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entitled 'No Child Left Behind Act: Improved Accessibility to 
Education's Information Could Help States Further Implement Teacher 
Qualification Requirements' which was released on November 21, 2005. 

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GAO: 

November 2005: 

No Child Left Behind Act: 

Improved Accessibility to Education's Information Could Help States 
Further Implement Teacher Qualification Requirements: 

GAO-06-25: 

GAO Highlights: 

Highlights of GAO-06-25, a report to congressional requesters: 

Why GAO Did This Study: 

The No Child Left Behind Act (NCLBA) of 2001 established qualification 
requirements that teachers of core academic subjects must meet by the 
end of the 2005-2006 school year. Congress has appropriated 
approximately $3 billion a year through the Title II, Part A (Title 
II), of NCLBA for teacher improvement programs since the law was 
passed. With the deadline approaching for all teachers to meet the 
requirements, GAO was asked to examine (1) the status of state efforts 
to meet NCLBA’s teacher qualification requirements, (2) the use of 
Title II funds in selected districts, and (3) how the U.S. Department 
of Education (Education) monitors states and assists them with 
implementation of the requirements. To obtain this information, GAO 
reviewed teacher qualifications data submitted to Education by 47 
states, conducted site visits to 6 states selected for variance in 
factors such as teacher requirements and geographic location, visited 
11 school districts across these states identified as high-need, and 
interviewed national experts and Education officials. 

What GAO Found: 

Data reported to Education by 47 states suggest that the majority of 
core academic classes were taught by teachers who met NCLBA 
requirements during the 2003-2004 school year. States have improved in 
their ability to track and report the percentage of core academic 
classes taught by teachers who met NCLBA qualification requirements, 
but several limitations on the quality and precision of state-reported 
data make it difficult to determine the exact percentage of core 
academic classes taught by teachers meeting the requirements. Five of 
the 6 states that we visited allowed veteran teachers to demonstrate 
subject matter competency through a state-developed procedure called 
High Objective Uniform State Standard of Evaluation (HOUSSE). Officials 
in states and districts that we visited said that teachers of multiple 
subjects, such as teachers in rural schools with a small teaching 
staff, would likely face challenges meeting the requirements by the 
2005-2006 deadline. 

The 11 school districts that we visited all used Title II funds to 
provide professional development, and most used Title II funds to 
reduce class size. Officials in the majority of these districts 
indicated that NCLBA had led to improvements in the kinds of 
professional development they funded with Title II funds. Although 
officials in over half of the districts indicated that they continued 
to use Title II funds to reduce class size, an activity that was 
supported under a federal program that predated NCLBA, some district 
officials told us that they had shifted funds away from class size 
reduction to initiatives designed to improve teachers’ subject matter 
knowledge and instructional skills, such as professional development. 
All districts that we visited reported considering student achievement 
data and targeting Title II funds to improve instruction in the 
academic subjects in which students were lagging behind. In the 11 
districts, few efforts funded with Title II targeted specific groups of 
teachers, such as teachers in high-poverty schools. Title II funds 
constituted a small proportion of total funds that districts could use 
for teacher improvement initiatives, and all districts that we visited 
used several other funding sources to support their teacher programs. 

Education monitored state efforts to meet the teacher qualification 
requirements and offered multiple types of assistance to help teachers 
meet the requirements. In monitoring states, Education has found 
several areas of concern, such as states not ensuring that certain 
newly hired teachers met NCLBA’s requirements. Education’s assistance 
has included professional development for teachers and site visits to 
provide technical assistance to state officials. Education officials 
said that their Web site has been an important tool for disseminating 
resources about the requirements, but officials from most states and 
districts that we visited told us that they were unaware of some of 
these resources or had difficulty locating them, despite frequently 
using the Web site. 

What GAO Recommends: 

GAO recommends that the Secretary of Education explore ways to make the 
Web-based information on teacher qualification requirements more 
accessible to users of its Web site. In comments, Education officials 
agreed with our recommendation and reported taking actions to address 
it. 

www.gao.gov/cgi-bin/getrpt?GAO-06-25. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Marnie Shaul at (202) 512-
6778 or shaulm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

States Have Made Progress in Meeting Teacher Qualification 
Requirements, but Challenges Remain: 

Visited School Districts Most Often Used Title II Funds for 
Professional Development: 

Education Monitored States and Offered Assistance on Implementing the 
Requirements, but Some of Education's Information Was Not Readily 
Accessible: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Activities on Which States and Districts Can Spend Title 
II, Part A, Funds: 

Appendix II: State-Reported Percentage of Core Academic Classes Taught 
by Teachers Meeting NCLBA's Teacher Qualification Requirements in the 
2003-2004 School Year: 

Appendix III: Sample HOUSSE Procedures from Two States Visited: 

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

Appendix V: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Major Findings from Education's Title II Monitoring: 

Table 2: NCLBA's Criteria for HOUSSE Procedures: 

Table 3: Title II, Part A, State Activities: 

Table 4: Title II, Part A, District Activities: 

Figures: 

Figure 1: Federal Teacher Qualification Criteria: 

Figure 2: Phase-in of Teacher Qualification Requirements: 

Figure 3: Overview of HOUSSE Point Systems in Site Visit States: 

Figure 4: Information on Teacher Qualifications Available through 
Education's Web Site, as of August 2005: 

Abbreviations: 

HOUSSE: High Objective Uniform State Standard of Evaluation: 

IDEA: Individuals with Disabilities Education Act: 

LEA: local education agency: 

NCLBA: No Child Left Behind Act: 

TAC: Teacher Assistance Corps: 

[End of section] 

United States Government Accountability Office: 

Washington, DC 20548: 

November 21, 2005: 

The Honorable John A. Boehner: 
Chairman: 
The Honorable George Miller 
Ranking Minority Member: 
Committee on Education and the Workforce: 
House of Representatives: 

Although research over the past 10 years has shown that teachers play a 
significant role in improving student performance, many teachers, 
especially those in high-poverty districts, lack competency in the 
subjects they teach. Recognizing this, the Congress passed the No Child 
Left Behind Act of 2001 (NCLBA), which established qualification 
requirements for the nation's approximately 3 million public school 
teachers, and made states, districts, and schools responsible for 
ensuring that teachers meet these requirements. Specifically, the act 
requires that teachers of core academic subjects such as math and 
science be "highly qualified" by the end of the 2005-2006 school year. 
[Footnote 1] To meet the requirements, teachers must (1) have at least 
a bachelor's degree, (2) be certified to teach by their state, and (3) 
demonstrate subject matter competency in each core academic subject 
they teach. Under the act, teachers may demonstrate subject matter 
competency through different avenues, including a state-developed High 
Objective Uniform State Standard of Evaluation (HOUSSE). State HOUSSE 
procedures give veteran teachers--generally those with 1 or more years 
of experience--the opportunity to demonstrate subject matter competency 
through teaching experience, professional development, coursework, and 
other activities. If teachers do not meet the requirements, school 
districts may be required to take certain actions, such as providing 
additional professional development.[Footnote 2] 

To help states and districts meet NCLBA's teacher qualification 
requirements, the Congress has appropriated approximately $3 billion a 
year in grants through the Title II, Part A (Title II), of NCLBA since 
the law was passed. This amount constituted about 7 percent of all 
federal funds made available to states in 2004 for supporting education 
in kindergarten through 12th grade. Title II replaced the Eisenhower 
Professional Development and Class-Size Reduction programs, allowing 
states and districts to use funds for similar purposes, including 
training of teachers and hiring of additional teachers to reduce class 
size, as well as various other activities to help recruit, retain, and 
develop teachers. The Department of Education (Education) monitors 
states' implementation of NCLBA and provides assistance to states to 
help them understand the teacher qualification requirements in the act 
and appropriate uses of Title II funds. 

In our prior work, we found that states and districts faced challenges 
in ensuring that teachers met the requirements and also generally did 
not have data systems that could track teacher qualifications by 
subject in order to determine teachers' status in meeting the 
requirements for those subjects.[Footnote 3] In response to 
congressional requests, we are providing information on (1) the status 
of state efforts to meet NCLBA's teacher qualification requirements, 
(2) the use of Title II funds in selected districts, and (3) how 
Education monitors states and assists them with implementation of the 
requirements. 

To obtain this information, we used multiple data collection methods. 
First, to provide a national perspective, we reviewed teacher 
qualification data in the consolidated performance reports that 47 
states submitted to Education for the 2003-2004 school year, the latest 
year for which these reports were available. The remaining 3 states, 
the District of Columbia, and Puerto Rico did not provide these data to 
Education. We identified several factors that affect the accuracy of 
these data and preclude a comparison of classes taught by teachers 
meeting the requirements across states. However, on the basis of our 
work, we determined state-reported percentages could be used to 
demonstrate how close a particular state was to reaching the goal of 
having all its teachers meet the requirements. The extent of the data 
limitations is not currently known, and Education has followed up with 
all states to obtain additional information on their processes for 
collecting these data. Second, to provide information on how selected 
states and districts are implementing the requirements and using Title 
II funds, we visited and interviewed officials in 6 states--California, 
Colorado, Kansas, Maryland, Rhode Island, and Tennessee--to collect in- 
depth information on their efforts to meet teacher qualification 
requirements and use of Title II funds. These states were selected for 
variance in procedures for teachers to demonstrate subject matter 
competency, reported quality of their data systems, amount of Title II 
funds received, and geographic location. At the time of our site 
visits, none of the states had been visited for monitoring purposes by 
Education. Across these states, we visited 11 of the nation's 14,466 
school districts, including both urban and rural districts that state 
officials had identified as high-need based on their poverty level and 
teacher challenges they experienced. We also interviewed officials from 
Education, national education organizations, and teachers' unions. In 
addition, we reviewed Title II monitoring reports completed by 
Education as of July 2005. Finally, we analyzed Education's documents 
and Web site, legislation, and other materials related to the teacher 
qualification requirements and Title II funds. We conducted our work 
between November 2004 and October 2005 in accordance with generally 
accepted government auditing standards. 

Results in Brief: 

The data reported by 47 states to Education suggest that the majority 
of core academic classes were taught by teachers who met NCLBA 
requirements during the 2003-2004 school year. States have improved in 
their ability to track and report the percentage of core academic 
classes taught by teachers who met NCLBA qualification requirements, 
but several limitations affect the quality and precision of state- 
reported data, making it difficult to determine the exact percentage of 
core academic classes taught by teachers meeting the requirements. Five 
of the 6 states that we visited had HOUSSE procedures in place that 
offered multiple options for veteran teachers--generally those with 1 
or more years of experience--to demonstrate subject matter competency, 
such as through a combination of experience, academic coursework or 
professional development, and leadership or service activities. Three 
of these states also used other methods of evaluating teachers' subject 
matter knowledge as part of their HOUSSE procedures, such as observing 
teachers' performance or assessing teachers' contributions to student 
achievement. Despite the number of ways allowed for teachers to 
demonstrate subject matter competency, state and district officials and 
national association representatives told us that teachers providing 
instruction in multiple core academic subjects, such as teachers in 
rural schools with a small teaching staff, would likely face difficulty 
in meeting the requirements by the deadline of school year 2005-2006. 

The 11 school districts that we visited used Title II funds to provide 
professional development for teachers, particularly in core academic 
subjects. Officials in the majority of these districts also told us 
that NCLBA's emphasis on student achievement and on strategies 
supported by research had led to improvements in the kinds of 
professional development they funded with Title II funds. Officials in 
7 of the 11 districts indicated that they continued to use Title II 
funds to support class size reduction efforts, but some district 
officials told us that they had begun shifting emphasis from class size 
reduction to professional development. In identifying appropriate uses 
of Title II funds, most districts that we visited considered student 
achievement needs and then targeted programs, such as professional 
development, to those academic subjects where students were lagging 
behind. However, only a few of these efforts targeted specific groups 
of teachers, such as teachers in high-poverty schools. Title II funds 
are generally a small part of total funds available to the districts 
for teacher initiatives, and districts visited also used non-Title II 
funds to address their teachers' needs, including other federal, state, 
and local funds. For example, one district used other federal funds to 
help teachers prepare for subject matter exams; another district used 
private foundation funds to provide financial incentives for teachers 
who accepted positions in the district's most struggling schools. 

Education monitored states' efforts to meet the teacher qualification 
requirements through its Title II monitoring process and offered 
assistance to states and districts that included professional 
development for teachers, on-site visits, and guidance. In the 20 state 
monitoring reports that Education had issued as of July 2005, it 
identified several areas of concern related to states' implementation 
of the teacher qualification requirements. For example, one frequent 
finding was that states did not require teachers of history, geography, 
civics/government, or economics to demonstrate subject matter 
competency in each subject taught, as required under NCLBA, but instead 
allowed them to demonstrate competency in the broad subject of social 
studies. Education also offered a variety of assistance both to the 
nation's approximately 3 million public school teachers and to state 
officials responsible for implementing the requirements. To assist 
teachers, Education offered professional development opportunities 
during 2004 and 2005 that were attended by about 4,500 teachers and 
distributed 255,000 "Toolkit for Teachers" information packets. 
Assistance to state officials included site visits to discuss NCLBA's 
teacher qualification requirements and offer technical assistance, 
information on innovative state and local initiatives, and guidance. 
Education officials said that the department's Web site has been an 
important part of their efforts to implement NCLBA's teacher 
qualification requirements. However, officials from most states and 
districts that we visited told us that they were unaware of some of 
these resources or had difficulty locating them, even though they use 
Education's Web site to access information on teacher requirements and 
programs. For example, officials from 4 states told us that information 
on other states' efforts to improve teacher qualifications would be 
helpful, but they were unaware that Education offered this online. Our 
review of Education's Web site found that resources on NCLBA's teacher 
qualification requirements were located on several different Web pages 
that were sometimes not linked, making it challenging to find them. 

