No Child Left Behind

Encouraging Spending on Parental Outreach for SES

Lindsey Luebchow — Mon, 28 Apr 2008 15:00:00 -0400

Many low-income parents with children in low-performing schools are not taking advantage of free tutoring available to them under No Child Left Behind. Under NCLB's "Supplemental Educational Services" (SES) provision, school districts that fail to meet academic benchmarks for three years must set aside part of their federal Title I grant to provide outside tutoring—but only a fraction of eligible students are using the program.

The Department of Education is trying to figure out how to increase take-up rates for the SES program. As part of a package of new NCLB regulations, the Department proposed this week that districts should be able to use part of their SES funding set-aside to conduct outreach activites to educate parents about the program (this currently isn't allowed). This is a logical, beneficial addition to the SES provision that hopefully will encourage districts to implement more intensive, effective ways to inform parents about SES.

Low Levels of SES Participation...

In the 2003-04 school year, 1,377,000 students were eligible for SES (eligible students are low-income students who are enrolled in schools that have failed to make Adequate Yearly Progress (AYP) for three consecutive years). But only 233,000 of those students—a mere 17 percent of eligible students nationwide—participated in SES, according to the most recent National Assessment of Title I.

Other studies of individual states and districts have found similarly low participation rates. While the overall number of students participating in SES has increased in recent years, this is a result of the rising number of failing schools and eligible students, not take-up (see graph to right).

...and Spending

NCLB requires school districts to set aside 20 percent of their Title I grants for SES and school choice (low-income students can also choose to transfer to another school after two years of AYP failure by their school). Administrative costs, such as parental outreach, cannot be included in the 20 percent. If a district does not spend the entire 20 percent set-aside—either because not enough students are eligible or because not enough students choose to participate—it can reallocate the remaining funds to other Title I activities.

A GAO report estimated that districts nationwide spent 42 percent of the total amount set aside for SES in 2004-05. Of course, spending on SES varies from district to district, and in some districts—primarily large, urban districts with significant numbers of failing schools and eligible students—the demand may exceed the funding available for SES. But this is not the norm (in this case, districts must prioritize the lowest-achieving students). In 2004-05, the GAO estimated that 16 percent of districts could not provide SES to all students who requested it with their 20 percent set-aside. In the majority of school districts, SES funds are under-utilized, allowing districts to redirect the unused SES money to other purposes.

Increasing Participation Takes Effort, and Money

Free tutoring should be an appealing option to most parents, so why does only one out of every five eligible students nationwide take advantage of the SES program? Most case studies find that the main obstacle is inadequate parental outreach and engagement.

NCLB requires districts to "promptly provide to a parent or parents (in an understandable and uniform format and, to the extent practicable, in a language the parents can understand) of each [eligible] student...an explanation of the parents' option to obtain SES." This typically means that districts send a letter to parents of eligible students at the beginning of the year.

These letters often fail to explain the SES option in a clear, understandable way. And in some cases they are lost because of high mobility rates for low-income families. In addition, parents can find the task of choosing a SES provider and filling out the requisite paperwork overwhelming. Because districts cannot include administrative costs in their 20 percent set-aside spending, many are discouraged from taking more extensive and effective, but also more expensive, actions to notify parents.

For example, some proactive districts have used a variety of strategies to increase SES take-up. They have: called, visited at home, or held meetings at school with parents; hosted informational events such as SES fairs at which parents can explore provider options; worked with outside community organizations or churches to raise awareness; bought advertisements on radio, television, or billboards, etc.

Given the widespread information problems, it's commonsense to allow districts to use a small portion of the 20 percent set-aside to figure out how to engage more parents and students. The Department proposes allowing districts to spend up to 0.2 percent of the overall Title I grant on parental outreach, or 1 percent of the 20 percent set-aside. In addition, districts that are under-utilizing their SES and school choice funds should be given other options to support low-income children in failing schools: for example, New America's Early Education Initiative, has proposed allowing districts to spend part of this money on high-quality pre-kindergarten for 3- and 4-year olds.

The Department recognizes that many low-income students in low-performing schools are not getting the additional academic support envisioned by NCLB. Encouraging districts to spend more money on parental outreach is a positive step toward reaching more of these students. Next up is accountability: the Department needs to show, conclusively, that this significant federal investment in SES is having a positive effect on student achievement. More to come on SES effectiveness from Ed Money Watch.

Tired of Waiting for Reauthorization, the Department of Education Regulates

Lindsey Luebchow — Thu, 24 Apr 2008 17:00:00 -0400

On Tuesday, the Department of Education unveiled a new set of proposed regulations on No Child Left Behind. The major announcement was details about the new, uniform graduation rate formula that all states will have to use for NCLB accountability purposes going forward. In addition, the Department outlined new requirements for district implementation of the Supplemental Educational Services (SES) provision.

