scientific research; 
Purpose: Clarify requirements of NCLBA to help states correctly 
implement legislation and share information among states and districts 
on successful practices taken to implement NCLBA.

Efforts to assist states: State visits--Teacher Assistance Corps; 
Purpose: Obtain information on state efforts and challenges and advise 
states on implementation of NCLBA teacher requirements.

Efforts to assist states: Conferences and workshops; 
Purpose: National and regional conferences to explain guidance, 
provide information on strategies, answer questions and obtain 
information from states and districts on their challenges.

Efforts to assist states: Superintendents' Hotline; 
Purpose: To respond to questions from district superintendents on 
NCLBA and its implementation.

Source: GAO analysis of Education's documents and interviews with 
Education officials.

[End of table]

Education's website contained information on guidance, regulations, and 
legislation. The website featured large sections devoted to NCLBA, 
including frequently asked questions and other useful information. For 
example, key requirements, such as those related to teacher 
qualifications, were highlighted with references to guidance. 
Education's website also included links to other websites. For example:

* A website on teacher qualifications (April 2004) that identified best 
practices for meeting teacher requirements. The Website also announced 
plans to hold teacher workshops on strategies for improving student 
proficiency.

* A website on supplemental educational services (May 2004) that 
provided information to administrators, teachers, and parents on 
lessons learned and available resources for providing supplemental 
educational services. The site also included links to websites of all 
state departments of education.

* A website for promising practices in offering school choice (May 
2004) to assist districts in offering parents the choice of sending 
their child to another school if the child's current school was in need 
of improvement.

Education also provided assistance through state visits, conferences, 
and a hotline for superintendents. In the summer of 2003, Education 
organized teams of experts, called Teacher Assistance Corps teams. 
These teams--composed of federal and state education officials, 
teachers, principals, superintendents, leaders from higher education, 
and others--visited every state education department to obtain 
information on how states were implementing teacher qualification 
provisions and the challenges they were facing, as well as to provide 
assistance to states on implementing these provisions. The teams 
completed visits to all states in April 2004. Education also held 
several regional and national conferences to assist states with NCLBA 
implementation. The conferences provided state and district officials 
with the opportunity to meet Education's staff, discuss implementation 
issues, and learn about recently issued guidance. In January 2004, 
Education established a Superintendents' Hotline to provide a single 
point where district superintendents could go to seek answers to their 
questions on NCLBA implementation. In addition to receiving Education's 
assistance, states we contacted provided districts with guidance and 
assistance to help them implement NCLBA, such as conducting workshops 
on NCLBA's requirements and disseminating information through state 
websites. State officials told us that they have spent considerable 
time and resources on these efforts, including the development of state 
plans that provide a road map for districts to implement the law. Rural 
districts surveyed reported assistance from the state department of 
education as the most helpful, as compared to federal and local 
agencies and other organizations.

Education Has Become More Focused on Rural Education Issues:

Since April 2003, Education has focused more efforts on rural education 
issues. At that time, Education established a Rural Education Task 
Force to coordinate and focus rural education efforts within the 
department and, according to the Executive Director of the task force, 
to bring together senior level personnel to identify rural issues and 
solutions. According to the information provided by the Executive 
Director, the task force has met with the Congressional Rural Caucus 
and several national education organizations. The task force also 
organized a virtual town hall meeting, hosted by the Secretary of 
Education, on how rural communities are using technology to meet the 
goals of NCLBA. The event was a live webcast to allow school officials 
from across the country to learn more about how their colleagues are 
using technology to achieve the goals and meet the requirements of 
NCLBA. The Executive Director also indicated that the task force 
contributed to developing the new flexibilities for rural states that 
addressed some of their challenges, such as those related to 
qualifications for teachers of multiple subjects. He said he believed 
that rural states and districts currently had all the flexibilities 
that they needed to implement NCLBA. The Executive Director added, 
however, that discussion would continue on whether there is any other 
work for the taskforce to do in assisting rural states and districts.