To help states address the issues of teacher quality and ensure that 
all teachers meet NCLBA's qualification requirements, we are 
recommending that the Secretary of Education explore ways to make the 
Web-based information on teacher qualification requirements more 
accessible to users of its Web site through such activities as more 
prominently displaying the link to state teacher initiatives or 
enhancing the capability of the search function. 

Background: 

The NCLBA of 2001 amended and reauthorized the Elementary and Secondary 
Education Act, the largest and most comprehensive federal education 
law. The focus of this legislation is on improving students' academic 
performance. A growing body of research has shown that teacher 
effectiveness is a significant factor in improving students' academic 
performance. Research has also shown that many children, especially 
those in high-poverty and high-minority schools, are assigned to 
teachers who lack knowledge of the subjects they teach. For example, a 
2004 report stated that one out of four high school courses was being 
taught by teachers without a college major, or even a minor, in the 
subject taught, and that students in high-poverty classrooms were more 
likely to be assigned to such teachers than students in low-poverty 
classrooms.[Footnote 4] 

Historically, states have been responsible for developing and 
administering their education systems, and most states have delegated 
the authority for operating schools to local governments. States and 
local governments provide most of the money for public elementary and 
secondary education. Education reported that 49 percent of the revenue 
for public elementary and secondary education in the 2001-2002 school 
year came from state sources, 43 percent came from local sources, and 8 
percent came from federal sources.[Footnote 5] As a result, state and 
local dollars fund most major expenses, such as teacher salaries, 
school buildings, and transportation. Although the autonomy of 
districts varies, states are responsible for monitoring and assisting 
their districts that, in turn, monitor and assist their schools. 

The federal government has played a limited but important role in 
education. Education's mission is to ensure equal access to education 
and promote educational excellence throughout the nation by, among 
other things, supporting state and local educational improvement 
efforts, gathering statistics and conducting research, and helping to 
make education a national priority. Education is responsible for 
providing assistance to states to help them understand the provisions 
or requirements of applicable laws and oversees and monitors how states 
implement them. With the passage of NCLBA, which requires public school 
teachers to be highly qualified in every core academic subject they 
teach,[Footnote 6] the federal government for the first time 
established specific criteria for teachers. 

The act requires all teachers of core academic subjects to have a 
bachelor's degree, state certification, and demonstrable subject matter 
competency for each core subject taught.[Footnote 7] Under the act, 
teachers may not have state certification requirements waived on an 
emergency, temporary, or provisional basis. According to the Education 
Commission of the States, every state required 4 years of college 
preparation for teacher certification as of 1974. However, ensuring 
that all teachers are certified and can demonstrate competency in the 
subject matter they teach presents a new challenge for many states. 
Allowable ways for teachers to demonstrate subject matter competency 
vary depending upon a teacher's experience and the grade level being 
taught. (See fig. 1.) For example, elementary teachers new to the 
profession must pass a state test to demonstrate subject knowledge and 
teaching skills. States have the flexibility to identify and approve 
such tests for new teachers, as well as establish the passing scores on 
the tests. Middle school and high school teachers have a number of 
options available to them for demonstration of subject matter 
competency, including a college major or a state test in the subject 
taught. In addition to the options available for new teachers, veteran 
teachers have an additional avenue for demonstrating subject matter 
competency through their state's HOUSSE procedures.[Footnote 8] 

Figure 1: Federal Teacher Qualification Criteria: 

[See PDF for image] 

[A] Must be a rigorous state test assessing subject and teaching skills 
in reading, writing, mathematics, and other areas of the basic 
elementary curriculum. 

[B] Must be a rigorous state test in the academic subject taught. 

[C] An example is the attainment of a National Board Certification in 
the subject and grade level taught. 

[End of figure] 

States can make the HOUSSE option available to veteran teachers at all 
grade levels. The act sets forth some general criteria for states to 
use in developing an acceptable evaluation standard. For example, the 
standard must be developed in a way that provides objective and 
coherent information about the teacher's attainment of core content 
knowledge, must be aligned with state academic content and student 
achievement standards, and must be uniformly applied to all teachers of 
the same subject and grade level in the state. 

In March 2004, Education announced additional flexibilities to help 
teachers who deliver instruction in multiple core academic subjects and 
science teachers meet the requirements. Education announced that 
veteran teachers who provide instruction in multiple core academic 
subjects will be able to demonstrate their subject matter competency 
through a single set of procedures, such as a single, streamlined 
HOUSSE covering multiple academic subjects. Education also announced 
that teachers in eligible rural areas who teach multiple core academic 
subjects and meet the requirements in at least one of those subjects 
would have additional time to demonstrate subject matter competency in 
the other subjects. Further, Education allowed states to rely on their 
own certification requirements for science to determine specific 
science areas in which teachers will be required to demonstrate subject 
matter competency. For example, if a state certified teachers in the 
general field of science, then a teacher may demonstrate subject matter 
competency in the general science area instead of each separate science 
subject, such as physics or biology. 

According to Education's August 2005 nonregulatory guidance, the NCLBA 
teacher qualification requirements apply to special education teachers 
who provide instruction in core academic subjects, such as teachers in 
self-contained classrooms.[Footnote 9] These teachers may demonstrate 
subject matter competency by using any of the options allowed to other 
teachers under NCLBA. 

Qualification requirements for special education teachers were modified 
in the December 2004 reauthorization of the Individuals with 
Disabilities Education Act (IDEA).[Footnote 10] The reauthorized IDEA 
allowed some special education teachers additional flexibility in terms 
of meeting subject matter competency requirements. First, new special 
education teachers at the elementary level who are teaching exclusively 
children with significant cognitive disabilities may use the state 
HOUSSE procedures to demonstrate subject matter competency, an option 
otherwise reserved under NCLBA to veteran teachers.[Footnote 11] 
Second, new special education teachers who teach multiple core academic 
subjects exclusively to special education students and already meet the 
requirements in mathematics, language arts, or science, have 2 years 
after hiring to demonstrate subject matter competency in the other 
subjects taught. Teachers in this second category may also do this 
through the HOUSSE process, including a single evaluation covering all 
academic subjects taught. Finally, veteran special education teachers 
who teach multiple core academic subjects exclusively to special 
education students have the option of demonstrating subject matter 
competency through a multisubject HOUSSE, consolidated to assess 
teachers' subject matter knowledge in multiple subjects through a 
single process. 

The deadline for teachers to meet the requirements depends on the type 
of school in which they work. Starting with the first day of the 2002- 
2003 school year, all new teachers hired into school programs supported 
with Title I funds must demonstrate compliance with the requirements 
immediately upon hire.[Footnote 12] Most other teachers have until the 
end of 2005-2006 school year to meet the requirements in the law. The 
current timelines for teachers to meet the requirements are shown in 
figure 2.[Footnote 13] 

Figure 2: Phase-in of Teacher Qualification Requirements: 

[See PDF for image] 

[End of figure] 

Prior GAO work found that states and districts were experiencing 
challenges implementing NCLBA's teacher qualification requirements. 
Among the most commonly cited challenges were difficulties with teacher 
recruitment and retention resulting from factors such as low teacher 
pay, lack of adequate professional development opportunities, and 
difficulty developing and implementing state data systems for tracking 
teacher qualifications.[Footnote 14] We found that challenges were 
especially acute in small, isolated rural districts where teachers 
often had to teach multiple subjects across different grade 
levels.[Footnote 15] Furthermore, although we found that all states 
required that special education teachers have a bachelor's degree and 
be certified to teach--two of the three NCLBA teacher qualification 
requirements--many states did not require them to demonstrate subject 
matter competency. As the result, we concluded that state-certified 
special education teachers who were assigned to teach core academic 
subjects might not be positioned to meet NCLBA requirements.[Footnote 
16] In the aftermath of Hurricane Katrina, states and districts faced 
with large numbers of displaced teachers and students may have 
additional challenges tracking teacher qualification status and 
ensuring that all teachers meet the requirements by the deadline. 
Education indicated that it will work with affected states and school 
districts to determine what flexibility will be needed with regard to 
implementing the teacher qualification requirements. 

Federal funding for teacher initiatives was provided prior to NCLBA, 
but the act increased the level of funding to help states and districts 
implement the teacher qualification requirements. Prior to NCLBA, the 
Eisenhower Professional Development and Class-Size Reduction programs 
provided funds to the states primarily for professional development in 
mathematics and science and efforts to reduce class size for students 
in kindergarten through third grade. Title II replaced these two 
programs, providing states and districts with approximately $2.85 
billion for fiscal year 2002 to help them implement various initiatives 
for raising teacher and principal qualifications--$740 million more 
than provided in fiscal year 2001 under the previous two programs. In 
fiscal year 2004, Title II provided $2.93 billion to states and 
districts through Improving Teacher Quality State Grants. 

The formula currently used to allocate funds to states and districts is 
similar to the formula used under the Eisenhower Professional 
Development and the Class-Size Reduction programs and takes into 
account poverty and student enrollment. Specifically, the amount of 
Title II funds that each state or district receives is based on its 
2001 allocation under the two previous programs, the number of children 
aged 5 to 17, and the number of those children residing in families 
with incomes below the poverty line.[Footnote 17] After reserving up to 
1 percent of the funds for administrative purposes, states allocate 95 
percent of the remaining funds to the districts. They retain 2.5 
percent to support state-level teacher initiatives and allocate the 
remaining 2.5 percent to the state agency for higher education to 
support partnerships between higher education institutions and high- 
need districts that work together to provide professional development 
to teachers. 

While there is no formula in NCLBA for districts to allocate funds to 
specific schools, the act requires states to ensure that districts 
target funds to those schools with the highest number of teachers who 
are not highly qualified, the largest class sizes, or that have been 
identified to be in need of improvement. In addition, districts 
applying for Title II funds from their states are required to conduct a 
districtwide needs assessment to identify their teacher quality needs. 
Among other things, the needs assessment should identify those needs 
that must be addressed if the district is to have all its teachers 
meeting NCLBA's requirements by the deadline. The needs assessment 
should take into account activities needed to provide teachers with the 
means for helping students meet challenging state and local academic 
achievement standards. Districts must involve teachers in the 
development of their needs assessment and may consider a variety of 
factors, such as teacher and student achievement data and projections 
of professional development necessary to help all teachers meet NCLBA's 
qualification requirements. 

Under Title II, acceptable uses of funds include teacher certification 
activities, professional development in a variety of core academic 
subjects, and recruitment and retention initiatives, including hiring 
teachers in order to reduce class size. (See app. I for state and 
district authorized activities.) Some of these activities, such as 
recruitment of new teachers and professional development in math and 
science, could be funded under the Eisenhower Professional Development 
and Class-Size Reduction programs as well. However, states and 
districts have more flexibility in how to spend Title II funds than was 
previously possible. For example, while under the Class-Size Reduction 
Program, funds could be spent on financial incentives and mentoring 
programs for new teachers only, Title II funds can be used for existing 
teachers as well, if the district identifies a need. While the 
Eisenhower program focused primarily on professional development in 
math and science, allowable activities under Title II may include any 
subject. Under NCLBA, professional development is considered to be an 
important component of the overall strategy to improve the quality of 
teaching and raise student achievement, and the law provides the 
definition of professional development.[Footnote 18] 

In addition to using Title II funds for the purposes of raising teacher 
qualifications, districts can also transfer these funds to most other 
NCLBA programs to meet their educational priorities. Specifically, 
districts are allowed to transfer up to 50 percent of the funds 
allocated to them under most major NCLBA programs, including Title II, 
into other programs under NCLBA.[Footnote 19] Thus, for example, 
districts may transfer a portion of their Title II funds into Title I 
for initiatives designed to improve student achievement. 

Regardless of whether or not districts transfer funds under the 
transferability option, they can spend non-Title II funds, such as 
Title I funds, to support teacher initiatives. Under NCLBA, districts 
are required to spend at least 5 percent of their Title I funds on 
helping teachers meet the qualification requirements. Additionally, 
schools in the district that do not meet their student proficiency 
goals for 2 or more consecutive years are required to spend at least 10 
percent of their Title I funds to provide the school's teachers and 
principals with high-quality professional development. 

States must prepare and publicly disseminate an Annual State Report 
Card with information on the professional qualifications of teachers in 
the state, the percentage of such teachers on emergency or provisional 
credentials, and the percentage of core academic classes being taught 
by teachers who do not meet NCLBA's teacher qualification requirements. 
Further, Title I of NCLBA requires districts and schools to inform 
parents about the qualifications of their children's teachers. 
Districts are required to notify parents of all students attending 
Title I schools that they have the right to request information about 
the qualifications of their child's teacher. Schools must further 
notify parents if their child has been taught by a teacher who did not 
met NCLBA's teacher qualification requirements for 4 or more 
consecutive weeks. 