In general, the proposed regulations focus on greater transparency for what's already happening in each state. At a briefing in Washington D.C., U.S. Deputy Secretary of Education Ray Simon said that the Department wants to make sure states and districts can justify what they are doing on assessment and accountability. He also raised concerns that districts are not adequately implementing NCLB's restructuring and SES requirements, and said that the Department wants to detail and reinforce what is already required by the law.

Here's a quick summary of the new proposed regulations, which were published today in the Federal Register and will be open for comment for 90 days:

Uniform Graduation Rates

By 2012-13, states, districts, and schools would have to use a "cohort graduation rate" formula, consistent with the National Governor's Association's formula.
Because it will take time for many states to collect the necessary data, they would have to use an "averaged freshman graduation rate" (AFGR) in the interim.

Adequate Yearly Progress (AYP): States currently require schools to show some improvement (generally only a minimal amount) in graduation rates in order to make AYP under NCLB. The Department wants to require that states set a specific goal and a timeline for improvement in graduation rates.

Disaggregation: By 2012-13, states would also have to report disaggregated graduation rates and use them in AYP calculations. In the meantime, disaggregated AFGR rates would have to be reported; however, because the AFGR is not accurate enough for small data groups, disaggregation would not be used for accountability purposes at the school level until the more accurate rate is available.
Transparency & Clarification
"N" Size: States are currently allowed to set their own minimum subgroup sizes ("N" sizes) for AYP reporting. The Department is concerned that too many students are being excluded in some states with large N sizes, and proposes requiring states to justify their N sizes and other technical AYP components in their accountability workbooks. These explanations would then undergo a peer review.

Restructuring: The Department wants to clarify school restructuring requirements, which it believes aren't being effectively implemented. Districts would have to show that schools in the restructuring phase are receiving much more comprehensive, tailored interventions than schools in earlier, corrective action phases.
Supplemental Education Services and School Choice
Parental Notification: Schools would have to notify parents of their school choice options at least 14 days before the start of the school year. When schools send out notices of SES eligibility, they would have to be "clearly distinguishable" from other NCLB information.

State Approval and Monitoring: The Department wants states to provide more information about how they approve and evaluate SES providers. In addition, the Department wants to expand the list of factors that a state must take into account when approving or monitoring the effectiveness of providers.

Title I Funds: Districts are not allowed to count the costs of parental outreach towards the 20 percent of their Title I grant that must go to SES and school choice. The Department proposes permitting districts to count those costs, up to 0.2 percent of the total Title I allocation. In addition, districts would have to prove that they have sufficiently exhausted SES and school choice opportunities before they could reallocate any remaining funds to other purposes.

Navigating the Rocky Road of School Improvement Funding

Lindsey Luebchow — Tue, 15 Apr 2008 15:00:00 -0400

As the number of schools identified for school improvement, corrective action, and restructuring under the No Child Left Behind Act continues to increase, states are under increasing pressure to improve student performance in these schools. Yet a new report from the Government Accountability Office finds that a little-known funding provision in NCLB is undermining state efforts to turn around low-performing schools.

The 4% Set-Aside vs. the Hold Harmless Provision

Under NCLB, schools that fail to meet state achievement benchmarks—otherwise known as Adequate Yearly Progress or AYP—for two consecutive years enter "school improvement" status. NCLB requires states to set aside four percent of their Title I funds to support school improvement activities—such as professional development, new curriculum, extended learning time, or full-scale restructuring—in these schools.

Yet many states are not able to reserve the full four percent of their Title I funds for school improvement, because a separate provision of the law prevents them from doing so. NCLB includes a "hold-harmless" provision that prevents states from reducing a school district's Title I funding more than 5 to 15 percent below the previous year's level as a result of the set-aside. States have to fulfill this obligation before reserving any funding for school improvement.

Title I funds are allocated to school districts through a formula that is based primarily on the number of poor children they enroll. The hold-harmless provision protects school districts from Title I funding cuts if their proportionate share of poor children declines. In practice, that means giving more money to such districts than the Title I formulas would allocate otherwise. After meeting hold-harmless requirements, some states have less than four percent of Title I funds left over to support school improvement.

The Result: Less, Unpredictable School Improvement Funding

According to a new report by the Government Accountability Office, 22 states have not been able to spend the full four percent of their annual Title I allocations on improvement activities for at least one year since 2002. A separate, earlier report by the Center for Education Policy found that 29 states would be unable to meet the four percent set-aside in 2007-08.

In theory, states should spend four percent of their Title I funds—a total of about $500 million out of the $12.8 Title I appropriation for fiscal year 2007—on school improvement. But the Center for Education Policy estimates that $192 million of that $500 million will be lost because of the hold-harmless provision.