Education issued new flexibilities in guidance in March 2004. According 
to Education officials, the information that rural state officials 
provided to visiting Education teams, along with other communications 
with state officials, was used by Education to develop the 
flexibilities. The new flexibilities were intended, among other things, 
to assist rural states with teacher qualification and student 
proficiency provisions of NCLBA. For example, under some circumstances, 
teachers in rural districts are allowed extra time--up to 3 years--to 
meet the teacher qualification requirements, and states can now use a 
single state test for teachers to demonstrate subject area knowledge in 
multiple subjects and grades. These flexibilities may be helpful to 
some rural districts, since teachers in small rural districts may be 
expected to teach multiple subjects. In addition, schools may average 
student participation in assessment over a 3-year period, which may 
make it easier for small rural schools to meet NCLBA's assessment 
participation requirement.

Education is also overseeing a research center for rural education. In 
response to congressional legislation, Education funds national 
research and development centers that examine a wide range of education 
topics in order to provide information on educational practices and 
outcomes contributing to successful school performance. On September 
14, 2004, Education awarded a grant for the National Center for 
Research and Development in Rural Education. According to Education's 
Cooperative Agreement with the grantee, the purpose of the center is to 
develop, test, and disseminate new approaches to improve teaching and 
learning, and ultimately student achievement. The grant proposal and 
the cooperative agreement documents contain several research 
initiatives to address challenges rural districts face. According to 
the agreement document, the research agenda is focused on the 
implementation and evaluation of school-wide strategies that enhance 
rural students' academic, behavioral, and social adjustment across the 
elementary and middle school years and two supplemental studies related 
to distance learning and career exploration for rural high school 
students. However, there was no mention of any research directed to the 
unique challenges faced by small rural districts such as frequent 
inaccessibility to technology-based initiatives. Education has also 
given other grants, including one to the National Association of State 
Boards of Education that focus on assisting rural states.

Rural State and District Officials Cited the Need for More Technical 
Assistance and Information on Services That Will Help Improve Student 
Performance:

Many districts reported the need for more assistance at the time our 
survey was administered in January 2004, and officials that we 
contacted reported that Education's current assistance did not fully 
address their unique issues. For example, almost three-quarters of 
rural district officials responding to the survey reported the need for 
additional assistance on remedial services that will help students meet 
academic proficiency goals. Officials we contacted said they did not 
know which strategies would help students reach student proficiency 
goals or the extent to which strategies currently in use should be 
maintained, modified, or eliminated. Currently, scientific research on 
the effectiveness of different strategies to improve student 
performance is limited.

Officials from some states we contacted between October 2003 and April 
2004 told us that while Education's on-site teacher qualification teams 
did seek information on challenges these states were facing, they did 
not always respond to their questions. State officials with unanswered 
questions were concerned that they may be out of compliance with the 
law. Education officials told us that because they were continually 
developing new policies and flexibilities in guidance to respond to 
states' concerns, some questions could not be answered during 
Education's visits to the states.

Most state officials told us that the guidance received from Education 
for implementing various parts of NCLBA was helpful, but officials from 
nine states we interviewed cited concerns, such as guidance being in 
draft form, changing frequently, or not being issued in a timely manner 
for meeting NCLBA requirements. In response to these concerns, 
Education officials told us it was challenging to provide the support 
states needed to meet NCLBA requirements given the short time frames 
for issuing guidance to implement NCLBA provisions and the differences 
in education systems among states. Education officials said that they 
were continuing to address rural issues.

Conclusions:

NCLBA seeks to make fundamental changes in public education by 
challenging federal, state, and local education officials to reevaluate 
the way education has been delivered. For the first time, the Congress 
has specified a deadline for when it expects all students to reach 
proficiency on state assessments, showing that students possess 
knowledge of the subject matter in accordance with state standards. 
Achieving the goal of having all students proficient will be a 
formidable challenge for all states, districts, schools, and students. 
However, educators in rural areas may face additional challenges, 
primarily related to the small size of rural school districts and their 
geographic isolation.

Education made considerable efforts and progress in promulgating 
regulations, providing assistance, and working with states during the 
first two and a half years of NCLBA implementation. States also have 
devoted significant time and resources in developing state plans and 
working with districts to meet NCLBA requirements and deadlines. As a 
result of these efforts, many states are becoming better positioned to 
meet the 2014 deadline that all students be proficient. Yet, these 
efforts have not always been as successful for states with small rural 
districts because of the unique challenges they face. Small rural 
districts comprise 11 percent of all school districts in the country.