The accountability provisions under Title I of NCLBA require every 
state and district receiving Title I funds to develop and submit a plan 
for how it intends to meet the teacher qualification requirements, 
along with other provisions of the act such as adopting challenging 
academic content and student achievement standards. The state plan must 
establish each district's and school's annual measurable objectives for 
increasing the number of teachers meeting qualification requirements 
and receiving high-quality professional development with the goal of 
ensuring that all teachers meet the requirements by the end of the 2005-
2006 school year. In addition, beginning with the 2002-2003 school 
year, districts receiving Title I funds are required to annually report 
to the state on their progress toward state-set objectives, and all 
states are required to submit an annual report to Education detailing 
state progress in meeting the annual measurable objectives regarding 
teacher qualification requirements. Under NCLBA, school districts that 
do not ensure that their teachers meet the qualification requirements 
must implement certain actions, such as additional professional 
development. However, their overall funding levels from Education are 
not affected[Footnote 20]. If states do not meet the requirements for 
reporting on the qualifications of their teachers, the Secretary of 
Education has the authority under NCLBA to withhold state 
administrative funds. 

Education monitors states' progress in implementing the requirements 
under both Title I and Title II of the act, as well as provides 
assistance to them. Beginning with the 2002-2003 school year, Title I 
of the act requires Education to publicly report the annual progress of 
states, districts, and schools in meeting the measurable objectives for 
ensuring that all teachers meet the qualification requirements by the 
deadline. 

States Have Made Progress in Meeting Teacher Qualification 
Requirements, but Challenges Remain: 

The available data suggest that the majority of core academic courses 
were taught by qualified teachers in 2003-2004. States have made 
progress in tracking and reporting teacher qualification data, but 
challenges remain in reporting precise results. States offered multiple 
options for veteran teachers to demonstrate subject matter competency 
as part of their HOUSSE procedures, but the rigor of these procedures 
varied across the states that we visited. Selected state and district 
officials told us that certain groups of teachers would likely face 
challenges meeting the requirements by the 2005-2006 deadline. 

Most States Reported That the Majority of Teachers Are Qualified, but 
Some Data Issues Remain: 

The data reported by 47 states suggest that the majority of core 
academic classes were taught by teachers who met NCLBA requirements 
during the 2003-2004 school year.[Footnote 21] Most of these states 
reported that nearly all of their core academic classes were being 
taught by teachers who met the requirements. However, data for most 
states appear to show that core academic classes in low-poverty schools 
were more likely to be taught by teachers who met the requirements than 
classes in high-poverty schools. [Footnote 22] The data also suggest 
that a higher percentage of elementary school classes were taught by 
teachers who met the requirements than secondary school classes. State- 
reported percentages for each of the 47 states are shown in appendix 
II.[Footnote 23] Data limitations preclude a comparison among states 
but, on the basis of our work, we determined state-reported percentages 
could be used to demonstrate how close a particular state was to 
reaching the goal of having all its teachers meet the requirements. 

States have improved in their ability to track and report the 
percentage of core academic classes taught by teachers who met NCLBA 
qualifications. Reports from 2002 and 2003 from national education 
organizations, such as the Education Commission of the States, showed 
that few states were able to track and report these data. Similarly, in 
our 2003 report on the NCLBA teacher qualification provisions, 
officials in 7 of the 8 states we visited told us they did not have 
data systems capable of tracking teacher qualifications for each core 
subject.[Footnote 24] But by 2005, 47 states reported teacher 
qualification data to Education for the 2003-2004 school year. 
Officials in the 6 states that we visited told us that they had 
improved their data systems, either by creating a new system or by 
redesigning their existing system to collect information required under 
NCLBA. For example, several states merged their state-level teacher 
qualification systems with their district-level class assignment 
systems to enable them to determine whether classes were being taught 
by teachers who met the requirements. Education officials also told us 
the 2003-2004 data had considerably improved from earlier years and 
that next year's data will accurately reflect the status of state 
efforts to implement the teacher qualification requirements. 

Despite this progress, several issues limit the quality and precision 
of state-reported data and make it difficult to determine the exact 
percentage of core academic classes taught by teachers meeting NCLBA 
qualification requirements. First, district officials in 3 of the 6 
states that we visited told us that they had excluded classes taught by 
special education teachers from their calculations;[Footnote 25] state 
officials in all 6 site visit states said these teachers faced 
particular challenges in meeting the requirements. Second, states 
relied on the data districts provided, but state officials generally 
noted that data collection processes varied by district, and that the 
quality of the data could vary as well. For example, two districts that 
we visited in 1 state reported data that were based on an incorrect 
assumption about which teachers met the requirements,[Footnote 26] and 
therefore included some teachers as meeting the requirements when they 
had not. Education also identified data problems in 13 of the 20 states 
for which it issued monitoring reports by July 2005.[Footnote 27] The 
impact and magnitude of these problems on state reports is unclear; 
state-reported data may under-or overstate the percentage of classes 
taught by teachers who met the requirements, depending on the nature of 
the data problem. Education has contracted with a research organization 
to follow up with states to identify any data issues that may have 
affected state-reported data, such as states excluding certain teachers 
subject to NCLBA's qualification requirements from their 
calculations.[Footnote 28] 

States Offered Multiple Options for Veteran Teachers to Meet the 
Requirements: 

Five of the 6 site visit states had HOUSSE procedures in place for 
veteran teachers--those generally with 1 or more years of experience-- 
to demonstrate subject matter competency, and the procedures included 
many different options for teachers to use as part of HOUSSE. The 
HOUSSE procedures in these states included the use of a point system 
that allowed veteran teachers to demonstrate subject matter competency 
by earning points in categories of experience, academic coursework or 
professional development, and leadership or service activities, as well 
as for evidence of publications, presentations, or awards. Colorado 
officials said they did not have a HOUSSE but allowed teachers to 
demonstrate subject matter competency through options typically 
included in other states' HOUSSE procedures, such as a combination of 
college coursework and professional development options.[Footnote 29] 
Figure 3 presents an overview of HOUSSE point systems from the 5 states 
we visited that had them in place. (App. III shows HOUSSE point systems 
from 2 site visit states.) 

Figure 3: Overview of HOUSSE Point Systems in Site Visit States: 

[See PDF for image] 

[A] Kansas and Maryland required teachers to earn a minimum number of 
points in this category. 

[B] The maximum points listed are for regular education teachers. 
Special education teachers may have different maximums. 

[C] Maryland required elementary teachers to earn a minimum of 40 
points in this category and middle and high school teachers a minimum 
of 30 points. 

[D] Maryland combined leadership, activities, service, awards, 
presentations and publications into a single category with a maximum of 
10 points. 

[E] Tennessee allowed teachers to earn up to 40 points for classroom 
teaching experience and up to an additional 12 points for teaching 
content courses at a postsecondary institution. 

[F] Tennessee recently revised its evaluation system to emphasize 
assessment of teachers' subject matter knowledge. This updated 
evaluation system places greater emphasis on the content taught and is 
performed by evaluators trained in the new evaluation format. Teachers 
evaluated under the new system can use that as a stand-alone option for 
meeting all the subject matter competency requirements under the 
state's HOUSSE. Teachers evaluated under the old system can earn up to 
30 points through the state's point system--up to 20 of those points 
can be earned for positive evaluations, and up to 10 points are given 
to teachers who attained an advanced level of performance under the 
Tennessee Career Ladder Evaluation System, which had been in existence 
between 1985 and 1997. Although teachers can continue using the former 
versions of state evaluations to earn points toward demonstration of 
subject matter competency, officials indicated that the new evaluation 
system is now used statewide to assess the performance of all teachers. 

[End of figure] 

In addition to the categories above, the point systems in two states 
that we visited also included the option for teachers to demonstrate 
subject matter competency through advanced certification. Teachers in 
Maryland and Tennessee could earn all of the required points by 
achieving National Board Certification.[Footnote 30] 

In addition to the point system, the HOUSSE procedures in some site 
visit states offered alternatives for demonstrating subject matter 
competency. For example, teachers in Tennessee could demonstrate 
subject matter competency through multiple observations of their 
performance completed by trained evaluators or the data showing their 
effect on student achievement. Teachers in California who were unable 
to obtain the required number of points through the point system could 
use evidence of positive evaluations of their performance in the 
classroom or prepare a portfolio of their work.[Footnote 31] 

Our review of HOUSSE procedures in states that we visited, particularly 
the analysis of the points they allowed teachers to count for different 
activities, showed that they varied in the weight given to these 
activities. The extent to which certain activities reflect teachers' 
subject matter knowledge may affect the rigor of these 
procedures.[Footnote 32] For example, as shown in figure 3, Rhode 
Island allowed experience to count for about one-fourth of the 100 
points required for demonstrating subject matter competency, but the 
other 4 states with HOUSSE procedures allowed experience to count for 
about one-half of the points to be earned. Officials in Colorado 
indicated that they had chosen not to count experience toward teachers' 
demonstration of subject matter competency because they did not believe 
that experience would necessarily translate into improved subject 
knowledge. However, Colorado permitted relevant travel to count toward 
demonstration of subject matter competency, whereas the other states 
did not explicitly include travel in their HOUSSE. 

Some site visit states also set a minimum number of points to be earned 
in certain categories, while other states did not require teachers to 
earn points from those categories. Specifically, Kansas and Maryland 
required teachers to earn at least a portion of the total number of 
points they needed to demonstrate subject matter competency through 
college coursework, while other states did not require a minimum number 
of points in that category. States also differed in the number of 
categories in which teachers had to earn points. For example, teachers 
in Rhode Island were required to earn points from at least three 
different categories, such as college-level coursework and professional 
development in the content area. In contrast, teachers in Maryland 
could earn all points necessary for demonstration of subject matter 
competency from a single category. California, Kansas, Rhode Island, 
and Tennessee also set a requirement that some activities had been 
completed within a recent period of time.[Footnote 33] For example, 
Kansas required professional development and service activities to have 
taken place within the last 6 years to earn points toward demonstrating 
subject matter competency under HOUSSE. 

Some of the options that site visit states permitted as part of their 
HOUSSE procedures relied on improved student performance or 
observations of teachers' classroom performance. Tennessee allowed 
teachers to demonstrate subject matter competency by using data that 
show their actual contribution to students' achievement in that 
subject.[Footnote 34] To use this option for the purposes of 
demonstrating subject matter competency, teachers must demonstrate that 
the most recent 3-year average gain in the achievement of their 
students is not detectably different from or is better than the average 
gain for all students in the state. At the same time, Tennessee and 
California both counted positive evaluations of teachers' classroom 
performance as evidence that could be counted toward subject matter 
competency. Although both states based these evaluations on uniform 
performance standards established by the state, officials in these 
states told us that they did not oversee the implementation of these 
evaluations. As a result, we determined that they could not effectively 
ensure the quality of evaluations. While we did not conduct an in-depth 
review of how the evaluations of teachers' performance were carried 
out, we identified two areas of concern for using this method as an 
objective state standard. First, the number and duration of the 
evaluation sessions may not provide enough information to determine 
subject matter competency. Second, these evaluations may be conducted 
by personnel who are also responsible for hiring and retaining teachers 
in the district, and thus these evaluators may not be objective. In one 
small rural district that we visited, the assistant superintendent 
responsible for evaluating the teachers' subject matter competency told 
us that the evaluation process was subjective. 

Finally, while most states that we visited tried to ensure that 
activities accepted as part of their HOUSSE procedures were connected 
to the subject area that the teacher taught, Maryland's HOUSSE 
procedure awarded points for activities not directly related to the 
subject matter, such as professional development on instructional 
strategies and principles. Officials there indicated that the majority 
of points had to be earned from activities specific to the subject 
matter, and that the state's HOUSSE procedure sought to recognize both 
subject matter knowledge and the teachers' general teaching expertise. 

Some educational experts have noted that the rigor of HOUSSE procedures 
varied across states and expressed concerns that states whose 
procedures offered less rigorous options may not adequately assess 
teachers' subject matter knowledge. The experts we interviewed told us 
that teachers who are not required to engage in activities directly 
related to accumulating subject matter knowledge, such as completing 
college coursework in a subject, may not increase their knowledge of 
the subject taught. In addition, the experts commented that if 
experience is heavily emphasized, teachers may not get the subject 
matter knowledge they need to be effective in the classroom. States 
with less rigorous procedures may not bring about improvements in 
teachers' content knowledge or student performance. Officials from 
Education confirmed that the rigor of HOUSSE procedures varied across 
states, as is permitted under NCLBA. 

Selected States and Districts Faced Implementation Challenges: 

Although numerous ways exist for veteran teachers to demonstrate 
subject matter competency, officials in site visit states and districts 
and national association representatives told us that some teachers 
providing instruction in multiple core academic subjects, such as 
special education teachers and teachers in rural areas and specialized 
school settings, may not meet the requirements by the deadline. 
Officials in the states that we visited noted that special education 
teachers would have the greatest difficulty in meeting the requirements 
by the deadline, because they were originally certified in special 
education rather than in a specific academic content area. In addition, 
special education teachers frequently provide instruction in multiple 
core academic subjects at the secondary level, creating challenges in 
meeting the requirements for each subject. Officials also noted that 
teachers in rural districts may face similar challenges. For example, 
an official in one state described a rural district landlocked by 
mountains where three high school teachers were responsible for 
teaching all classes across all subjects and grades at the high school 
level, and therefore had to meet the requirements for each subject. 
Although under IDEA and Education's guidance certain special education 
and rural teachers who already meet the requirements in one core 
academic subject have additional time to meet the requirements for the 
other subjects, officials were still concerned about whether these 
teachers will be able to meet the requirements for all of the subjects. 
Officials also reported challenges for middle school teachers who 
frequently provide instruction in multiple core academic 
subjects,[Footnote 35] as well as teachers in specialized school 
settings, such as schools for students dismissed from their regular 
schools as a result of behavioral problems. Officials from two 
districts in one state that we visited told us that they had a large 
number of these specialized schools, and officials there indicated that 
teachers often had to teach multiple subjects to the same group of 
students, making it difficult for them because they had to meet the 
subject matter requirements in each subject taught. Education allowed 
states to streamline HOUSSE procedures by developing a method for 
veteran teachers of multiple core academic subjects to demonstrate 
subject matter competency in all those subjects through a single 
procedure. One of the states that we visited offered a streamlined 
HOUSSE procedure for its teachers of multiple core academic subjects. 
However, officials in the other states that we visited did not have a 
single HOUSSE procedure for teachers of multiple subjects, and some of 
them indicated that they would like more information on how to develop 
one. 