Moreover, the amount of money states have to spend to satisfy hold-harmless requirements is unpredictable from year to year, depending on the amount of money that Congress appropriates for Title I and demographic changes across and within states. This instability makes it difficult for low-performing schools to implement coherent, long-term school reforms, as the amount of money they receive to support these efforts often fluctuates each year. Some states have compensated by finding other funding sources for school improvement activities. For example, states have used federal funds from the Comprehensive School Reform program, Reading First, and Improving Teacher Quality State Grants to support school improvement efforts. In addition, 17 states have used their own funds to help sustain improvement activities in low-performing schools.

Eliminating the Hold Harmless Provision

The Department of Education has recognized these problems with the four percent set-aside. The administration's 2007 budget request proposed eliminating the hold-harmless provision so that federal school improvement funding would stabilize at four percent of overall Title I funding.

As the GAO report points out, there has been little analysis of how the hold harmless provision affects different types of school districts. The Department claims that the provision is keeping too much federal money in lower-poverty school districts, and harming high-poverty, low-performing districts by leaving less money for them and for school improvement activities.

But this is all hypothesis. For years hold harmless provisions in Title II of NCLB protected districts throughout Mississippi from experiencing dramatic funding declines, whereas low-poverty but high-growth districts in California were slated for increases. GAO recommends that the Department of Education "develop an analysis comparing the characteristics of districts that contribute to the set-aside with those protected by the hold-harmless provision." The Department agreed with this recommendation. Congress will need to address this issue when it resumes reauthorization of NCLB legislation—and the Department must ensure it has the facts and data to make informed decisions about these policies.

A Separate School Improvement Funding Stream

The fiscal year 2007 budget also provided funding to support "School Improvement Grants" to states to supplement the four percent set-aside. Although NCLB authorized these grants, the Bush administration did not request funding for them until fiscal year 2007. Congress funded the program in fiscal year 2007 at $125 million and increased funding to $491 million in the current fiscal year. In order to receive the grants, which are distributed in proportion to each state's Title I allocation, states must submit an application and meet some additional reporting and accountability requirements.

As the four percent set-aside shrinks in many states, School Improvement Grants are an important source of additional federal funding needed to sustain school improvement activities in low-performing schools. The Bush administration has requested level-funding for this program in fiscal year 2009—even as the number of schools in school improvement status rises (8,400 in 2004-05 to 10,700 in 2006-07). In the near term, Congress must continue to fund, and possibly even expand, the School Improvement Grants program. It must also make sustained funding to support school turnaround efforts a key priority in the NCLB reauthorization.

What's Behind Standardized Graduation Rates? Data System Investment

Lindsey Luebchow — Wed, 09 Apr 2008 17:00:00 -0400

Last week Secretary of Education Margaret Spellings announced that the Department of Education will begin requiring all states to use the same method to calculate high school graduation rates. NCLB already requires states and high schools to report graduation rates, but it allows states to craft their own formulas to do so. The result: states inevitably found ways to inflate graduation statistics. And the state-by-state patchwork of methods used makes it impossible to compare graduation rates across states.

Spellings' announcement is an important, smart move following years of pressure from education and civil rights organizations to improve graduation rate data. Without comparable, meaningful data to expose low graduation rates, states can continue to ignore the drop-out crisis that is plaguing low-income communities—especially in urban areas—around the country.

But Spellings' announcement also raises some important questions: Do states have in place the data systems they need to calculate new, standardized graduation rates? And, if not, how will they pay for new state data systems? So far, neither Spellings nor news articles covering the new regulations have addressed these issues in any detail.

Where State Data Systems Stand

The first step toward accurate graduation rates is a student unit record data system that can track individual students. These systems assign a unique identification number to each student in the state, so that the state can follow individual students from the time they enroll in ninth grade through high school graduation—even if they transfer between schools or school districts.

An accurate graduation rate formula (such the one adopted by the National Governor's Association, which appears below) measures the percent of students from an entering ninth grade cohort who graduate with a standard diploma in four years. This is commonly known as a "cohort" method of calculating graduation rates.

According to the results of a 2007 survey by the Data Quality Campaign, 36 states have the full data system capability to calculate this formula. Seven other states have student unit records in place, but lack a robust data audit system. Robust audit systems ensure that districts report valid dropout data, and they are necessary to remedy past documented problems with unreliable district reporting.

All 43 states that have already invested in data systems to track individual high school students should be prepared to comply with new federal graduation rate measures within the next four years. Some states that implemented these data systems only recently may need time to accumulate four years of student data (from the time the first ninth grade class enrolls until they complete 12th grade) to calculate a cohort graduation rate.

But seven states that don't have the necessary data infrastructure to calculate accurate graduate rates are going to have to play catch up—and that will likely be expensive.

Laggards Face Data System Costs

The exact costs of establishing a student unit record data system depend on the data infrastructure a state already has in place, but they are substantial. The Data Quality Campaign estimates that putting in place the structure for these systems costs between $1 million and $3 million annually over several years of development—not including ongoing maintenance costs after the system is in place or staff time at the district level.