Officials in states with small rural districts, as well as the district 
officials, reported on the difficulties they were having implementing 
NCLBA provisions. Although Education issued guidance that provides 
additional flexibilities to help rural areas, challenges still exist. 
Rural districts are held accountable for student performance to the 
same extent as all other districts, so in the third year of NCLBA 
implementation, additional assistance from Education would likely help 
students in rural districts, particularly small rural districts, fully 
benefit from NCLBA.

Further, rural districts, as well as nonrural districts, reported that 
they needed information on what strategies are most effective in 
helping improve students' performance. Currently, scientifically based 
research on the effectiveness of various remedial services is limited, 
particularly research on effective strategies that takes into account 
the challenges that small and geographically isolated districts face. 
Without information from scientifically based research studies on 
effective remedial services, particularly services that can be used in 
these districts, students may not achieve the levels of academic 
progress sufficient for meeting state proficiency goals. In addition, 
without this information, districts would not know what expenditures 
they would need to make to better position themselves for meeting the 
goals of NCLBA.

Recommendations for Executive Action:

Because of the challenges small rural districts face, we recommend that 
the Secretary of Education provide additional assistance to states on 
approaches small rural districts can use to implement student 
proficiency provisions and teacher qualification requirements, 
including the application of new flexibilities.

To assist rural states in meeting student proficiency provisions of 
NCLBA, we are recommending that Education---through its recently 
established National Research and Development Center on Rural 
Education---focus on effective, scientifically based methods to improve 
student performance, and that it conduct studies on the services that 
can help small rural districts meet students proficiency provisions in 
light of the unique challenges that these districts face.

Agency Comments and Our Evaluation:

We provided a draft of this report to Education for review and comment. 
Education's written comments are reproduced in appendix II. The 
department discussed but did not explicitly agree or disagree with our 
recommendations. For both recommendations, Education provided new 
information that was incorporated, as appropriate, in the report. In 
addition, we modified the report to address Education's two technical 
comments.

In response to our recommendation that Education provide additional 
assistance to states on approaches small rural districts can use, the 
department commented that it intends to provide such assistance. In its 
comments, Education provided some additional information on the actions 
already taken and stated that it plans to take action to help states 
and districts, including those districts in rural areas. However, some 
of these actions do not address the unique challenges of small rural 
school districts, such as those with limited access to the Internet. 
Therefore, we continue to recommend that Education focus some 
assistance to address the needs of these small rural school districts.

Regarding our second recommendation, that Education use its new 
National Research and Development Center on Rural Education to address 
the unique challenges small rural districts face, Education commented 
that through the center, it would initiate a long-term program of 
research to implement and evaluate professional development strategies 
to enhance rural students' performance. Education awarded the research 
grant to fund this center on September 14, 2004, after it had received 
and reviewed our report. Education noted in its comments that the 
center will conduct research programs that will be helpful to rural 
districts, such as the effectiveness of web-and video-based programs. 
However, our findings have shown such programs may not be appropriate 
for some small, isolated rural districts that often have limited access 
to technology. On the basis of our review of the awarded grant 
proposal, we found that it contained no indication that the center 
would direct any research to specifically focus on challenges and 
strategies applicable to small, isolated rural districts. Therefore, we 
continue to recommend that through the center Education conduct studies 
on approaches that can help small rural districts meet student 
proficiency provisions in light of the unique challenges these 
districts face.

Unless you publicly announce its contents earlier, we plan no further 
distribution until 30 days after the date of this letter. At that time, 
we will send copies of this report to the Secretary of Education, 
appropriate congressional committees, and others who are interested. We 
will also make copies available to others upon request. In addition, 
the report will be available at no charge on GAO's Web site at http://
www.gao.gov. If you have any question about this report, please call me 
at (202) 512-7215. Key contributors are listed in appendix III.

Signed by: 

Marnie S. Shaul, Director: 
Education, Workforce, and Income Security Issues:

[End of section]

Appendix I: Scope and Methodology:

In conducting our work, we administered a mail survey to a nationally 
representative sample of 1,215 school district superintendents. The 
survey was conducted between January 19, 2004, and March 26, 2004. We 
analyzed survey data and identified significant results. The response 
rate for the survey was 85 percent.