Officials in states and districts that we visited also told us that 
schools will continue to have difficulty recruiting math and science 
teachers who meet the requirements. Schools had difficulty recruiting 
these secondary teachers even before NCLBA. These recruitment 
shortfalls will likely continue after the 2005-2006 deadline passes, in 
part because thereafter all newly hired teachers of core academic 
subjects, not just those in Title I schools, will have to demonstrate 
their subject matter competency before entering the classroom. Some 
state and district officials told us that they were unable to restrict 
hiring to teachers who met the requirements because there were not 
enough candidates who had met the requirements to fill all of the open 
positions. One state is altering its emergency certificate to 
incorporate a time limit; this certificate will allow teachers to 
provide instruction for up to 2 years before they have to fully meet 
the subject matter competency requirements.[Footnote 36] While state 
officials responsible for teacher licensing in the state acknowledged 
that the new certificate does not meet the requirements of NCLBA, they 
indicated that school districts might not be able to fill all their 
open positions with teachers who meet the requirements. 

We also found that 8 of the 11 districts either did not notify parents 
when their children were assigned to teachers who did not meet the 
requirements, as required under the act, or did not make the 
notification entirely clear to the parents. Five districts in the 
states that we visited did not send the letters to the parents, with 
some district officials stating that they did not know that the letters 
had to be sent. Officials in one state instructed districts not to send 
the letters until the 2005-2006 deadline had passed. Three districts in 
another state sent letters to the parents, but these letters did not 
explicitly indicate that the teacher did not meet the requirements of 
the law. For example, one district's letter said that the teacher "is a 
dedicated professional who will always work in the best interest of 
your child" and "holds a probationary certificate" without explaining 
to the parents that probationary certificates do not meet NCLBA's 
requirements.[Footnote 37] 

Additionally, some officials did not know about other aspects of the 
requirements, such as actions required for teachers not meeting the 
requirements and to whom the requirements applied. For example, 
officials in two states told us that they did not know what actions 
districts or schools should take against teachers who did not meet the 
requirements by the deadline. Officials in one district had fired 
teachers because they did not meet the requirements. Other districts 
generally had not fired teachers who did not meet the requirements but 
wanted to know whether they should. There are no actions specified in 
the NCLBA with respect to teachers' conditions of employment for those 
who do not meet the requirements by the deadline. In addition, 
officials in one district did not know until our visit that all 
teachers of core academic subjects--not just those in Title I schools-
-would have to meet the requirements by the end of 2005-2006 school 
year. 

Education acknowledged the challenges that states may face in ensuring 
that all teachers meet the requirements by the end of 2005-2006 school 
year. On October 21, 2005, Education announced that states may have 
until the end of the 2006-2007 school year to ensure that all their 
teachers meet the requirements if they can demonstrate that they are 
making good-faith effort toward that goal. As evidence of good-faith 
efforts, states will need to meet the following four conditions: (1) 
show that the state's requirements for teachers to demonstrate that 
they are highly qualified are consistent with the law, (2) meet the 
requirements for parental notification and public reporting, (3) 
provide complete and accurate teacher qualification data to Education 
in January 2006 for the 2004-2005 school year, and (4) take action to 
ensure that poor and minority students are not taught by teachers who 
do not meet the requirements at a higher rate than other students. The 
letter also stated that no federal funds will be withheld from states 
if they are unable to ensure that all their teachers meet the 
requirements by the end of 2005-2006 school year, as long as these 
states are implementing the law and making a good-faith effort to reach 
that goal. 

Despite the challenges experienced, state officials reported progress 
in better positioning themselves to meet NCLBA requirements. Although 
our 2003 report showed that states we visited generally did not have 
data systems capable of tracking teacher qualifications for each core 
subject teachers taught,[Footnote 38] officials told us that they had 
improved their data systems since then. All of the states that we 
visited had either created a new data system or redesigned their 
existing data systems to collect information required under NCLBA. For 
example, several states merged their state-level teacher qualification 
systems with their district-level class assignment systems to enable 
states to determine whether classes were being taught by teachers who 
met the requirements. Another state redesigned its data system so that 
it would capture teachers' status in meeting the requirements. 

In addition to improving data systems, state officials also reported 
taking steps to help more teachers meet the requirements. For example, 
one of the states developed HOUSSE procedures that could be used to 
demonstrate subject matter competency across multiple subjects. Under 
those HOUSSE procedures, the same allowable activities, such as 
professional development and leadership positions, could be counted for 
more than one subject. Most states that we visited made some changes in 
certification requirements or professional development standards to 
make them more consistent with the requirements of NCLBA. For example, 
two states created a separate certificate for middle school teachers 
that incorporated subject matter competency requirements--a change that 
would ensure that middle school teachers have demonstrated subject 
matter competency. 

District officials also reported taking steps, such as changing their 
personnel policies, to ensure that more of their teachers meet the 
requirements. For example, officials in two districts told us that they 
had encouraged principals to consider dismissing teachers who were not 
on track to meet the requirements. In another state, districts were 
reassigning teachers to positions for which they met the requirements, 
and one district's officials instituted a policy of preventing teachers 
from transferring to any positions for which they did not meet the 
requirements. Officials in most districts also told us that they have 
incorporated NCLBA's teacher qualification criteria into their 
screening of new candidates. Further, officials from 6 of the 11 
districts that we visited told us that they were reducing the number of 
teachers with emergency credentials. 

Visited School Districts Most Often Used Title II Funds for 
Professional Development: 

The 11 districts that we visited used Title II funds to support 
professional development for teachers, particularly in core academic 
subjects. Officials in the majority of these districts indicated that 
NCLBA had led to improvements in the kinds of professional development 
they funded with Title II funds. Seven of the 11 districts that we 
visited also continued to use the funds for class size reduction 
efforts. However, district officials told us that they have begun 
shifting emphasis from class size reduction to initiatives focused on 
improving teacher qualifications. Most districts that we visited 
considered student achievement needs in identifying appropriate uses of 
Title II funds and targeted the funds to programs designed to help 
teachers address those needs. Few initiatives in these districts 
targeted specific groups of teachers, such as teachers in high-poverty 
schools. In addition to using Title II, district officials told us they 
used various other funding sources to support their teacher 
initiatives, including other federal, state, and local funds. 

All Visited Districts Used Title II Funds for Professional Development, 
and Many of Them Used These Funds for Class Size Reduction: 

All districts that we visited used Title II funds to provide 
professional development to teachers and focused their efforts on 
improving the quality of instruction in core academic subjects such as 
reading and math. For example, one district used Title II funds to 
provide summer workshops on research-based instructional strategies in 
reading and paid for instructional coaches to support classroom 
teachers throughout the year. Two districts reported spending Title II 
funds on math coaches who perform tasks such as working with teachers 
to develop lessons that reflected states' academic standards and 
assisting them in using students' test data to identify and address 
students' academic needs. In four districts, Title II professional 
development expenditures included the cost of instructional materials, 
and in one district Title II funds paid for substitute teachers while 
regular teachers attended training. 

In addition to spending for professional development in core academic 
subjects, officials in 10 of the 11 districts reported using Title II 
funds on professional development in other areas, such as on general 
teaching strategies and professional development for nonteaching staff. 
Most of these districts used at least some Title II funds for 
professional development that focused on teaching skills and general 
teaching strategies. For example, one district used Title II funds to 
support a program for all teachers during their first 3 years of 
employment with the district, including biweekly workshops on classroom 
management, student assessment, and parental involvement. Another 
district used the funds to help teachers understand the instructional 
needs of gifted and talented students and to adjust teaching methods to 
best address those students' needs. Seven districts also used Title II 
funds to offer professional development for nonteaching staff, such as 
school administrative personnel. For example, one district coordinated 
with a postsecondary institution to train assistant principals on 
becoming more effective educational leaders, while another district 
used the funds to develop guidance counselors and social workers 
employed in the district's schools. 

Officials in the majority of the districts that we visited told us that 
NCLBA's emphasis on student achievement and on strategies supported by 
research had led to improvements in the kinds of professional 
development they funded with Title II funds. Officials said they had 
become much more selective when approving professional development 
providers, looking for those programs that focused on intensive, 
research-based instructional strategies. In one district, for example, 
officials said that before NCLBA, providers were often selected on the 
basis of their long-standing relationship with the district, whereas 
now the district approved only those providers whose programs could be 
substantiated by research-based evidence of effectiveness. They also 
indicated that they had moved away from onetime workshops and begun to 
emphasize ongoing professional development that provided teachers with 
opportunities to reinforce and apply concepts learned. Furthermore, 
district officials that we interviewed reported greater emphasis on 
professional development opportunities in core academic subjects in 
which NCLBA required students to be assessed. While officials in some 
districts said that they were moving in the direction of higher-quality 
professional development even before NCLBA, several of them indicated 
that the passage of the act added urgency to these efforts. 

Officials in 7 of the 11 districts that we visited told us that they 
also used Title II funds to hire additional teachers to reduce class 
size. Districts focused their class size reduction efforts on specific 
grades, depending on their needs and other funding sources available. 
For example, one district visited focused its Title II-funded class 
size reduction efforts on the eighth grade because the state already 
provided funding for reducing class size in other grades. Officials in 
another district told us they planned to spend most of their Title II 
allocation on class size reduction because class size reduction funding 
from the state was insufficient. While class size reduction may 
contribute to teacher retention and result in a more individualized 
approach to student instruction, it also increases the number of 
classrooms that need to be staffed. As a result, districts that are 
already having problems with teacher recruitment may find it difficult 
to find enough teachers who meet NCLBA's qualification requirements to 
staff these classrooms. For example, one district visited used about 
one-third of Title II funds for class size reduction, but district 
officials indicated that recruitment difficulties forced them to 
continue to hire teachers who did not meet NCLBA's qualification 
requirements. 

Our previous work found that classroom reduction expenditures amounted 
to more than 50 percent of total Title II funds that districts spent 
during 2002-2003 school year,[Footnote 39] a finding consistent with 
Education's review of districts' Title II spending during the same time 
period.[Footnote 40] Officials in states that we visited and 
educational organization representatives that we interviewed told us 
that districts continued to spend funds on activities developed under 
the previous program. However, some state officials told us that they 
were encouraging districts to expand their traditional uses of these 
funds and to place a greater emphasis on initiatives designed to 
increase teachers' effectiveness in the classroom. 

In 6 districts that we visited, officials told us that they had begun 
shifting away from class size reduction efforts to placing greater 
emphasis on initiatives for existing teachers. For example, 2 of the 
districts stopped spending Title II funds on class size reduction 
efforts, and another district planned to eliminate class size reduction 
expenditures in the next school year. Officials in 2 other districts 
told us that while they still funded class size reduction efforts, they 
had reduced the amount of Title II funds they spent for this purpose. 
District officials indicated that they were now redirecting funds to 
support initiatives designed to improve teachers' subject matter 
knowledge and instructional skills, such as professional development. 

In addition to undertaking professional development and class size 
reduction efforts, 6 of the districts that we visited used Title II 
funds to support recruitment and retention activities. For example, 2 
districts used the funds to advertise open teaching positions, as well 
as to attend recruitment events outside of the district to identify 
qualified candidates. Another district used Title II funds to expand 
its alternative certification program, which allowed qualified 
candidates to teach while they worked to meet requirements for 
certification. Two districts used Title II funds for bonuses to attract 
successful administrators. To promote greater retention among new 
teachers, 3 districts used Title II funds for mentoring activities. For 
example, 1 of these districts reported using the funds to provide two 
trained mentors for every new teacher. Ten of the 11 districts that we 
visited did not use Title II funds to support programs that offered 
additional pay to teachers based on their performance or other 
qualifications. A few officials cited reasons for not using such 
programs, such as the expense or the difficulties in ensuring that they 
are implemented fairly. 

Six of the districts that we visited reported taking advantage of 
NCLBA's transferability option, with most of them transferring Title II 
funds into Title V. Under Title V, districts receive funding to support 
local education reform efforts in a broad range of areas, including 
activities to improve the academic achievement of all students and 
raise teacher effectiveness. For example, one district transferred 
Title II funds into Title V for initiatives designed to address 
students' academic needs, such as assessing their reading skills. 
Districts officials indicated that they preferred to transfer funds 
into Title V because it afforded them the most flexibility in spending 
the funds. However, one district transferred Title II funds into Title 
I to provide academic services in reading and math to middle school 
students. 

In addition to participating in activities funded with districts' own 
Title II allocations, teachers also took part in activities supported 
through Title II grants to universities and in state-level Title II 
initiatives. Three of the four university-based grantees that we 
visited focused on providing professional development to teachers in 
math or science. For example, one program reviewed offered a 2-week 
summer math workshop to prepare teachers for the subject matter exams 
that, if passed, could be used to demonstrate subject matter 
competency. Another university grantee developed a standards-based 
online math program for middle school teachers based on the math 
questions that students most frequently missed on the state's 
assessment. While university officials administering that program said 
that it could be used for teachers to earn points toward demonstration 
of subject matter competency under NCLBA, they did not know how many 
participants in the program had not yet met the requirements or how 
many districts allowed teachers to apply their participation toward 
earning points through the state's HOUSSE. Additionally, states used a 
portion of Title II funds retained by state departments of education to 
support professional development for teachers in core academic 
subjects. In two states that we visited, officials reported that state 
Title II initiatives specifically targeted teachers who had not met the 
subject matter competency requirements of NCLBA; these initiatives 
either offered them professional development in core academic subjects 
or reimbursed them for taking college courses in the subjects taught. 