These seven states may not be eager to spend money on K-12 data initiatives. One reason they don't have them already is that they've been unwilling to pony up the necessary funds in the past. But soon they may not have a choice—although if the history of NCLB and IASA implementation is any guide, they will likely drag their feet. And they may complain about more "unfunded mandates" from the federal government.

NCLB does provide funding to help states cover the costs of developing and administering state assessments and standards—$409 million in fiscal year 2008, distributed to states based on their share of students ages 5 to 17. Once a state meets all of NCLB's assessment requirements, it can use the grant money for "support for data reporting." But given the limited amount of money available in this pot (average state grant: $7.6 million), many states don’t have a lot left over after annual testing costs. The Bush Administration's 2009 budget request did not propose any increase in funding for state assessments. And Secretary Spellings hasn't indicated that the Department of Education will provide additional funding to help states implement new graduation rate standards.

A Worthwhile Investment

States that haven't already invested in student unit record data systems may not want to pay the costs to do so. But in the long run, student unit record data systems are an incredibly valuable investment that every state should make. If new, standardized graduation rate standards require lagging states to improve their data systems, that will be an additional benefit of these requirements.

Even states that already have the framework in place for graduation rates could do a lot to further develop their systems—for example, tracking all students from pre-kindergarten through higher education, or performing more extensive coding of student characteristics and outcomes. This type of data is invaluable in education research and accountability efforts.

That is, if states actually use it. According to the Editorial Projects in Education Research Center, only 16 states used a cohort formula for NCLB accountability purposes in 2006-07, while others preserved their old formulas even if they had accumulated the data to use a more accurate cohort formula. In many cases, the less accurate measures produce inflated graduation rates that make states look like they're doing better than they actually are. Standardizing graduation rate measures will result in more accurate data—and make sure state taxpayers are getting their money's worth from new data systems.

Ending the Reading First Funding Limbo

Lindsey Luebchow — Wed, 02 Apr 2008 19:00:00 -0400

States and school districts are starting to feel the impact of major funding cuts to the federal Reading First program. Congress cut Reading First funding by 61 percent in fiscal year 2008—the unfortunate result of a serious federal-level management scandal. On the ground, however, the Reading First program is producing results in many schools, and school administrators and teachers have praised it.

President Bush's fiscal year 2009 budget request would return Reading First funding back to $1 billion annually. As school districts scramble to look for other funding sources to keep Reading First programs alive this year, Members of Congress should reassure them by making a commitment to restore funding in the fiscal year 2009 budget. Congress has made its point on the scandal and should end the political games.

The Administration did make grave errors in program management. But Secretary of Education Margaret Spellings has promised that the program is running cleanly, and she's fighting to restore funding to the $1 billion level.

Of course, in order to restore funding, Congress will have to pass a fiscal year 2009 appropriations bill, instead of a continuing resolution (which would maintain funding at the 2008 level for the next fiscal year). Reading First is a prime example of why Congress should work on and pass a Labor, Health and Human Services, and Education Appropriations bill—NOT postpone funding questions until fiscal year 2010. While some states and school districts may be able to produce one year of stop-gap funding to cover the Reading First cuts, most will have to significantly alter and downsize their Reading First programs if Congress maintains funding at $393 million for another year.

Schools Deal with Reduced Funding

Reading First funding supports a variety of reading initiatives, including professional development for teachers, additional reading coaches, and new curriculum, assessments, and diagnostic tools. These are intensive and costly interventions for low-performing children. This year's drastic reduction in funding is putting these initiatives in limbo, as districts do not know if they can find enough supplemental funding to continue them.

Some states have funds remaining from last year that they can carry over and use to maintain the current programs for at least one more year. Others may have to raid other federal programs, such as Title I or IDEA, for additional support, but these funding streams are also limited. Schools will have to make tough decisions about which federally supported interventions to prioritize.

A lot of states and districts are simply going to have to cut grants or discontinue programs at certain schools. This will require more difficult decisions: Should districts give priority to successful programs, or to programs that need the most development, or to programs that serve the lowest-performing children...?

Appropriations Politics

Congressional Democrats have signaled that they may not try to pass most fiscal year 2009 appropriations bills. Instead, they may use continuing resolutions to maintain funding for federal programs at the 2008 level until fiscal year 2010, when they hope to have a Democratic president in office. The likelihood that Congress and President Bush can agree on a Labor-HHS-Education spending bill for fiscal year 2009 does appear slim. But Congressional Democrats could postpone the fiscal year 2009 appropriations bill until early 2009, in the hope that a new president and Congress will quickly pass a bill upon entering office.