The study population for the survey consisted of public school 
districts contained in the Department of Education's Common Core of 
Data (CCD) Local Education Agency (LEA) file for the 2001-02 school 
year, the latest year for which data were available. We reviewed the 
documentation for this file and conducted electronic testing of the 
file we received. Based on these reviews, we determined that the file 
was sufficiently reliable for our purposes. In addition, we determined 
the data were sufficiently accurate to serve as our study population. 
From this file, we identified a population of 14,396 school districts 
in the 50 states.

Sample. The sample design for this survey was a stratified sample of 
1,215 LEAs in the study population. To enable us to compare rural 
districts with nonrural districts, we categorized our sample as 
follows:

* Rural districts. We defined districts as rural if they were 55 miles 
or farther from a metropolitan statistical area.

* Nonrural districts. We defined districts as nonrural if they were 
located less than 55 miles from a metropolitan statistical area.

The distance of 55 miles was chosen because it reflects the 25 percent 
of districts in the country located farthest from a metropolitan 
statistical area. This definition allowed us to analyze those districts 
that may be experiencing special challenges due to their geographic 
isolation.

To ensure that we obtained information from most rural school 
districts, we further stratified our sample by size as follows:

* Small rural districts. We defined districts as small rural if they 
were 55 miles or farther from a metropolitan area and had 300 or fewer 
students.

* Other rural districts. We defined districts as other rural if they 
were 55 miles or farther from a metropolitan statistical area but had 
more than 300 students.

Estimates. All estimates produced from the district sample in this 
report were for a target population defined as all public school 
districts in the 50 states for the 2003-04 school year. Estimates of 
this target population were formed by weighting the survey data to 
account for both sample design and the response rates for each stratum.

Sampling error. Because we surveyed a sample of school districts, our 
results were estimates of a population of school districts and thus 
were subject to sampling errors associated with samples of this size 
and type. Our confidence in the precision of the results from this 
sample was expressed in the 95 percent confidence intervals. The 95 
percent confidence intervals are expected to include the actual results 
for 95 percent of the samples of this type. We calculated confidence 
intervals for our study results using methods that were appropriate for 
a stratified, probability sample. For the percentages presented in this 
report, we were 95 percent confident that the results we would have 
obtained if we had studied the entire study population were within plus 
or minus 10 percentage points of our results, unless otherwise noted. 
For example, we estimated that 39 percent of small rural school 
districts identified geographic isolation as a challenge in meeting the 
highly qualified teacher provisions of the No Child Left Behind Act 
(NCLBA). The 95 percent confidence interval for this estimate would be 
no wider than plus or minus 10 percent, or from 29 percent to 49 
percent.

Nonsampling error. In addition to these sampling errors, the practical 
difficulties in conducting surveys of this type may introduce other 
types of errors, commonly referred to as nonsampling errors. For 
example, questions may be misinterpreted, the respondents' answers may 
differ from those of the districts that did not respond, or errors 
could be made in keying questionnaire data. We took steps to reduce 
these errors.

Prior to fielding the questionnaire, we met with two outside experts in 
October 2003 to discuss the survey and listen to their suggestions. On 
the basis of these suggestions, the survey was revised. It was 
pretested with 5 district superintendents in rural and nonrural 
districts in November and December of 2003. We conducted these pretests 
to ensure that the respondents understood the questions and could 
provide the answers to them. Following these pretests, the survey 
underwent additional, mostly minor, revisions. Data edits and 
estimation programs were independently verified to ensure that 
programming errors did not affect our estimates. To reduce nonresponse, 
we sent a follow-up mailing to all school districts that had not 
responded to the survey by our deadline, followed by telephone calls to 
nonresponding districts.

