seeing beyond silos: how state education agencies spend federal education dollars and why

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 WWW.AMERICANPROGRESS.ORG Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why By Robert Hanna June 2014

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Page 1: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 132 WWWAMERICANPROGRESSO

Seeing Beyond SilosHow State Education Agencies Spend

Federal Education Dollars and Why

By Robert Hanna June 2014

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 232

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 332

Seeing Beyond SilosHow State Education Agencies Spend

Federal Education Dollars and Why

By Robert Hanna June 2014

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 432

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 532

1 Introduction and summary

9 Why and how states work in silos

13 The federal role in state education agency siloing

17 Recommendations

19 Conclusion

23 Endnotes

Contents

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 2: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

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Seeing Beyond SilosHow State Education Agencies Spend

Federal Education Dollars and Why

By Robert Hanna June 2014

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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1 Introduction and summary

9 Why and how states work in silos

13 The federal role in state education agency siloing

17 Recommendations

19 Conclusion

23 Endnotes

Contents

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

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8 Center for American Progress | Seeing Beyond Silos

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 3: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

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Seeing Beyond SilosHow State Education Agencies Spend

Federal Education Dollars and Why

By Robert Hanna June 2014

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 532

1 Introduction and summary

9 Why and how states work in silos

13 The federal role in state education agency siloing

17 Recommendations

19 Conclusion

23 Endnotes

Contents

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

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8 Center for American Progress | Seeing Beyond Silos

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 532

1 Introduction and summary

9 Why and how states work in silos

13 The federal role in state education agency siloing

17 Recommendations

19 Conclusion

23 Endnotes

Contents

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

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8 Center for American Progress | Seeing Beyond Silos

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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1 Introduction and summary

9 Why and how states work in silos

13 The federal role in state education agency siloing

17 Recommendations

19 Conclusion

23 Endnotes

Contents

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2132

The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 6: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

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8 Center for American Progress | Seeing Beyond Silos

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 7: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

Introduction and summary

Hisorically sae deparmens o educaion or SEAs have991252or he mos

par991252been compliance-ocused organizaions ha managed ederal educaion

policy Over he pas several decades hese agencies have been educaion policy

implemenaion eniies1 oday while heir compliance responsibiliies have

remained hey are aking on more responsibiliy or educaion and academic

oucomes han ever beore subsanially increasing he scope o heir work Sae

leaders and heir saffs mus disribue ederal educaion dollars and monior he

disricsrsquo use o hese unds in accordance o regulaions se by ederal policymak-ers2 ere is nohing conroversial abou ataching srings o unding sources bu

hese differen compliance requiremens have driven many agencies o respond

in predicable ways o make compliance easier sae leaders have radiionally

separaed agency saff ino differen areas responsible or each ederal und Once

an approach has passed exernal audis hey hen have mainained he saus quo

o SEA saffsrsquo work3

o suppor his work he US Deparmen o Educaion or DOE allows saes

o se aside cerain amouns o ederal unds o cover SEA adminisraive coss4

Indeed ensions beween saes and he ederal governmen are inheren o he

enerprise o co-governance bu sae educaion leaders can poin o specific

ederal regulaions ha have a direc impac on heir work decisions and ha make

i difficul or hem o mee he demands o ederal policymakers5

rough legislaion and regulaion ederal policymakers have se numerous con-

diions or sae educaion leaders o drive manage suppor and monior school

improvemen a scale Saes receive dollars hrough a se o disinc ederal unds

ha hey mus use only or ederally allowed aciviies A firs appearance i is an

approach ha make sense paricularly when i is much easier991252or example991252ohave Elemenary and Secondary Educaion Ac or ESEA ile I saff working on

ile I aciviies serving economically disadvanaged sudens and alernaively o

have Perkins Ac saff working on Perkins Ac aciviies ha suppor career and

echnical educaion Bu moving orward wha i our approaches o improving

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

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8 Center for American Progress | Seeing Beyond Silos

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 8: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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2 Center for American Progress | Seeing Beyond Silos

oucomes or economically disadvanaged sudens require atenion o career

and echnical raining or o improved special educaion services Are he ederal

condiions opimal or helping saes mee ederal demands while a he same ime

carrying ou heir educaional mandae is repor conribues o he discussion

o hese and oher quesions relaed o he disribuion o ederal educaion unds

is paper explores saesrsquo uses o ederal educaion dollars and how ederal policy

condiions migh lead saes o use unds in he ways ha hey do which are no

always he mos producive ways Our analysis o SEA spending o ederal unds

is based on financial and saffing daa rom 11 sae deparmens o educaion

rom he fiscal year 2012ndash2013 Eigh saes in our analysis991252Arkansas Illinois

Kenucky Missouri Nebraska Norh Carolina Oklahoma and exas991252provided

saffing and conac daa ha idenified specific ederal unds and heir uses ree

saes991252Washingon Iowa and Delaware991252did no mee our requiremens or

use in his repor Iowa and Washingon did no provide daa ha we could use

o ideniy saff responsibiliies and Delaware provided inormaion on ederallyunded posiions and conracs bu did no designae which specific unds were

used Furhermore his sudy ocuses on how he eigh sudy SEAs use ederal

dollars or heir own aciviies raher han on how school disrics991252anoher

major recipien o ederal educaion suppor991252use ederal resources Our goal was

o learn more abou sae leadersrsquo use o ederal dollars o adminiser hese pro-

grams and wha implicaions ha had or how hey organized heir own agencies

In gahering he daa or his repor he Cener or American Progress sen ques-

ionnaires o sae educaion officials rom all 50 saes during he las quarer o

2013 In some cases we made his reques under he auspices o sae reedom o

inormaion laws No sae in his sudy had he inormaion we sough relaed o

sae spending o ederal unds readily available or easily accessible o he public

Specifically we asked saes o repor how much hey spen rom each ederal edu-

caion und on compensaing sae saff and exernal conracors In his repor

our analysis o SEA saffing is based on he inormaion we colleced direcly rom

hese saes unless oherwise noed (see Mehodology)