Visited Districts Considered Student Achievement Needs in Identifying 
Uses of Title II Funds: 

Officials in the districts that we visited said that in deciding what 
specific initiatives should be funded with Title II funds, such as the 
types of professional development programs for teachers, they 
considered student achievement needs and targeted the funds to programs 
designed to help teachers address those needs.[Footnote 41] To identify 
student achievement needs, these officials said that their districts 
examined students' results on state assessments and a school's progress 
in meeting annual student proficiency goals in core academic subjects, 
as required under NCLBA.[Footnote 42] The districts then targeted their 
Title II funds to programs for teachers to improve instruction in those 
subjects in which students were lagging behind. For example, officials 
in one district said that because math was an area in which schools did 
not meet annual student proficiency goals, the district's Title II 
expenditures were targeted to professional development programs in 
math. In another district, the superintendent indicated that his 
district had placed the primary focus of its Title II initiatives on 
reading in early grades because schools in the district had not met 
reading proficiency goals for elementary students in the past. Some 
districts considered student achievement results in combination with 
other factors to identify most appropriate uses of federal funds. For 
example, officials in one district said that they looked at both 
schools' student assessment results and teacher experience levels when 
deciding where to place Title II-funded instructional coaches. 

Officials in the districts that we visited said that they involved a 
variety of stakeholders, such as teachers and parents, to help them 
identify district needs that could be addressed with Title II funds. 
The nature of stakeholder involvement varied across the districts that 
we visited. For example, several districts administered a survey to 
teachers, parents, and students, asking them about their perceptions of 
the district and its needs. Another district administered an online 
professional development survey to its teachers, asking them to assess 
the type of professional development activities received. District 
officials said they used the results of these surveys to decide how to 
best spend Title II funds. In other districts, officials considered 
stakeholders' perspectives in less structured ways. For example, in one 
district that did not have a separate process for gathering 
stakeholders' views prior to making funding decisions, officials said 
that stakeholders' perspectives were still considered as the result of 
the superintendent's regular meetings with school officials and parent 
groups across the district. 

While most districts that we visited targeted Title II funds to subject 
areas that presented academic challenges to students, only a few of the 
Title II funded initiatives were directed to specific groups of 
teachers, such as teachers in high-poverty schools or teachers who had 
not yet met the requirements of NCLBA. One district that we visited 
targeted Title II dollars to teachers in high-poverty schools, funding 
initiatives such as reimbursing these teachers for taking college 
classes necessary for them to meet state certification requirements and 
providing tuition for teachers in alternative certification programs 
who agreed to teach in high-poverty schools. In four districts that we 
visited, officials reported having initiatives specifically for 
teachers who had not yet met NCLBA's qualification requirements. Some 
of these initiatives offered reimbursement to teachers for taking 
college courses or other professional development that they could use 
to demonstrate compliance with NCLBA's requirements. Other initiatives 
helped teachers prepare for subject matter exams and reimbursed the 
registration fees of those who passed them to demonstrate subject 
matter competency in the subject taught. While many professional 
development programs supported with Title II funds were not necessarily 
targeted to teachers who still needed to meet the requirements, 
teachers who had not met the requirements could count their 
participation toward demonstration of subject matter competency under 
NCLBA by earning points through their state's HOUSSE. 

In each of the districts that we visited, any teacher could participate 
in at least some professional development or other programs supported 
with Title II funds, and district officials indicated that they had 
made efforts to address district-wide teacher needs. Ten of the 11 
districts that we visited had a large number of high-poverty 
schools,[Footnote 43] and by focusing on districtwide teacher needs, 
district officials could also address the needs of teachers who 
provided instruction to low-income students. For example, the 
superintendent of 1 district, in which all teachers could participate 
in Title II initiatives, credited the professional development funded 
through Title II with the narrowing of the achievement gap between the 
district's low-income and other students. The statutory formula that 
states used to allocate Title II funds to the districts takes into 
consideration their poverty levels,[Footnote 44] and several officials 
we interviewed told us they believed Title II funds were generally 
reaching districts with the greatest need. 

Visited Districts Used Non-Title II Funds to Support Teacher 
Initiatives: 

Title II funds are generally a small part of total funds available to 
the districts for teacher initiatives, and visited districts used 
various non-Title II funds to address their teacher needs, including 
other federal, state, and local funds. In two districts, for example, 
officials told us that Title II funds represented less than half of all 
the funds they spent on teacher initiatives. Moreover, districts 
received federal funds under different programs, and Title II 
constitutes a relatively small proportion of all federal funds they 
could use for teacher initiatives. In one district visited, for 
example, Title II funds constituted about 13 percent of the total 
federal funds available, with the bulk of the district's federal money 
coming from Title I. Our prior work also showed that districts planned 
to spend much larger percentages of other federal, state, and local 
funds than Title II funds on teacher-related activities, but in high- 
poverty districts Title II funds constituted a larger share of total 
funds spent on these activities than in low-poverty districts.[Footnote 
45] 

Although Title II was one of many resources available to the districts, 
many district officials we interviewed said that Title II funds played 
a significant role in their teacher improvement efforts. For example, 
officials in one district credited Title II-funded professional 
development with helping teachers prepare for subject matter tests they 
needed to pass in order to demonstrate subject matter competency under 
NCLBA. In another district, officials said that their initiatives to 
support teachers, such as coaches, would not have been possible without 
Title II funding. 

Districts that we visited supported a variety of teacher programs with 
non-Title II funds. Among other federal funds, Title I was one of the 
most frequently cited sources for supporting teacher initiatives. For 
example, two districts used Title I funds to hire coaches or 
consultants to help individual teachers in high-poverty schools become 
more effective in the classroom. A few of the initiatives funded with 
Title I were specifically designed to help teachers meet NCLBA's 
qualification requirements. For example, one district used the funds to 
reimburse teachers who passed the subject matter exam for their 
registration fees and for taking additional college coursework to help 
them meet NCLBA's subject matter competency requirements. In addition 
to using federal funds, districts also used state funds for teacher 
initiatives. For example, districts in one state received funds from 
the state for activities such as professional development to support 
all beginning teachers. Finally, districts used local and private funds 
to support various teacher initiatives. For example, one district used 
local funds to reimburse teachers for taking additional courses to 
raise their qualifications, while another district used private 
foundation funds to provide housing allowances for high-performing 
teachers who accepted positions in the district's most struggling inner-
city schools. 

Two districts that we visited had implemented or planned to implement 
differential compensation programs that offered financial rewards to 
teachers, such as onetime bonuses or salary increases, based on their 
performance or other qualifications. One school district in Tennessee 
made recruitment, retention, and salary bonuses available to teachers 
who had demonstrated a record of effectiveness and taught in some of 
the district's neediest schools.[Footnote 46] To assess teachers' 
eligibility for these bonuses, the district used the data showing 
teachers' impact on student performance available through the state's 
system of measuring students' achievement gains from year to year. This 
initiative is currently supported with both Title I and Title II funds. 
A school district in Colorado approved a plan for a districtwide 
differential compensation system that would provide teachers with 
multiple opportunities to increase their yearly pay, including gaining 
additional knowledge and skills, assuming positions in hard-to-fill 
subjects or hard-to-staff schools, earning successful performance 
evaluations, or meeting annual objectives for students' 
performance.[Footnote 47] This initiative will be funded through a 
local property tax increase that will create a trust fund to ensure 
that the new pay system can be permanently sustained.[Footnote 48] 
While officials in that district acknowledged that Title II funds could 
be used to support differential compensation initiatives, they 
indicated that Title II alone could not sustain this system. 

Officials in the districts that we visited said that they did not look 
at Title II funds in isolation from other funds when making funding 
decisions, but rather they attempted to leverage different funding 
sources available to address their teacher needs. For example, 
officials in one district said that the district's use of Title I funds 
for teacher recruitment purposes allowed them to focus Title II funds 
on the coaching program for teachers. 

Education Monitored States and Offered Assistance on Implementing the 
Requirements, but Some of Education's Information Was Not Readily 
Accessible: 

Education monitored states and offered assistance to help teachers meet 
NCLBA's teacher qualification requirements. In its monitoring reports, 
Education identified areas of concern related to states' implementation 
of the teacher qualification requirements. Education's assistance 
efforts included professional development opportunities and information 
packets on NCLBA's requirements. The agency also conducted site visits 
to states to discuss NCLBA's teacher qualification requirements and 
offer technical assistance. Although several key resources about 
NCLBA's teacher requirements can be reached only through Education's 
Web site, officials in most states and districts that we visited told 
us that they had difficulty locating these resources or were unaware of 
them. Our review of Education's Web site showed that several key 
resources on NCLBA's teacher qualification requirements were located on 
different Web pages that were not linked, making it challenging to find 
them. 

Education Monitored States' Implementation of Teacher Qualification 
Requirements: 

Education provided written feedback to states on their implementation 
of NCLBA's teacher qualification requirements through the Title II 
monitoring process. Education began Title II monitoring in June 2004 
and, as of July 15, 2005, had conducted monitoring visits to 29 states 
and the District of Columbia and released reports documenting findings 
to 20 of the states. Reports were generally released to states about 1 
to 3 months after the monitoring visit. Education officials reported 
that states had an opportunity to respond prior to the release of 
monitoring reports, and to develop a plan to address findings. None of 
our site visit states received a monitoring report in time to be 
included in this analysis. 

In these 20 monitoring reports, Education issued findings to states 
that did not fully implement NCLBA requirements. States most frequently 
received findings for not ensuring that teachers hired into Title I 
schools or with Title II funds met the teacher requirements (14 
states), as required by NCLBA. Another frequent finding was that state- 
reported data did not adequately reflect the status of teachers in 
meeting the requirements (13 states). For example, several states could 
not report data on the percentage of classes taught by teachers not 
meeting NCLBA's teacher qualification requirements for special 
education or secondary school classes. 

In addition, some states received findings for not requiring certain 
teachers to demonstrate subject matter competency as required under 
NCLBA. For example, 9 states received findings for allowing teachers of 
history, geography, civics/government, or economics to demonstrate 
subject matter competency in the broad area of social studies instead 
of in each subject taught. Seven states received findings for not 
requiring new elementary school teachers to demonstrate competency in 
the manner required by NCLBA. Education found that all 7 states had not 
implemented a test for new elementary school teachers to demonstrate 
subject matter competency or the test was optional. Eight states 
received findings related to the demonstration of competency for middle 
and high school teachers, and 7 states received findings related to the 
demonstration of competency for special education teachers. In states 
that did not require certain teachers to demonstrate competency as 
required by NCLBA, state data do not fully reflect the percentage of 
classes taught by teachers who met NCLBA teacher qualification 
requirements. 

Table 1 lists the major findings related to NCLBA's teacher 
qualification requirements. 

Table 1: Major Findings from Education's Title II Monitoring: 

Hiring: 

Teacher qualification requirements that states did not fully implement: 
Did not ensure that teachers hired into Title I schools or with Title 
II funds met the requirements; 
Number of states with finding: 14. 

Reporting and data: 

Teacher qualification requirements that states did not fully implement: 
Did not include all required data elements on state report card; 
Number of states with finding: 10. 

Teacher qualification requirements that states did not fully implement: 
State-reported data did not adequately reflect the status of teachers 
in meeting the requirements; 
Number of states with finding: 13. 

Demonstration of subject matter competency: 

Teacher qualification requirements that states did not fully implement: 
Did not require a state test for new elementary teachers to demonstrate 
subject matter competency; 
Number of states with finding: 8. 

Teacher qualification requirements that states did not fully implement: 
Requirements for veteran elementary teachers were not sufficient to 
demonstrate subject matter competency; 
Number of states with finding: 5. 

Teacher qualification requirements that states did not fully implement: 
Requirements for middle or high school teachers were not sufficient to 
demonstrate subject matter competency; 
Number of states with finding: 8. 

Teacher qualification requirements that states did not fully implement: 
Did not require teachers of history, geography, civics/government, or 
economics to demonstrate subject matter competency in each subject 
taught; 
Number of states with finding: 9. 

Teacher qualification requirements that states did not fully implement: 
Did not require special education teachers to demonstrate subject 
matter competency in subjects taught or have not determined the status 
of these teachers; 
Number of states with finding: 7. 

Teacher qualification requirements that states did not fully implement: 
State HOUSSE procedures did not meet criteria in the law; 
Number of states with finding: 1. 

Development of annual measurable objectives and plan for meeting the 
requirements: 

Teacher qualification requirements that states did not fully implement: 
Did not develop annual measurable objectives for districts and schools; 
Number of states with finding: 12. 

Source: GAO analysis of Education's Title II monitoring reports. 

Note: Information presented for 20 monitoring reports reviewed by GAO. 

[End of table] 

Of the 20 states that received monitoring reports, 19 states did not 
receive a finding regarding their HOUSSE procedures, even though some 
experts have questioned the rigor of HOUSSE procedures in many states. 
Through the monitoring process, Education is reviewing state HOUSSE 
procedures to ensure that they are consistent with NCLBA's criteria. 
Table 2 lists NCLBA's criteria for state HOUSSE procedures. 