Site visits. To obtain information on rural districts' experiences with 
implementing the accountability and teacher quality provisions of 
NCLBA, we made site visits and conducted telephone interviews with the 
10 most rural states: Alaska, Iowa, Kansas, Maine, Mississippi, 
Montana, Nebraska, North Dakota, South Dakota, and Vermont. These 
states represented the most rural states in the country based on the 
percentage of their school districts in rural communities, the 
percentage of their students attending schools in rural communities, 
and the average distance between the school districts in the state and 
the nearest metropolitan statistical area as a measure of geographic 
isolation. We made site visits to 6 states--Maine, Mississippi, 
Montana, Nebraska, North Dakota, and South Dakota, visiting state 
education officials, as well as officials in two or three local school 
districts in each state (see table 9). We selected school districts to 
visit on the basis of variation in student enrollment, geographic 
isolation, school performance, and demographic characteristics. In 
addition, we consulted with state education officials in helping us 
select local school districts that were in need of improvement. We 
conducted telephone interviews with officials in Alaska, Iowa, Kansas, 
and Vermont. We spoke with state education officials in each of these 
states, as well as with officials in three Alaska districts. We also 
conducted telephone interviews with state education officials in 
Wyoming because of the large geographic distance that school districts 
in that state cover.

Table 9: Site Visit States and School Districts:

State: Alaska; 
Local school district: Haines Borough; 
Local school district: Kuspuk; 
Local school district: Pelican City.

State: Maine; 
Local school district: School Administrative District 34, Belfast; 
Local school district: School Administrative District 49, Fairfield; 
Local school district: Steuben School Department.

State: Mississippi; 
Local school district: Jefferson County; 
Local school district: North Panola.

State: Montana; 
Local school district: Box Elder; 
Local school district: Browning.

State: Nebraska; 
Local school district: Creighton; 
Local school district: Santee; 
Local school district: Wheeler Central.

State: North Dakota; 
Local school district: Mandaree; 
Local school district: Selfridge.

State: South Dakota; 
Local school district: Isabel; 
Local school district: Todd County.

Source: GAO data.

Note: Interviews with state and district officials in Alaska were 
conducted by telephone.

[End of table]

Other Methodology:

We also conducted interviews with educational association 
representatives and other experts, met with Education officials, and 
reviewed guidance and data from Education. We conducted our work in 
accordance with generally accepted government auditing standards 
between August 2003 and August 2004.

[End of section]

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

UNITED STATES DEPARTMENT OF EDUCATION:

THE DEPUTY SECRETARY:

September 15, 2004:

Ms. Marnie S. Shaul: 
Director:
Education, Workforce, and Income Security Issues:
United States Government Accountability Office: 
Washington, DC 20548:

Dear Ms. Shaul:

This is in response to your request for comments on the draft report 
entitled "No Child Left Behind: Additional Assistance and Research on 
Effective Strategies Would Help Small Rural Districts" (GAO-04-909). We 
have carefully reviewed the document and appreciate this opportunity to 
provide comments to you.

We are pleased that GAO recognized in the report that "Education made 
considerable efforts and progress in promulgating regulations, 
providing assistance, and working with states in the first two and a 
half years of NCLBA implementation." You additionally recognized the 
considerable efforts of the States.

Your report first recommends ads that the U.S. Department of Education 
"provide additional assistance to states on approaches small rural 
districts can use to implement student proficiency provisions and 
teacher qualification requirements, including the 
application of new flexibilities."

We appreciate the concerns that you have expressed concerning the 
unique challenges that small rural districts face and recognize there 
is a continuing need for additional assistance in confronting those 
challenges. While we intend to provide such additional assistance, the 
authors of the report may not understand all the actions we have 
already taken in this area, and the report might be revised to include 
more information on those actions.

As you noted in your report, we have taken a number of steps to address 
the challenges faced by small rural districts. These steps include the 
formation of a rural task force, updates to the Title II, Part A non-
regulatory guidance Teacher Assistance Corps visits, new flexibility 
for meeting the "highly qualified teacher" requirements provided in 
guidance last March, and a variety of workshops. Other activities we 
have undertaken to help improve student achievement in rural districts 
and help those districts implement the No Child Left Behind Act (NCLB) 
include the following.