Whether Congress passes a fiscal year 2009 education appropriations bill under Bush or a new President doesn't matter to states and school districts, because they don't get fiscal year 2009 funding until July 1, 2009, regardless of when the legislation passes. What matters for Reading First programs is that Congress passes a fiscal year 2009 bill, because a continuing resolution will likely maintain the 61 percent funding cut. (There is some room for changing funding levels in a continuing resolution, but that room is limited and unlikely to be used for a large funding restoration.)

Leading Democrats should recognize that the Reading First cuts have real, negative consequences for their constituents, and they should set aside their political bias against the program and restore funding. This requires sitting down at the appropriations table and doing the tough budget work for the next fiscal year. They can accomplish a lot, particularly for low-performing schools, if they don't go the easier continuing resolution route.

"The Cure for Cancer"

Democrats must also continue Congressional scrutiny and assessment of Reading First's implementation. When Spellings recently told Reading First State Directors at a conference in Washington, D.C., "if ever there was a program that was rooted in research and science and fact, this is it. This is [like] the cure for cancer," she may have slightly exaggerated Reading First's results.

Reading First has produced promising achievement gains in many individual school studies. The first large-scale federal evaluation using achievement data has not been released yet, but according to the Office of Management and Budget's ExpectMore.Gov it "yielded positive results" and should be out soon.

There are many critics of the Department of Education's claims about Reading First's success, and they make good points. Reading First is not perfect and we need more evaluation to ensure that schools are using the funding in the scientifically based manner most effective for their students.

Promising to restore funding does not mean accepting Reading First as flawless. But Democrats should recognize that, on the whole, Reading First has been a positive federal investment, and there is room for program improvement with continued evaluation (and tighter management controls). If federal funding remains low, states will not be able to sustain the number or intensity of Reading First programs, and schools may lose reading achievement gains for low-performing children.

Spellings' Flexible NCLB Plan: Breaking, Not Bending

Ben Miller — Thu, 20 Mar 2008 21:40:00 -0400

With No Child Left Behind (NCLB) reauthorization stalled for the foreseeable future, Secretary of Education Margaret Spellings announced her own initiative Tuesday to introduce more flexibility into how schools are held accountable under the law. While we acknowledge that NCLB can be a blunt tool at times, we are wary that Spellings' vague plan will help states circumvent existing accountability measures.

Spellings' plan is designed to answer complaints that NCLB's required interventions don't differentiate between schools that fall just short of making adequate yearly progress (AYP) and those that aren't even close. Her proposal, therefore, would create a pilot program for up to 10 states that would allow them to shift resources to those schools that are badly missing AYP. According to Spellings, this differentiated accountability would help states provide "triage" for the "chronic underpeformers" by giving them aid that had previously gone to schools with scores closer to mandated targets.

We have serious concerns about this initiative. Since NCLB's passage - and the passage of the 1994 Improving America's Schools Act that preceded it - states have been strikingly recalcitrant about implementing the law's accountability requirements. They have lowered standards, gamed the system, and manipulated every possible loophole to reduce the number of schools identified as failing to make AYP. In the face of documented abuse of the significant flexibility that already exists under NCLB, giving them more leeway in how they implement accountability is potentially dangerous.

We agree with Spellings that, to some extent, more differentiated interventions in low performing schools make sense. Schools that are chronically failing the majority of their student body require different interventions than schools that narrowly miss goals in a few subgroups. The House Education Committee's draft NCLB legislation, widely circulated last fall, included some sensible approaches in that direction. But school districts and states already have substantial flexibility in how they implement the more consequential interventions for schools that have failed to make AYP for multiple years. The "other" option in NCLB's current menu of options for schools in restructuring - those that have failed to make AYP for over five years - is a loophole you can drive a truck through. And most states have. In only a few instances have school districts implemented the most intensive restructuring options, such as reconstituting a school's entire staff, converting it to a charter school, or closing it altogether. So, while we welcome some differentiation to allow states and districts to target intervention resources to the most troubled schools, we're very wary as to what that flexibility looks like.

Unfortunately, Spellings hasn't provided enough details to assuage our concerns on this score. The "fact sheet" the Department released Tuesday is incredibly vague, offering little indication of what states would be allowed to do under the pilot that they can't do under existing law. In her remarks, Spellings suggested that states "send [the] most experienced and effective teachers to work in the neediest schools" - but nothing in the law keeps them from doing that now! Nor is it clear what the Department expects states to do with the added flexibility. The fact sheet states that the Department will give priority for the pilot project to states that have "clear" and "significant and comprehensive" interventions for the lowest performing schools--but doesn't offer any clarification on what the standard for judging this will be.

We are also concerned that the pilot program could allow states to ignore schools that are coming close, but still missing, AYP. The fact remains that these schools are not meeting performance requirements and are leaving some groups of students behind. These "within range" schools, as Spellings refers to them, are not institutions that just had one down year. They are schools that missed AYP for at least two consecutive years and potentially longer. Less help for these failing schools suggests that it is ok to miss AYP so long as you come close - a notion that runs counter to the idea of leaving NO child behind, and could be particularly harmful to the most vulnerable subgroups of students.