Table 2: NCLBA's Criteria for HOUSSE Procedures: 

States can establish a process for evaluating teacher knowledge and 
ability based on the standard that meets the following criteria: 

* Is set by the state for both grade-appropriate academic subject 
matter knowledge and teaching skills. 

* Is aligned with challenging state academic content and student 
academic achievement standards and developed in consultation with core 
content specialists, teachers, principals, and school administrators. 

* Provides objective, coherent information about the teacher's 
attainment of core content knowledge in the academic subjects taught. 

* Is applied uniformly to all teachers in the same academic subject and 
the same grade level throughout the state. 

* Takes into consideration, but not be based primarily on, the time the 
teacher has been teaching in the academic subject. 

* Is made available to the public upon request. 

* May involve multiple objective measures of teacher competency. 

Source: NCLBA, Pub.L. No. 107-110, section 9101(23)(C)(ii). 

[End of table] 

As long as their HOUSSE procedures meet each of NCLBA's criteria, 
states have had flexibility in developing HOUSSE under NCLBA. Among 19 
states with HOUSSE procedures that were determined to meet NCLBA's 
criteria were one state with a HOUSSE that allowed for evaluations of 
teachers' classroom performance and several states in which teachers 
meet HOUSSE requirements by being fully certified to teach their 
subject. Education officials noted that evaluations of teachers' 
performance could be accepted as part of state HOUSSSE procedures as 
long as they are rigorous and objective measures of teachers' subject 
matter knowledge that are based on multiple observations and performed 
by trained evaluators. In addition, Education officials told us that 
while teacher certification in itself would not be sufficient for 
demonstration of subject matter competency, several states provided 
evidence that was accepted by Education showing that their 
certification requirements met the criteria for HOUSSE in the law. In 
the one state that received a finding related to its HOUSSE, teachers 
were allowed to earn more than half of the points necessary to meet 
HOUSSE requirements through experience. The state received a finding 
because NCLBA does not allow HOUSSE to be based primarily on teaching 
experience. 

Eleven of the 20 state monitoring reports included written 
commendations from Education for state efforts to improve professional 
development, strengthen teacher preparation, or develop data systems 
that track teacher qualifications. Eight states received commendation 
for improving or offering high-quality professional development for 
teachers. For example, Arkansas was commended for requiring every 
teacher to complete 60 hours of professional development each year and 
devoting considerable state funding to professional development. Seven 
states were commended for strengthening teacher preparation. For 
example, Georgia was commended for aligning all teacher preparation to 
state standards for student learning. Six states were commended for new 
or improved data systems for tracking teacher qualifications. For 
example, Mississippi received a commendation for tracking teachers' 
qualifications, certifications, and assignments, and linking those 
factors to individual students' progress. 

Education Offered Assistance to Teachers and States on the 
Implementation of Teacher Qualification Requirements: 

Education offered several types of assistance to help the nation's 3 
million public school teachers meet NCLBA's teacher qualification 
requirements, including professional development opportunities. 
Education offered professional development opportunities workshops in 
which about 4,500 teachers have participated since June 2004. These 
workshops and related materials were also made available online free of 
charge. Teachers accessed these workshops online through Education's 
Web site or through www.teacherquality.us, a Web site Education uses to 
provide information on Education's teacher initiatives. In addition, 
teachers can determine whether their state would accept these workshops 
as credit toward the state HOUSSE requirement online. As of September 
2005, all states and the District of Columbia were awarding points for 
teachers' participation in these workshops as part of their HOUSSE 
procedures or for teacher recertification. 

Education also offered assistance directly to teachers to help them 
understand NCLBA's requirements and gave teachers an opportunity to 
provide feedback about what additional support they need. Education 
distributed 255,000 "Toolkit for Teachers" information packets that 
provide information about NCLBA's teacher qualification requirements. 
The toolkit addressed frequently asked questions that are relevant to 
teachers, such as whether NCLBA's teacher qualification requirements 
apply to special education teachers. In addition, Education offered a 
series of teacher roundtables that gave teachers an opportunity to 
share their views with Education officials on how Education can support 
them in the classroom. 

Education provided technical assistance to state officials from all 50 
states through site visits by the Teacher Assistance Corps (TAC). TAC 
visits, which took place prior to Education's monitoring of NCLBA's 
teacher qualification requirements, were intended to help states 
implement the requirements, according to Education officials. The TAC 
teams that conducted site visits were composed of Education officials 
and experts. Education characterized these visits as "conversations 
without consequences" and did not provide written feedback to states 
based on the TAC visits. Education officials said that TAC teams 
discussed HOUSSE procedures, the collection of data on teacher 
qualifications, the best use of Title II funds, and other issues. 
Officials from two of the six states that we visited said that TAC 
suggestions helped them implement their HOUSSE procedures. Three other 
states that we visited said that TAC teams' suggestions were not useful 
in their circumstances. For example, officials in one state said that 
Education's suggestion that small rural districts share teachers to 
ensure that students are taught by teachers who meet NCLBA's 
requirements was impractical given the distance between schools. Based 
on difficulties that states identified during TAC visits, Education 
offered science teachers and teachers of multiple subjects, including 
rural teachers, additional flexibility in meeting NCLBA's teacher 
requirements. 

Through TAC visits, Education officials identified state and local 
initiatives that they considered to be innovative ways of improving 
teacher qualifications. Such initiatives addressed teacher 
certification and licensing, professional development, and other 
topics. In an effort to share information on these state and local 
initiatives with policy makers or others, Education posted information 
about these initiatives on www.teacherquality.us. 

Education has provided guidance and hosted meetings for state officials 
on the implementation of NCLBA's teacher qualification requirements. 
Education's guidance answered questions about NCLBA's teacher 
qualification requirements and Title II, such as when teachers with 
alternative certification can be considered as having met NCLBA's 
teacher requirements. Education officials reported that they update 
their guidance periodically to answer new questions about the teacher 
requirements, most recently in August 2005. In addition, Education 
convenes state Title II directors once a year to provide updates on the 
implementation of NCLBA's teacher requirements. 

Education has also funded several projects that work to improve the 
preparation and increase the numbers of special education teachers. For 
example, one center compared special education teachers prepared in 
alternative certification programs with their counterparts from 
traditional preparation programs. 

Some Information on Education's Web Site Was Not Readily Accessible: 

According to Education officials, Education's Web site has been an 
important part of their outreach efforts regarding NCLBA's teacher 
qualification requirements. Several of the resources related to 
implementation of the teacher qualification requirements, such as the 
Teacher Toolkit and state innovative practices, are now available only 
through Education's Web site. However, officials from most states and 
districts that we visited who use Education's Web site to access 
information on teacher programs or requirements told us that they were 
unaware of some of Education's teacher resources or had difficulty 
accessing those resources. For example, although all of the states we 
visited accepted Education's professional development for credit toward 
recertification or HOUSSE, district officials from only 3 of the 11 
districts we spoke with were aware of these opportunities or that they 
were available online. Moreover, officials in 4 of the states that we 
visited told us that they wanted to know more about other states' 
initiatives to improve teacher qualifications but were not aware that 
Education had made this information available online or did not know 
how to access the information. In the states that we visited, several 
state and local officials mentioned that they attempted to find 
information by using Education's search function but often had trouble 
finding what they needed. 

In our review of Education's Web site, we found that information and 
resources on the teacher qualification requirements were located on 
several different Web pages that sometimes were not linked, making the 
information difficult to locate. For example, state initiatives were 
available through the "Teachers" section of Education's Web site and 
not through the "Administrators" section, even though state and local 
administrators would likely find this information more useful than 
teachers would. See figure 4 for the description of teacher 
qualification information included on different sections of Education's 
Web site. 

Figure 4: Information on Teacher Qualifications Available through 
Education's Web Site, as of August 2005: 

[See PDF for image] 

[End of figure] 

Conclusions: 

Since we last reported on the status of implementing the teacher 
qualification requirements in our 2003 report, state and district 
officials have taken steps to implement these requirements, such as 
reducing the number of uncertified teachers and developing data systems 
to track teachers' qualifications. In addition, Education officials 
indicated that states have taken steps to raise teacher qualifications 
through changes in state certification systems. 

Although states have made progress in tracking teacher qualifications 
data and reporting on their status in meeting the requirements, 
difficulties remain in identifying teachers who do not meet the 
requirements. This may be a challenge, particularly because a number of 
states did not include all teachers in their calculations or faced 
other data issues. Where data challenges exist, Education and the 
states may not have the information necessary to direct assistance to 
where it is most needed. This may result in some teachers not receiving 
appropriate support to help them meet the requirements. Education is 
working on identifying data challenges and addressing them through its 
monitoring visits and other technical assistance to states. Until these 
data issues are resolved, state reports on their status in meeting the 
teacher qualification requirements should be viewed as preliminary. 

To facilitate state and district implementation efforts, Education 
relies extensively on its Web site as one of its principal means for 
providing information and implementation resources for states and 
districts. However, state and district officials told us that they were 
unaware of some of the information resources that Education made 
available and had difficulty locating other known sources of 
information on Education's Web site. Consequently, states and districts 
may not be taking full advantage of the opportunities and flexibilities 
made available by Education that would help them meet teacher 
qualification goals. Further, without this information, some states and 
districts may not be correctly applying the requirements, thus 
jeopardizing the ability of their teachers to meet the requirements by 
the deadline. This may impede efforts to increase student performance 
and ensure that all students reach state standards. 

Finally, even when all teachers have met NCLBA's qualification 
requirements, it is unclear whether their doing so will have the 
expected effect on student performance. Under the law, states have 
considerable flexibility in developing requirements for teachers to 
demonstrate subject matter competency. The rigor of these requirements 
varied across states. Consequently, it remains to be seen how different 
state requirements will affect the quality of instruction and student 
performance. 

Recommendation for Executive Action: 

We recommend that the Secretary of Education explore ways to make the 
Web-based information on teacher qualification requirements more 
accessible to users of its Web site. Specifically, the Secretary may 
want to more prominently display the link to state teacher initiatives, 
as well as consider enhancing the capability of the search function. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to Education for review and comment. 
In its letter, Education agreed with our recommendation, indicating 
that the department has already taken steps to address it. 
Specifically, the department is reviewing how teacher qualification 
information on the "Teachers" section of its Web site can be better 
integrated with related information on other Web sites, including 
teacherquality.us. Education's written comments are reproduced in 
appendix IV. 

We are sending copies of this report to the Secretary of Education, 
relevant congressional committees, and other interested parties. We 
will also make copies available to others upon request. In addition, 
the report will be made available at no charge on GAO's Web site at 
http://www.gao.gov. 

Please contact me at (202) 512-7215 if you or your staff have any 
questions about this report. Other contacts and major contributors are 
listed in appendix V. 

Signed by: 

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

[End of section] 

Appendix I: Activities on Which States and Districts Can Spend Title 
II, Part A, Funds: 

Table 3 lists our summaries of the authorized activities on which 
states can spend Title II funds and shows the five categories we used 
to group them. After reserving 1 percent of the total Title II 
allocation to the state for administrative activities, states retain 
only 2.5 percent of the remaining 99 percent for state activities. 

Table 3: Title II, Part A, State Activities: 

Category: Accountability; 

Activity: 1. Developing systems to measure the effectiveness of 
professional development programs and strategies to document 
improvements in students' academic achievement. 

Activity: 2. Ensuring that teachers use challenging state academic 
content standards, assessments, and student achievement standards to 
improve their teaching practices and their student's achievement. 

Category: Certification; 

Activity: 3. Reforming teacher and principal certification. 

Activity: 4. Reforming tenure and implementing tests for subject matter 
knowledge. 

Activity: 5. Promoting license and certification reciprocity agreements 
with other states for teachers and principals. 

Activity: 6. Providing programs that establish, expand, or improve 
alternative routes for state certification, especially for highly 
qualified individuals in the areas of mathematics and science. 

Category: Professional development; 

Activity: 7. Conducting programs that provide support to teachers, such 
as those that provide teacher mentoring and use assessments that are 
consistent with student academic achievement standards. 

Activity: 8. Providing professional development for teachers and 
principals. 

Activity: 9. Developing or assisting local educational agencies (LEAs) 
in developing and using proven innovative strategies for intensive 
professional development programs that are both cost-effective and 
easily accessible. 

Activity: 10. Encouraging and supporting the training of teachers and 
administrators to integrate technology into curricula and instruction, 
including training to improve their ability to use data to improve 
their teaching. 

Activity: 11. Providing assistance to teachers to enable them to meet 
certification, licensing, or other Title II requirements needed to 
become highly qualified. 

Category: Recruitment and retention; 

Activity: 12. Developing or assisting LEAs to develop, merit-based 
performance systems and strategies that provide pay differentials and 
bonus pay for teachers in academic subjects in which there is high 
need. 

Activity: 13. Developing projects and programs to encourage men to 
become elementary teachers. 

Activity: 14. Establishing and operating a statewide clearinghouse and 
programs for the recruitment, placement, and retention of teachers. 

Activity: 15. Assisting LEAs and schools in recruiting and retaining 
highly qualified teachers, including specialists in core subjects. 

Activity: 16. Developing or assisting LEAs to develop teacher 
advancement initiatives that promote professional growth and emphasize 
multiple career paths and pay differentiation. 

Category: Technical assistance; 

Activity: 17. Fulfilling the state agency's responsibility to properly 
and efficiently carry out the administration of programs, including 
providing technical assistance to LEAs. 

Activity: 18. Assisting LEAs to develop and implement professional 
development programs and school leadership academies for principals and 
superintendents. 