In March and July of this year, we conducted two major Technology 
Leadership Summits that provided technical assistance on how technology 
can assist States and districts in the implementation of NCLB. For each 
summit, we made a special effort to invite and encourage participation 
from small and low-income rural school districts. The first summit 
provided technical assistance in identifying technology tools and 
resources that are available to support the accountability, student 
info information and data collection and reporting requirements of 
NCLB, promoting the benefits of online assessment, illustrating how 
online assessments can inform instruction at the classroom level 
(through, for example, diagnostic tests, real-time reporting, and the 
use of performance-based assessments) and focusing on strategies to 
make assessment results useful. The second summit focused on 
increasing options though "e-learning." This summit explored virtual 
education - distance learning, virtual schools and other online 
education courses - as a powerful technology innovation expanding 
opportunities for learning in support of NCLB. A major feature of the 
summit was a "Virtual Schoolhouse" in which students from a rural 
school demonstrated how technology has increased their learning 
options.

We also have conducted Webcasts with State Title I directors and 
district Federal program coordinators in which Federal, State, 
district, and other officials discuss NCLB requirements and strategies 
for addressing them. In addition, we are expanding the use of Web 
conferencing technology as another strategy for providing information 
to, and sharing information among, States in order to assist all 
districts including rural and low-income school districts in 
understanding and meeting the requirements of NCLB. We have a contract 
with the Council of Chief State School Officer to provide technical 
assistance to States. One area of focus is technical assistance to 
States with small districts and small schools regarding different 
strategies four making adequate yearly progress (AYP) determinations. 
Such districts and schools have enrollments in tested grade that 
require them to go through a separate review process to make AYP 
determinations since the total number of students doesn't meet the 
State's minimum size requirements ("group size" for making 
accountability determinations in the same manner as other, larger 
schools.

As a part of our continuing outreach to rural districts and schools, 
our Teacher-to-Teacher initiative, which is designed to support 
teachers in raising student achievement, is planning four Saturday 
workshops this fall, two of which will be in rural areas. Next summer 
we will hold an additional six workshops throughout the country. To 
provide further e-learning opportunities for teachers, the Department 
will make available, on line, eleven presentations focusing on reading, 
math, and science from this summer's Teacher-to-Teacher workshops, and 
we plan to add twelve more reading and math presentations from the fall 
workshops mentioned above. To access these presentations visit 
www.ed.gov/teacherinitiative. Teachers will be able to access this 
high-quality professional development free of charge.

Your report recommends, secondly, that the Department "through 
its recently established National Research and Development Center on 
Rural Education - focus on effective, scientifically-based methods to 
improve student performance, and that it conduct studies on the 
services that can help small rural districts meet student proficiency 
provisions in light of the unique challenges that these districts 
face."

On February 4, the Institute of Education Sciences released a Request 
for Applications (RFA) for its Education Research and Development 
Center Grants competition. The requirements for the proposed research 
and development centers were published in that RFA. Prior to receiving 
the GAO's report, the Institute awarded a research grant to fund a 
national research and development center on rural education. The he 
grantee proposed, and the Institute is funding, a focused, long-term 
program of research to implement and evaluate professional development 
strategies for rural schools aimed at establishing schoolwide 
strategies that enhance rural students' academic, behavioral, and 
social adjustment across the elementary and middle school years. As 
part of its program of research, the center will evaluate the 
effectiveness of delivering a teacher professional development program 
via Web-based training and video-conferencing consultation, an approach 
that may prove to be extremely useful for small, isolated rural school 
districts. The primary purpose of the National Research and 
Development Center on Rural Education is to conduct rigorous research 
to identify which education practices are effective for increasing 
student achievement and improving the teaching and learning 
environment and not to provide technical assistance. However, 
approximately one quarter of the effect of the Department's regional 
laboratories is devoted to providing support and technical assistance 
for rural schools.

As you complete this report, there are two other comments we would 
like to offer.

We recommend that the report specifically note that, by statute, the 
"Rural-Flex" authority to use funds for alternative purposes is 
available only to those districts that meet the specific eligibility 
requirements of the Small, Rural School Achievement program as set 
forth in 6211 (b) of the Elementary and Secondary Education Act, as 
amended.

In the report, reference is made to a requirement by NCLB "to ensure 
that every student becomes proficient in reading, math and science by 
school year 2013-14." NCLB requires student proficiency in reading/
language arts and math by 2013-14. Proficiency in science is not an 
NCLB accountability requirement.