The fact sheet says that states would still have to follow their existing AYP standards, so these schools presumably would continue to be identified for school improvement. But it's not at all clear whether they could be immune to the law's supplemental education services, school choice, and school improvement plan requirements - which would thwart NCLB's accountability goals for these schools.

An Alternative Plan

There are good reasons to introduce more differentiation into interventions for schools that fail to make AYP. This should not, however, be a zero-sum game where the Department of Education grants leniency to some schools in exchange for more intervention in another. And it certainly should not offer more leniency without a very strong guarantee of greater intervention in the lowest-performing schools. Congress has the opportunity in NCLB reauthorization to provide states with a clearly defined national minimum standard for intervention, which can vary depending on how close a school comes to making AYP. For instance, a school missing by just a few students could receive supplemental services, while one falling well short of the mark would be subject to harsher requirements. Adding flexibility in this manner would still give states the ability to experiment with new types of interventions that exceed the standard, while also ensuring that the initial goal of accountability is preserved. Or, to put it more succinctly, states would be able to bend, but not break when it comes to accountability.

Transforming Schools From The Ground Up

Christina Satkowski — Thu, 21 Feb 2008 00:00:00 -0500

Education policymakers are increasingly concerned about how to turn around chronically underperforming schools. Under the federal No Child Left Behind Act (NCLB), states and school districts must restructure schools that fail to make adequate yearly progress (AYP) for five years—and they’re looking for strategies to do so. At the same time, policymakers are focusing on early education—36 states increased pre-k funding in 2008. Yet these two policy strands rarely intersect.

They should. Research shows that quality pre-kindergarten can boost student achievement and narrow achievement gaps. While NCLB doesn’t require states to assesses students until grade three, the foundational skills that support students’ later learning are already in place by then. Therefore, efforts to improve chronically low-performing elementary schools must start early.

That’s why we’ve proposed changes to NCLB that would encourage school districts to reconstitute elementary schools identified for restructuring as "PK-3 Early Education Academies" featuring pre-k, full-day kindergarten, and aligned standards, curriculum, and teacher professional development from pre-k through grade three. A series of recent reports by the Center for Education Policy (CEP) about school restructuring efforts in California, Michigan, and Maryland provide further support for this idea. CEP identified factors that contribute to success in school restructuring:

Change the school culture. Principals of restructuring schools frequently identify the need to refocus their curriculum and inject new energy into the learning environment. Some of the successful restructurings CEP profiled brought outside specialists and coaches who helped reshape the schools’ missions and reinvigorate staff. Others changed culture by breaking up larger schools into small learning communities. As we’ve argued elsewhere, converting elementary schools to PK-3 academies is another strategy for reorienting school culture around a shared vision of early education.

Increased inter- and intra- grade collaboration makes an impact. Schools that set aside time for teacher collaboration were able to increase consistency and coordination of curriculum. PK-3 academies that emphasize alignment and integration of standards, curriculum, and teaching strategies offer a framework within which schools can build the kind of cooperation that CEP calls for.

There’s precedent for using a PK-3 focus to turnaround low-performing schools. Deep Creek Elementary in Baltimore County, for example, was once one of the county’s lowest performing schools, with only 38 percent of third graders were reading at grade level in 2003. But after a new principal implemented a vertically-aligned curriculum from pre-k through third grade, and expanded teacher professional development, the school made AYP, and 73 percent of students now read at grade level.

Of course, there are challenges to using a PK-3 reform strategy to turn around low-performing schools. CEP researchers note a tension in NCLB restructuring efforts between long term reform and the need to produce immediate results. Because early education reforms focus energy on non-tested grades, it can takes time to see the benefits—but such reforms produce lasting gains that extend all the way through the high school years, rather than temporary test score bumps.

Money is also a challenge. Officials in 32 states told CEP that NCLB provides insufficient funding to complete restructuring. And some elements of a PK-3 reform strategy, such as pre-k and full-day kindergarten, are expensive. States and schools districts need to think creatively about how they can use variety of funding streams—state pre-k programs, Reading First, Title I, and school improvement funds—to support PK-3 reforms. And federal policymakers can use NCLB reauthorization to increase resources for schools to implement such reforms.

The pressure of restructuring creates an opening for major changes in struggling schools. By focusing on the foundational early elementary years, and integrating pre-k and full-day kindergarten into school restructuring, policymakers have an opportunity to drive real improvement in early education for some of the students that need it the most.