Source: NCLBA Pub.L. No. 107-110, section 2113. 

[End of table] 

Table 4 lists our summaries of the authorized activities on which 
districts can spend Title II funds and shows the two categories we used 
to group them. After reserving 1 percent of the total Title II 
allocation to the state for administrative activities, states allocate 
95 percent of the remaining 99 percent to the districts. 

Table 4: Title II, Part A, District Activities: 

Category: Professional development; 

Activity: 1. Providing professional development activities for teachers 
and principals that improve their knowledge of their core subjects and 
effective instructional strategies. 

Activity: 2. Carrying out professional development activities designed 
to improve the quality of principals and superintendents. 

Activity: 3. Carrying out teacher advancement initiatives to promote 
professional growth and to emphasize multiple career paths and pay 
differentiation. 

Activity: 4. Carrying out programs and activities that are designed to 
improve the quality of teachers, such as professional development 
programs, merit pay programs, and testing teachers in the subjects they 
teach. 

Category: Recruitment and retention; 

Activity: 5. Developing and implementing mechanisms to assist schools 
in effectively recruiting and retaining highly qualified teachers and 
principals. 

Activity: 6. Developing and implementing initiatives to retain highly 
qualified teachers and principals, particularly in schools with a high 
percentage of low-achieving students, including programs that provide 
teacher mentoring and incentives. 

Activity: 7. Carrying out programs and activities related to exemplary 
teachers. 

Activity: 8. Developing and implementing initiatives to assist schools 
in recruiting and hiring teachers, including providing financial 
incentives and establishing programs that train and hire special 
education and other teachers, recruit qualified professionals from 
other fields, and provide increased opportunities for minorities, 
individuals with disabilities, and others. 

Activity: 9. Hiring highly qualified teachers in order to reduce class 
size, particularly in the early grades. 

Source: NCLBA Pub.L. No. 107-110, section 2123. 

[End of table] 

[End of section] 

Appendix II: State-Reported Percentage of Core Academic Classes Taught 
by Teachers Meeting NCLBA's Teacher Qualification Requirements in the 
2003-2004 School Year: 

State: Alabama; 
All schools: 77%; 
High-poverty schools: 68%; 
Low-poverty schools: 79%; 
Elementary schools: 80%; 
Secondary schools: 77%. 

State: Alaska; 
All schools: Data not provided by the state; 
High-poverty schools: Data not provided by the state; 
Low-poverty schools: Data not provided by the state; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Arizona; 
All schools: 96%; 
High-poverty schools: 96%; 
Low-poverty schools: 96%; 
Elementary schools: 98%; 
Secondary schools: 94%. 

State: Arkansas; 
All schools: Data not provided by the state; 
High-poverty schools: Data not provided by the state; 
Low-poverty schools: Data not provided by the state; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: California; 
All schools: 52%; 
High-poverty schools: 40%; 
Low-poverty schools: 60%; 
Elementary schools: 49%; 
Secondary schools: 53%. 

State: Colorado; 
All schools: 91%; 
High-poverty schools: 90%; 
Low-poverty schools: 92%; 
Elementary schools: 95%; 
Secondary schools: 86%. 

State: Connecticut; 
All schools: 99%; 
High-poverty schools: 98%; 
Low-poverty schools: 99%; 
Elementary schools: 99%; 
Secondary schools: 99%. 

State: Delaware; 
All schools: 73%; 
High-poverty schools: 68%; 
Low-poverty schools: 74%; 
Elementary schools: 74%; 
Secondary schools: 72%. 

State: District of Columbia; 
All schools: Data not provided by the state; 
High-poverty schools: Data not provided by the state; 
Low-poverty schools: Data not provided by the state; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Florida; 
All schools: 89%; 
High-poverty schools: 87%; 
Low-poverty schools: 91%; 
Elementary schools: 94%; 
Secondary schools: 85%. 

State: Georgia; 
All schools: 97%; 
High-poverty schools: 97%; 
Low-poverty schools: 98%; 
Elementary schools: 98%; 
Secondary schools: 95%. 

State: Hawaii; 
All schools: 73%; 
High-poverty schools: 71%; 
Low-poverty schools: 73%; 
Elementary schools: 90%; 
Secondary schools: 68%. 

State: Idaho; 
All schools: 97%; 
High-poverty schools: 98%; 
Low-poverty schools: 96%; 
Elementary schools: 98%; 
Secondary schools: 97%. 

State: Illinois; 
All schools: 98%; 
High-poverty schools: 93%; 
Low-poverty schools: 100%; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Indiana; 
All schools: 96%; 
High-poverty schools: 94%; 
Low-poverty schools: 97%; 
Elementary schools: 96%; 
Secondary schools: 97%. 

State: Iowa; 
All schools: 95%; 
High-poverty schools: 96%; 
Low-poverty schools: 95%; 
Elementary schools: 97%; 
Secondary schools: 94%. 

State: Kansas; 
All schools: 95%; 
High-poverty schools: 96%; 
Low-poverty schools: 95%; 
Elementary schools: 98%; 
Secondary schools: 93%. 

State: Kentucky; 
All schools: 95%; 
High-poverty schools: 98%; 
Low-poverty schools: 95%; 
Elementary schools: 99%; 
Secondary schools: 92%. 

State: Louisiana; 
All schools: 90%; 
High-poverty schools: 87%; 
Low-poverty schools: 92%; 
Elementary schools: 95%; 
Secondary schools: 86%. 

State: Maine; 
All schools: 90%; 
High-poverty schools: 91%; 
Low-poverty schools: 91%; 
Elementary schools: 93%; 
Secondary schools: 89%. 

State: Maryland; 
All schools: 67%; 
High-poverty schools: 47%; 
Low-poverty schools: 78%; 
Elementary schools: 73%; 
Secondary schools: 64%. 

State: Massachusetts; 
All schools: 94%; 
High-poverty schools: 88%; 
Low-poverty schools: 96%; 
Elementary schools: 95%; 
Secondary schools: 92%. 

State: Michigan; 
All schools: 92%; 
High-poverty schools: 92%; 
Low-poverty schools: 93%; 
Elementary schools: 97%; 
Secondary schools: 89%. 

State: Minnesota; 
All schools: 99%; 
High-poverty schools: 98%; 
Low-poverty schools: 99%; 
Elementary schools: 99%; 
Secondary schools: 98%. 

State: Mississippi[A]; 
All schools: 93%; 
High-poverty schools: 89%; 
Low-poverty schools: 95%; 
Elementary schools: 97%; 
Secondary schools: 91%. 

State: Missouri; 
All schools: 96%; 
High-poverty schools: 92%; 
Low-poverty schools: 97%; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Montana; 
All schools: 99%; 
High-poverty schools: 98%; 
Low-poverty schools: 99%; 
Elementary schools: 99%; 
Secondary schools: 98%. 

State: Nebraska; 
All schools: 91%; 
High-poverty schools: 90%; 
Low-poverty schools: 95%; 
Elementary schools: 98%; 
Secondary schools: 90%. 

State: Nevada; 
All schools: 64%; 
High-poverty schools: 59%; 
Low-poverty schools: 75%; 
Elementary schools: 71%; 
Secondary schools: 51%. 

State: New Hampshire; 
All schools: 73%; 
High-poverty schools: 69%; 
Low-poverty schools: 73%; 
Elementary schools: 76%; 
Secondary schools: 70%. 

State: New Jersey; 
All schools: 94%; 
High-poverty schools: 88%; 
Low-poverty schools: 96%; 
Elementary schools: 94%; 
Secondary schools: 95%. 

State: New Mexico; 
All schools: 67%; 
High-poverty schools: 63%; 
Low-poverty schools: 72%; 
Elementary schools: 74%; 
Secondary schools: 65%. 

State: New York; 
All schools: 92%; 
High-poverty schools: 81%; 
Low-poverty schools: 97%; 
Elementary schools: 92%; 
Secondary schools: 94%. 

State: North Carolina; 
All schools: 85%; 
High-poverty schools: 82%; 
Low-poverty schools: 87%; 
Elementary schools: 88%; 
Secondary schools: 82%. 

State: North Dakota; 
All schools: 77%; 
High-poverty schools: 83%; 
Low-poverty schools: 73%; 
Elementary schools: 100%; 
Secondary schools: 56%. 

State: Ohio; 
All schools: 93%; 
High-poverty schools: 91%; 
Low-poverty schools: 95%; 
Elementary schools: 93%; 
Secondary schools: 93%. 

State: Oklahoma; 
All schools: 98%; 
High-poverty schools: 97%; 
Low-poverty schools: 98%; 
Elementary schools: 98%; 
Secondary schools: 98%. 

State: Oregon; 
All schools: 87%; 
High-poverty schools: 85%; 
Low-poverty schools: 89%; 
Elementary schools: 97%; 
Secondary schools: 85%. 

State: Pennsylvania; 
All schools: 97%; 
High-poverty schools: 92%; 
Low-poverty schools: 99%; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Puerto Rico; 
All schools: Data not provided by the state; 
High-poverty schools: Data not provided by the state; 
Low-poverty schools: Data not provided by the state; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Rhode Island; 
All schools: 76%; 
High-poverty schools: 77%; 
Low-poverty schools: 74%; 
Elementary schools: 75%; 
Secondary schools: 75%. 

State: South Carolina; 
All schools: 75%; 
High-poverty schools: 68%; 
Low-poverty schools: 79%; 
Elementary schools: 75%; 
Secondary schools: 75%. 

State: South Dakota; 
All schools: 93%; 
High-poverty schools: 89%; 
Low-poverty schools: 93%; 
Elementary schools: 94%; 
Secondary schools: 91%. 

State: Tennessee; 
All schools: 58; 
High-poverty schools: 57%; 
Low-poverty schools: 50%; 
Elementary schools: 60%; 
Secondary schools: 51%. 

State: Texas; 
All schools: 92%; 
High-poverty schools: 92%; 
Low-poverty schools: 93%; 
Elementary schools: 97%; 
Secondary schools: 93%. 

State: Utah; 
All schools: 69%; 
High-poverty schools: 65%; 
Low-poverty schools: 73%; 
Elementary schools: 80%; 
Secondary schools: 70%. 

State: Vermont; 
All schools: Data not provided by the state; 
High-poverty schools: Data not provided by the state; 
Low-poverty schools: Data not provided by the state; 
Elementary schools: Data not provided by the state; 
Secondary schools: Data not provided by the state. 

State: Virginia; 
All schools: 95%; 
High-poverty schools: 92%; 
Low-poverty schools: 97%; 
Elementary schools: 96%; 
Secondary schools: 94%. 

State: Washington; 
All schools: 99%; 
High-poverty schools: 99%; 
Low-poverty schools: 99%; 
Elementary schools: 100%; 
Secondary schools: 99%. 

State: West Virginia; 
All schools: 96%; 
High-poverty schools: 97%; 
Low-poverty schools: 95%; 
Elementary schools: 97%; 
Secondary schools: 95%. 

State: Wisconsin; 
All schools: 98%; 
High-poverty schools: 96%; 
Low-poverty schools: 99%; 
Elementary schools: 99%; 
Secondary schools: 98%. 

State: Wyoming; 
All schools: 99%; 
High-poverty schools: 99%; 
Low-poverty schools: 99%; 
Elementary schools: 100%; 
Secondary schools: 98%. 

Source: U.S. Department of Education, State Consolidated Performance 
Reports. 

Notes: We identified several factors that affect the accuracy of these 
data and preclude a comparison of classes taught by teachers meeting 
the requirements across states. However, on the basis of our work, we 
determined state-reported percentages could be used to demonstrate how 
close a particular state was to reaching the goal of having all its 
teachers meet the requirements. All numbers have been rounded to the 
nearest whole figure. 

[A] These data exclude classes that have students from both elementary 
and secondary grades. 

[End of table] 

[End of section] 

Appendix III: Sample HOUSSE Procedures from Two States Visited: 

[See PDF for image] 

[End of figure] 

[End of section] 

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

UNITED STATES DEPARTMENT OF EDUCATION: 
OFFICE OF ELEMENTARY AND SECONDARY EDUCATION: 

THE ASSISTANT SECRETARY: 

Ms. Marnie S. Shaul, Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

OCT 26 2005: 

Dear Ms. Shaul: 

Thank you for the opportunity to review the GAO's report on "Improved 
Accessibility to Education's Information Could Help States Further 
Implement Teacher Qualification Requirements." The Department of 
Education strongly believes that having highly qualified teachers 
available in all core academic classes is a critical strategy in 
closing the achievement gap, the primary goal of the No Child Left 
Behind legislation. We are pleased to see the effort that the GAO has 
invested in examining the states' progress toward this goal, and in 
reviewing and acknowledging the diverse ways in which the Department 
has supported their efforts. 

The GAO report contains the following recommendation for executive 
action: 

"We recommend that the Secretary of Education explore ways to make the 
Web-based information on teacher qualification requirements more 
accessible to users of its Web site. Specifically, the Secretary may 
want to more prominently display the link to state teacher initiatives, 
as well as consider enhancing the capability of the search function." 

The Department concurs with the GAO's recommendation, and has already 
taken steps to review how information on our ED.gov "Teachers" Web site 
can be expanded and better integrated with information on www 
teacherquality.us on the ESEA Title II Web site, and with Web sites 
located at other organizations that maintain related information. It is 
our goal that, within the next two months, we will provide a more 
seamless portal to all information about highly qualified teachers. 

Again, thank you for sharing your report on this timely and critical 
issue. 