Again, we appreciate your efforts in preparing this report and 
providing us with an opportunity to submit these comments. Please feel 
free to contact us if you would like to discuss any of these matters 
further.

Sincerely,

Signed by: 

Eugene W. Hickok: 

[End of section]

Appendix III: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Harriet C. Ganson (202) 512-7042 or gansonh@gao.gov 
Mary E. Roy (202) 512-7072 or roym@gao.gov:

Staff Acknowledgments:

In addition to those named above, the following individuals made 
important contributions to this report: Natalya Bolshun, Daniele 
Schiffman, Cynthia Decker, Kris Braaten, Jessica Botsford, Jean 
McSween, John Mingus, Corinna Nicolaou, Robert Owens, and Jay Smale.

[End of section]

Related GAO Products:

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

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

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

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

Elementary and Secondary Education: Ed-Flex States Vary in 
Implementation of Waiver Process. GAO/HEHS-99-17. Washington, D.C.: 
November 13, 1998.

Rural Development: Profile of Rural Areas. GAO/RCED-93-40FS. 
Washington, D.C.: April 29, 1993.

Rural Development: Rural America Faces Many Challenges. GAO/RCED-93-35. 
Washington, D.C.: November 20, 1992.

FOOTNOTES

[1] NCLBA was signed into law as Pub. L. No.107-110.

[2] Title I, Part A of the Elementary and Secondary Education Act, 
allocated almost $12 billion in fiscal year 2003 to serve disadvantaged 
children in approximately 90 percent of the nation's school districts.

[3] NCES is part of the Department of Education and is the primary 
federal entity for collecting, analyzing, and reporting data related to 
education in the United States and other nations.

[4] All percentage differences reported from the survey have sampling 
errors of no more than plus or minus 10 percentage points, at a 95 
percent confidence level, unless otherwise noted. In our analysis of 
the survey data, we combined responses that were reported to a "great" 
or "very great" extent. References in the report that describe the 
frequency of occurrence of a particular response reflect this combined 
category. For example, all reported responses for challenges to 
implementation were identified by respondents as occurring to a "great" 
or "very great" extent.

[5] See GAO, DOD Overseas Schools: Compensation Adequate for Recruiting 
and Retaining Well-Qualified Teachers, GAO-03-19 (Washington, D.C.: 
December 2002).

[6] In March 2004, Education issued guidance with new flexibility for 
states to allow some rural districts up to 3 years for multiple subject 
teachers who are highly qualified in one subject to become highly 
qualified in the additional subjects they teach.

[7] The term "educational service agency" refers to a regional public 
multiservice agency authorized by state statute to develop, manage, and 
provide services or programs to school districts. 

[8] Under the Individuals with Disabilities Education Act, an 
individualized education program must be developed for each student 
with a disability to state the student's current levels of education 
performance, establish measurable annual goals, and outline special 
education and related services to be provided to the student. A state 
discussed here, however, adopted this practice for all students, not 
just those with disabilities. 

[9] These studies included Driscoll, William, and Howard Fleeter, 
Projected Costs of Implementing the Federal "No Child Left Behind Act" 
In Ohio (Columbus, OH: Levin, Driscoll , & Fleeter, December 12, 2003); 
AccountabilityWorks, NCLB under A Microscope: A Cost Analysis of the 
Fiscal Impact of the No Child Left Behind Act of 2001 on States and 
Local Education Agencies (Washington, D.C.:Education Leaders Council, 
January 2004); Mathis, William J., The Federal "No Child Left Behind" 
Law: Should Vermont Take the Money? (Vermont Society for the Study of 
Education, October 22, 2002); New Hampshire School Administrators 
Association, Analysis of Cost Impact of ESEA No Child Left Behind Act 
on New Hampshire (Penacook, NH: November 19, 2002); the Minnesota 
Office of the Legislative Auditor, Evaluation Report: No Child Left 
Behind (St. Paul, MN: Program Evaluation Division, March 2004). A 
number of studies have estimated the cost of providing a certain level 
of education, yet they did not directly estimate the cost of NCLBA. For 
example, see Myers, John, and Justin Silverstein, Calculation of the 
Cost of a Suitable Education in Montana in 2001-2002 Using the 
Professional Judgment Approach (Denver, CO: Augenblick & Myers, Inc., 
August 2002) and Duncombe, William, Estimating the Cost of an Adequate 
Education in New York (Syracuse, NY: Center for Policy Research, 
Syracuse University, February 2002). While these studies may be helpful 
in thinking about potential approaches to estimating total expenditures 
related to NCLBA, they were not directly relevant to NCLBA 
implementation efforts. We also reviewed NCLBA cost estimates developed 
by Kansas State Department of Education and a school district in Utah. 