Loophole Makes School Finance Inequity Within Districts Possible

Ed Policy — Tue, 19 Feb 2008 00:00:00 -0500

When the federal government started distributing compensatory education (i.e. Title I) funding in 1965, it wanted to ensure that federal money was supplementing, not supplanting, support to schools educating disadvantaged children. Thus, the government added fiscal requirements to Title I of the Elementary and Secondary Education Act that require communities to establish an even state and local school finance playing field within district — before supplemental Title I money is given to the highest-poverty schools.

For a school district to be eligible for federal funds under Title I, Part A of the Elementary and Secondary Education Act, it has to fulfill three fiscal requirements:

Maintenance of effort
School districts must maintain expenditures from state and local funding sources from year to year.
Comparability of services
School districts must provide services in Title I (high-poverty) schools that are at least comparable to the services provided in non-Title I (low-poverty) schools.
Supplement, not supplant
School districts must use Title I funds to supplement the activities supported by state and local funds that would have taken place in the absence of federal funds.

In theory, the "comparability" requirement has the greatest potential to help low-income students and schools. It's supposed to require school districts to change their long-standing practice of spending more money per pupil on schools with the lowest poverty rates. The maintenance of effort and supplement, not supplant and don’t address underlying finance structures.

But the legislative statute and regulations that define comparability contain a major loophole that renders the guarantee meaningless. The loophole allows school districts, when comparing education services provided at Title I and non-Title I schools, to ignore differences in spending on teachers, which consitutes over half of all state and local education spending.

In the first draft of a No Child Left Behind reauthorization bill released last fall, the House Education and Labor Committee proposed closing the comparability loophole. Done correctly, it could be the most important change to NCLB for low-income children.

[slideshow] Within-District Spending Disparities, and Why They Exist

Within-district, between-school spending disparities aren’t frequently discussed, but they are widespread, particularly within diverse districts that house a socio-economic range of neighborhoods and students. Disparities result mainly from an unequal distribution of teachers and teacher salaries among schools—more experienced, better paid teachers gravitate towards the lowest-poverty schools, while the highest-poverty schools are left with the least experienced, lowest paid teachers (and thus the highest-poverty schools receive less money per-pupil).

This type of teacher movement is allowed, because of the structure of union contracts with school districts. Staffing provisions in collective bargaining agreements grant preference for seniority, meaning that the most experienced teachers get first choice where they want to transfer and teach. And the better teaching conditions at lowest-poverty schools attract the higher-credentialed, more experienced teachers.

The Teacher Salary Loophole, and How it Undermines Comparability

It sounds like the comparability requirement might force districts to remedy these teacher spending disparities. Unfortunately, the legislation contains one major loophole that throws any possibility of meaningful comparability out the window:

For the purpose of this subsection, in the determination of expenditures per pupil from State and local funds, or instructional salaries per pupil from State and local funds, staff salary differentials for years of employment shall not be included in such determinations.

This means the principle cause of within-district, school finance inequity—teacher salary differences—need not be remedied.

Currently, all school districts have to do to demonstrate comparability among schools is submit a written assurance to the state that they: (1) use a district-wide salary schedule, and (2) have policies "to ensure equivalence among schools in teachers, administrators, and other staff…and in the provision of curriculum materials and instructional supplies." (Oh, and they must "keep records to document that the salary schedule and policies were, in fact, implemented." But states do such a poor job monitoring comparability that it’s unlikely those records would ever be needed.)

Thus as long as the teachers are all paid on the same scale and distributed evenly in terms of numbers, not quality, it doesn’t matter that the lowest-poverty school has 20 highly-credentialed, experienced teachers and the highest-poverty school has 20 rookie teachers. In this regulatory world, Wilson High School in Northwest Washington, DC is comparable to Anacostia High School in Southeast Washington, DC. And thus, the comparability provision has become a cruel joke.

Giving Comparability Teeth

The most robust demonstration of comparability would involve a straight-up, no-gimmick state and local teacher salary expenditure comparisons between schools—with salary differentials for years of employment included. This is what the House has proposed, and where Congress should continue to head, in its NCLB reauthorization bill.

(Side note: One obstacle to using teacher salary spending per-pupil for comparisons is that many school districts do not track real teacher spending at each school, instead only monitoring teacher allocation numbers. These local budgeting practices, which mask teacher spending disparities, would have to change.)

There will be (and already has been) intense opposition to any comparability changes from teacher’s unions and school administrators, as such changes might require renegotiating teacher collective bargaining agreements, changing seniority and transfer provisions that enable the most experienced teachers to cluster in lowest-poverty schools, or adding pay incentives to attract high-quality teachers to highest-poverty schools.

But if the federal government wants to ensure that its investment is truly enhancing the education of disadvantaged children—not making up for disparities in teacher quality—strengthening comparability is a critical first step.

10 Questions on the Bush Education Budget

Ed Policy — Tue, 05 Feb 2008 00:00:00 -0500

Ed Money Watch has some questions for the Bush administration on its fiscal year 2009 budget request for education.