Sincerely, 

Signed by: 

Henry L. Johnson: 

600 INDEPENDENCE AVE SW. 
WASIHNGTON, DC 20202: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Marnie S. Shaul, (202)512-7215, shaulm@gao.gov: 

Staff Acknowledgments: 

Harriet Ganson (Assistant Director) and Natalya Barden (Analyst-in- 
Charge) managed all aspects of the assignment. Scott Spicer, Katharine 
Leavitt, and Deborah Edwards made significant contributions to this 
report. Other key contributors to this report included Jessica 
Botsford, Richard Burkard, Emily Leventhal, Jonathan McMurray, Jean 
McSween, John Mingus, and Shannon VanCleave. 

[End of section] 

Related GAO Products: 

No Child Left Behind Act: Education Could Do More to Help States Better 
Define Graduation Rates and Improve Knowledge about Intervention 
Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005. 

No Child Left Behind Act: Most Students with Disabilities Participated 
in Statewide Assessments, but Inclusion Options Could Be Improved. GAO- 
05-618. Washington, D.C.: July 20, 2005. 

Charter Schools: To Enhance Education's Monitoring and Research, More 
Charter School-Level Data Are Needed. GAO-05-5. Washington, D.C.: Jan. 
12, 2005. 

No Child Left Behind Act: Education Needs to Provide Additional 
Technical Assistance and Conduct Implementation Studies for School 
Choice Provision. GAO-05-7. Washington, D.C.: Dec. 10, 2004. 

No Child Left Behind Act: Improvements Needed in Education's Process 
for Tracking States' Implementation of Key Provisions. GAO-04-734. 
Washington, D.C.: Sept. 30, 2004. 

No Child Left Behind Act: Additional Assistance and Research on 
Effective Strategies Would Help Small Rural Districts. GAO-04-909. 
Washington, D.C.: Sept. 23, 2004. 

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. 

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

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

FOOTNOTES 

[1] In its October 21 letter to the states, the Department of Education 
(Education) indicated that states demonstrating a good-faith effort to 
meet the teacher qualification requirements will have until the end of 
2006-2007 school year for all teachers to become highly qualified. 
Education acknowledged the effects of Hurricane Katrina on the ability 
of some states to meet the teacher qualification requirements by the 
deadline, and noted in this and other correspondence that it will work 
with affected states and school districts to determine whether any 
flexibility will be needed with regard to implementing these 
requirements. As of October 21, Education had not granted any waivers 
regarding the teacher qualification requirements to affected states, 
but indicated that it may consider certain waivers or additional 
flexibility, depending on state's needs. Education indicated in a 
September 21 letter to Louisiana that it may extend the deadline for 
reporting on the state's implementation of NCLBA provisions, including 
reporting on the status of teachers in meeting the requirements, if the 
states determine that additional time is needed. In response to 
Mississippi's request for a waiver of the teacher qualification 
requirements, Education noted in a September 12 letter to the state 
that it would continue to review this matter and would like more 
information to assess the state's specific needs. Finally, Education 
noted in a September 21 letter to Texas that it will postpone its 
monitoring visit to assess the state's implementation of the teacher 
qualification requirements, originally scheduled for December 2005. 

[2] In its October 21 letter to the states, Education indicated that it 
reserves the right to take appropriate action including the withholding 
of funds if states are not in compliance with the statutory teacher 
qualification requirements or are not making a good-faith effort to 
ensure that all teachers meet the qualification requirements. 

[3] See GAO, 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). 

[4] "The Real Value of Teachers," Thinking K-16, Vol. 8, Issue 1 (The 
Education Trust, Winter 2004). 

[5] U.S. Department of Education, National Center for Education 
Statistics, The Condition of Education 2005. (U.S. Department of 
Education, Institute of Education Sciences, 2005). 

[6] Core subjects include English, reading or language arts, 
mathematics, science, foreign languages, civics and government, 
economics, arts, history, and geography. 

[7] NCLBA requirements make an exception in the certification 
requirement for charter school teachers. The law provides that teachers 
in charter schools meet the certification requirements set forth in 
their state's charter school law regarding certification or licensure. 
A recent GAO survey found that officials in 13 of the 39 surveyed 
states reported that their state law exempted charter school teachers 
from certification requirements. 

[8] We use the term "veteran teacher" to refer to teachers who are not 
new to the teaching profession. Education's August 2005 guidance says 
that states have the authority to define which teachers are new and not 
new to the profession, as long as these definitions are reasonable. 
According to the guidance, Education believes that teachers with less 
than 1 year of experience should be considered new and therefore must 
meet subject matter competency requirements using the methods allowable 
for new teachers. 

[9] A self-contained classroom is one in which the students stay with 
their teacher all day and for all academic subjects. In these 
classrooms, the special education teacher is responsible for providing 
instruction in more than one core academic subject and thus would need 
to demonstrate subject matter competency in each of the subjects 
taught. 

[10] IDEA is the primary federal law that addresses the educational 
needs of students with disabilities. Among other provisions, the law 
mandates that a free appropriate public education be made available to 
all eligible children with disabilities and requires an individualized 
education program for each student. 

[11] Under IDEA, states can determine the level of instruction provided 
by middle and high school teachers who teach students with significant 
cognitive disabilities. If the level of instruction that is being 
provided is equivalent to the level of instruction at the elementary 
level, the requirements for elementary teachers apply. 

[12] Title I, Part A, of the Elementary and Secondary Education Act, 
allocated more than $12 billion in fiscal year 2004 to serve 
disadvantaged students in approximately 90 percent of the nation's 
school districts. 

[13] In October 2005, Education announced that states showing 
sufficient effort in implementing the teacher qualification 
requirements but still falling short of having all their teachers meet 
them by the end of 2005-2006 school year, will be able to negotiate 
with Education a plan for achieving that goal by the end of 2006-2007 
school year. 

[14] See GAO-03-631. 

[15] See GAO, No Child Left Behind Act: Additional Assistance and 
Research on Effective Strategies Would Help Small Rural Districts, GAO-
04-909 (Washington, D.C.: Sept. 23, 2004). 

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

[17] For 2004, the poverty threshold was $19,484 annually for a family 
of four. 

[18] NCLBA defined professional development in Title IX of the act. 
Among other things, the definition emphasizes the type of professional 
development that increases teachers' academic knowledge, gives teachers 
the knowledge and skills to provide students with the opportunity to 
meet challenging state content and student achievement standards, is 
sustained and intensive rather than short-term, and increases teachers' 
understanding of effective instructional strategies that are based on 
the principles of scientifically based research. 

[19] Under Title VI of NCLBA, a district meeting its annual student 
proficiency goals may transfer up to 50 percent of the funds allocated 
under any of the following programs: Title II, Part A (Improving 
Teacher Quality State Grants); Title II, Part D (Educational Technology 
State Grants); Part A of Title IV (Safe and Drug-Free Schools and 
Communities); and Part A of Title V (State Grants for Innovative 
Programs). Districts not meeting their student proficiency goals for at 
least 2 years are identified for improvement and cannot transfer more 
than 30 percent of their funds under any given program. Districts not 
meeting their goals for at least 4 years are identified for corrective 
action and are prohibited from transferring funds under this option. 

[20] Under Section 2141 of NCLBA, if the district falls short of its 
annual measurable objectives for ensuring that teachers meet 
qualification requirements for 2 consecutive years, it has to develop 
an improvement plan. During the development of the improvement plan, 
the state must provide technical assistance to the district and to any 
schools served by the district that would enable it to meet its teacher 
qualification objectives. If the district continues to fall short of 
its annual measurable objectives and is also failing to meet its annual 
student proficiency goals for 3 consecutive years, the state has to 
enter into an agreement with the district. Under that agreement, the 
state works with the district to develop professional development 
strategies for teachers and principals to help the district meet its 
teacher qualification objectives, and in most cases the district cannot 
use Title I funds for hiring new paraprofessionals. 

[21] These states include approximately 97 percent of all public school 
students in the country. 

[22] High-poverty and low-poverty schools are respectively those in the 
top and bottom quartiles of poverty in the state; most states based 
this on the percentage of students eligible for free or reduced lunch 
in the school. 

[23] Education has followed up with four of the five entities that did 
not provide data. Officials indicated that changing definitions and 
challenges with data systems were among the reasons for not providing 
data. References to Education's efforts to collect and assess teacher 
qualifications data from the states includes the work completed by 
Education's data quality contractor. 

[24] As part of that study, GAO visited California, Connecticut, 
Illinois, Iowa, Maryland, North Carolina, Delaware, and Wyoming. See 
GAO-03-631. 

[25] Special education teachers must be included if they teach core 
academic subjects. 

[26] District officials in this state told us that teachers with 
emergency certification and a plan to meet the requirements counted as 
meeting the requirements. 

[27] These states did not overlap with our site visit states. 
Education's findings are discussed in a subsequent section of this 
report. 

[28] Education's contractor plans to issue a report on its findings 
regarding state teacher qualifications data in fall 2005. 

[29] Colorado allowed teachers to demonstrate subject matter competency 
through accumulation of 24 college or professional development credits. 
Up to one-fourth of these credit hours could be accumulated through 
travel relevant to the subject area taught, such as travel to Greece 
for a history teacher. Officials there indicated that to count travel 
toward demonstration of subject matter competency, a teacher would need 
to explain what was learned as the result of this travel and how this 
knowledge would contribute to student performance, as well as 
demonstrate how the travel enhanced his or her content knowledge. The 
responsibility for ensuring the relevance of travel is with the 
districts, and state officials did not know how often this option was 
actually used. 

[30] The National Board for Professional Teaching Standards offers 
National Board Certification in subject areas such as English language 
arts and mathematics, requiring teachers to create a portfolio 
demonstrating their work in the subject area and exercises to 
demonstrate their subject matter knowledge. For more information, 
please see http://www.nbpts.org/. 

[31] Officials in California explained that their teacher preparation 
program included subject-specific coursework, and they expected that 
their veteran teachers would count points for college coursework and 
experience before counting points for other activities on the state's 
HOUSSE. 

[32] Education had not yet monitored these states at the time of our 
site visits. 

[33] Officials in California noted that the recency requirement applies 
to professional development activities accepted under the state's 
HOUSSE. Specifically, teachers can earn points only for those 
professional development activities that had been completed after the 
adoption of the state's professional development standards in 1997. 

[34] Such data are available for teachers through the Tennessee Value- 
Added Assessment System. 

[35] According to the Department of Education, states have the 
flexibility to determine whether middle school teachers--such as sixth 
grade teachers in some districts--will have to meet the requirements 
for elementary or secondary teachers, depending on the degree of rigor 
and technicality of the subject matter that the teacher will need to 
know in relation to the state's content standards and academic 
achievement standards for the subjects that will be taught. 

[36] The new certificate will allow teachers with significant subject 
matter competency coursework to teach for up to 2 years as long as they 
demonstrate progress toward meeting the subject matter requirements. 
After meeting the subject matter requirements, they can move into one 
of the state's alternative certification programs to obtain a teaching 
certificate. Under NCLBA, teachers in alternative certification 
programs are considered to have met the requirements as long as they 
receive high-quality professional development and intensive 
supervision, assume the functions of a teacher for no more than 3 
years, and demonstrate satisfactory progress toward obtaining state 
certification. 

[37] Education monitors state and district efforts on this requirement 
through its Title I monitoring. NCLBA does not make any provisions for 
penalties for districts failing to make this notification. 

[38] See GAO-03-631. 

[39] Our survey of a nationally representative sample of school 
districts during 2002-2003 school year showed that classroom reduction 
expenditures accounted for 56 percent of total Title II funds districts 
spent. See GAO-03-631. 

[40] Education's survey of a nationally representative sample of school 
districts showed that they spent 58 percent of Title II funds on 
teachers' salaries to reduce class size during 2002-2003 school year. 
See "Improving Teacher Quality in U.S. School Districts; Districts' Use 
of Title II, Part A, Funds in 2002-2003," Policy and Program Brief, 
U.S. Department of Education, February 6, 2004. 

[41] Two of the 11 districts reported using additional criteria in 
making Title II funding decisions. 

[42] NCLBA requires states to develop annual measurable objectives for 
adequate yearly progress that schools and districts must meet to ensure 
that every student becomes proficient in math and reading/language arts 
by school year 2013-2014. 

[43] We visited one district that did not have high-poverty schools but 
was chosen because of its rural location. 

[44] After awarding to each district the amount of Title II funds 
equivalent to what the district received in fiscal year 2001 under the 
Eisenhower Professional Development and Class-Size Reduction programs, 
the state allocates any excess funds to the districts based on the 
following formula: 20 percent of the excess funds must be distributed 
based on the district's relative number of individuals ages 5 through 
17 residing in the area served by the district; 80 percent of the 
excess funds must be distributed based on the relative number of 
individuals ages 5 through 17 residing in the area served by the 
district who are also from families with incomes below the poverty 
line. 

[45] See GAO-03-631. 

[46] Hamilton County Schools is an urban school district in 
Chattanooga, Tennessee, with 79 schools, 2,674 full-time teachers, and 
student enrollment of 40,494 in the 2004-2005 school year. 

[47] Denver Public Schools is an urban school district in Denver, 
Colorado, with 154 schools, 4,061 teachers, and student enrollment of 
72,901 in the 2004-2005 school year. 

[48] In November 2005, Denver voters approved a property tax increase 
that will be used to finance the differential compensation system. 
Beginning on January 1, 2006, all new teachers will be automatically 
enrolled in the new system; current teachers will be able to opt into 
the system over the first 7 years or remain in the current system. 

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