[10] In its recent study, GAO developed a model for estimating states' 
assessment expenditures by analyzing expenditure data from seven 
states. The study provided three estimates of total state spending 
between fiscal years 2002 and 2008 for test development, 
administration, scoring, and reporting--ranging from $1.9 billion to 
$5.3 billion--largely depending on the type of scoring method that 
tests chosen by the states would require. For example, GAO estimated 
that total state expenditures will be about $1.9 billion if states use 
all multiple choice questions, which are machine-scored, but $5.3 
billion if states choose tests with a mixture of multiple-choice 
questions and a limited number of open-ended questions that require 
students to write their responses and that have to be hand-scored. See 
GAO, Title I: Characteristics of Tests Will Influence Expenses; 
Information Sharing May Help States Realize Efficiencies, GAO-03-389 
(Washington, D.C.: May 8, 2003). 

[11] Title II, Part A, of the Elementary and Secondary Education Act, 
Teacher and Principal Training and Recruiting Fund, provides grants to 
state and local educational agencies, state higher education agencies, 
and eligible partnerships to implement strategies for improving teacher 
and principal quality, as well as to increase the number of highly 
qualified teachers, principals, and assistant principals. For fiscal 
year 2004, $2.93 billion was appropriated under this program.

[12] Portfolio-based assessment provides for teachers' subject-matter 
competency to be determined on the basis of teachers' educational and 
professional credentials and experiences. 

[13] The Impact Aid program (now Title VIII of the Elementary and 
Secondary Education Act) provides assistance to school districts with a 
large number of children living on Indian reservations, military bases, 
low-rent housing properties, or other federal lands. School districts 
use Impact Aid for various purposes, including salaries of teachers and 
teacher aides, textbooks, after-school and special enrichment programs, 
and remedial tutoring. For fiscal year 2004, $1.2 billion was 
appropriated under this program.

[14] REAP was designed to help rural districts that may lack the 
personnel and resources to compete effectively for federal competitive 
grants. It is composed of two programs: (1) the Small, Rural School 
Achievement program authorizes the Secretary of Education to award 
formula grants directly to eligible school districts; (2) the Rural and 
Low-Income Schools program is designed to address the needs of rural, 
low-income schools and authorizes the Secretary to award formula grants 
to state educational agencies, which in turn award subgrants to 
eligible school districts either competitively or on a formula basis. 

[15] Rural districts eligible for REAP funds have the flexibility to 
use funds under the following programs for activities beyond those that 
the programs intend: Subpart 2 of Part A of Title II (Improving Teacher 
Quality State Grants); Part D of Title II (Educational Technology State 
Grants); Part A of Title IV (Safe and Drug-Free Schools and 
Communities); Part A of Title V (State Grants for Innovative Programs). 
Funds can be used for activities authorized under the following 
programs: Part A of Title I (Improving the Academic Achievement of the 
Disadvantaged); Part A of Title II (Improving Teacher Quality State 
Grants) and Part D of Title II (Educational Technology State Grants); 
Title III (Language Instruction for Limited English Proficient and 
Immigrant Students); Part A of Title IV (Safe and Drug-Free Schools and 
Communities), Part B of Title IV (21st Century Community Learning 
Centers); and Part A of Title V (State Grants for Innovative Programs). 
Additional information on these programs is available on Education's 
website at www.ed.gov. 

[16] The E-Rate program, created as part of the Telecommunications Act 
of 1996, provides discounts on telecommunications services, Internet 
access, and internal connections to libraries and schools in the United 
States. Through disbursement of over $10 billion in discounted services 
since 1997, the E-Rate has helped ensure Internet access in most 
schools and libraries in the country. 

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