K-12 EDUCATION

1) The administration proposes increasing No Child Left Behind (NCLB) Title I grants to school districts by 2.9 percent, essentially an increase matching inflation. It also proposes redirecting a greater proportion of Title I funds to high schools. Does this mean that school districts will have to cut Title I funding for K-8 schools, since districts will effectively receive the same level of funding as in the previous year? How will this affect student achievement in grades 3 through 8?

[slideshow] 2) The administration’s budget proposes shifting $100 million from the NCLB’s Title II "Improving Teacher Quality State Grants" program to a "Teacher Incentive Fund" program that supports state and local performance-based compensation initiatives and incentives for teachers to serve in challenging schools. These activities already are allowed under the large and flexible Improving Teacher Quality State Grants program. Why, when the administration is generally trying to consolidate programs and get rid of duplicative ones, does the budget slice off funding for this smaller duplicative program?

3) The newly proposed "Pell Grant for Kids" program includes a provision that scholarship recipients would be required to take an assessment in each grade and subject as required under NCLB’s Title I program. Would there be any accountability for the private schools if the test results show that students are not achieving? What would the consequences be for failure to make adequate yearly progress? If there are only a few students taking the test at a given private school, how would schools provide the public with the information required under NCLB accountability standards?

4) The budget request proposes replacing the 21st Century Learning Community Learning Centers with a new 21st Century Learning Opportunities program, transferring funding to voucher-like scholarships for extended learning activities. The administration argues that the Learning Centers were not improving academic outcomes, and that a scholarship system would be more effective, because states can identify high-quality programs for parents. But states are currently required to ensure the quality of the after-school centers they choose to fund; why would they be any better at identifying high quality choices for parents? How would the new program differ from the Title I Supplemental Educational Services provision, under which states are struggling to evaluate the quality and academic outcomes of extended learning activities?

HIGHER EDUCATION: STUDENT LOANS

5) The Federal Family Education Loan (FFEL) program and the Direct Loan program show similar per loan costs for 2008 and 2009, with the FFEL program showing a slight cost advantage for the first time. However, page 364 of the Budget Appendix notes that costs are higher for the Direct Loan program, because it holds nearly 100 percent of student loans that have defaulted (under FFEL and Direct Loans) and have been rehabilitated through consolidation.

Can per loan program costs be accurately compared when high-default risk FFEL loans are dumped into the Direct Loan program? If OMB and the Department of Education corrected cost estimates for this bias, how would the costs change? Which program would be cheaper for taxpayers in costs were controlled for borrower differences?

6) Federal funds held by state guaranty agencies used to pay loan default claims under the Federal Family Education Loan (FFEL) program nearly doubled to $1.1 billion in 2007 from $579 million in 2006. Are the federal funds held by guarantee agencies in excess of what is needed to pay default claims, and if so, would the administration recommend recalling those funds?

7) The budget proposes a change in the eligibility rules for the new Loan Forgiveness for Public Service Employees program created under the College Cost Reduction and Access Act last year. Borrowers who pursue public service careers and begin loan repayment after October 1, 2007 are eligible to have the remaining balance of their loans forgiven after 10 years. The benefit is available to Direct Loan borrowers and Federal Family Education Loan (FFEL) borrowers who refinance into direct lending.

The budget request would limit eligibility to new borrowers who take out loans after October 1, 2009. If the proposal is enacted, how many borrowers now eligible for public service loan forgiveness will lose eligibility? And what types of shifts in the loan volume does the administration foresee between direct lending and the program that the administration cites as the need for the change in eligibility rules?

8) The loans for short-term training proposal would create a new and relatively small loan program, subsidizing $362 million in loans in 2009 to help dislocated and unemployed workers obtain training. Given the administration’s overarching goal of reducing smaller and duplicative education programs, why not use existing student loan programs for this goal instead of establishing a new program administered by two agencies (the Departments of Labor and Education)?

HIGHER EDUCATION: GRANTS

9) The budget includes a $652 million cancellation of the $960 million Congress has made available for the Academic Competitiveness and SMART Grant programs, citing insufficient program participation rates. Why are participation rates not high enough to use all available funding, and does the administration recommend any action to increase participation? Also, the programs expire after the 2010-11 academic year. Does the administration have a position on whether they should be extended?

HIGHER EDUCATION: TAX BENEFITS

10) The administration is proposing a new higher education tax credit worth up to $1,000 annually on contributions to 529 college savings plans, while maintaining other overlapping higher education tax benefits. Four years ago the administration wanted to "revise and simplify" rules regarding the three largest existing higher education tax credits. Why has the administration abandoned the goal of simplification, and what steps will be taken to ensure the 529 credit does not make the interaction between the higher education tax credits more confusing?

Bonus Question: Did Senator Pell's family consent to the use of his name for a private school voucher proposal? Were they even asked?