In general research on he organizaion and managemen o sae educaion

agencies is limied Our analysis however reaffirms exising research showinghe srings atached o ederal unds hinder sae leaders rom building educaion

agency capaciy Specifically we describe how saes in his sudy silo heir use

o ederal educaion unds esablishing separae offices based on which ederal

dollars und hem For example saes commonly have a special educaion office

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1332

Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1432

8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1532

Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1632

10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 9: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

ha is unded primarily hrough ederal special educaion unding hrough

he Individuals wih Disabiliies Educaion Ac or IDEA Oher analyss have

described how his pracice maters because siloing undermines comprehensive

educaion reorm by limiing collaboraion and communicaion

However no every sae in our sudy sruggled wih his challenge For insancehe pracices o he exas Educaion Agency deailed in his repor illusraes

how exas sae leadersrsquo used ederal unds more comprehensively However or

he mos par991252exas and a handul o oher examples nowihsanding991252sae

educaion agencies are hard pressed o ge he bigges bang rom heir ederal dol-

lars because o srucural consrains

Based on our findings we recommend ha ederal policymakers and sae educa-

ion leaders re-examine ederal regulaions wih an eye oward improving he

condiions in which sae agency leaders work Boh mus ensure ha sae educa-

ion leaders can ake comprehensive approaches o criical new educaion reormsraher han relying on he silos in which hey have operaed in he pas Sae

leaders mus ensure ha hey are doing everyhing wihin heir power o improve

he perormance o heir agencies hrough careul re-examinaion o ederal

regulaions Federal policymakers should provide he opimal condiions o make

his a realiy by eliminaing unnecessary and burdensome regulaions or providing

flexibiliy in areas ha do no suppor ederal educaion prioriies Specifically we

recommend he ollowing

bull Congress and he US Deparmen o Educaion should sraegically reduce

compliance and reporing requiremens or sae educaion agencies

bull DOE should highligh ederal compliance flexibiliies ha exis and ensure sae

educaion agencies will no be incenivized o use saff in ways ha oser silos

bull Sae educaion leaders should ake anoher look a heir regulaory environ-

men and find new ways o improve how hey organize heir agencies

In he effor o achieve beter oucomes or odayrsquos sudens educaion leaders and

policymakers mus achieve a new equilibrium where he condiions se by ederalpolicymakers mee he inens o ederal educaion policy isel oo ofen he hands

sae educaion leaders are ied by ederal regulaions ha preven hem rom effec-

ively spending ederal unding sources o bes o heir advanage Faced wih audis

relaed o he large volume o ederal requiremens some saes have responded by

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1732

Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 10: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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4 Center for American Progress | Seeing Beyond Silos

siloing differen ederal unds and heir associaed aciviies Ye oher sae educa-

ion agencies have ound ways around regulaory obsacles and have been able o

implemen more comprehensive and collaboraive approaches o agency work

Clearly here are lessons o be learned rom innovaive SEAs However o ge a

beter undersanding o he decisions ha odayrsquos sae educaion leaders makemore SEAs should make basic inormaion abou he use o ederal educaion dol-

lars available o he public

In many ways he success o US educaional policy depends grealy on he suc-

cess o sae educaion agencies o mee he curren demands placed on hem

i is imperaive ha he ederal governmen removes any obsacles ha under-

mine SEA perormance

How state education agencies spend federal funds

During he 2012ndash13 school year sae educaion leaders spen ederal dollars in

differen ways ye hese expendiures shared common eaures Consider he wo

larges noncompeiive unds ha saes receive rom he ederal governmen ESEA

and IDEA ESEA ile I Par A allows saes o reserve a small porion o dollars o

suppor he adminisraion o aciviies serving disadvanaged sudens in he sae6

In he special educaion services unding rom IDEA saes can reserve a porion o

heir unding o suppor sae aciviies hrough he ile I Par B secion o he ac7

Sae leaders use hese ederal unds o suppor saff ha work on monioring

reporing and compliance managemen jus as he law inends For example

Illinois uses ile I Par A dollars o suppor nine posiions in he Federal and

Sae Monioring Division and IDEA dollars o suppor eigh posiions in he

Funding and Disbursemens Division Missouri use IDEA unding o suppor saff

in he Office o Special Educaion and is Office o Daa Sysems Managemen

However Missourirsquos daa do no allow us o ideni y sae saff membersrsquo areas o

work or heir specific responsibiliies

Saes varied in how much hey spend on saff using ESEA ile I Par A moneyand hese amouns are generally proporional o how many primary and second-

ary schools were locaed in said saes In able 1 below we presen hese saisics

or he 10 saes or which we had hese daa In Nebraska or example he sae

educaion agency paid saff a oal o around $670000 dollars in he 2012ndash13

school year an amoun equivalen o abou $600 per public school8 In exas on

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1132

Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 11: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

he oher hand wih more han 8000 schools he sae agency paid saff around

$8 million dollars oal abou $900 per public school Illinois spen more han $7

million IDEA dollars o compensae saff abou $1600 per school

TABLE 1

State agency spending of federal funds

Summary statistics for state education agencies in study

State

Number

of public

schools

2011ndash12

Number

of school

districts

2011ndash12

ESEA Title I Part A

state spending

on personnel

2012ndash2013

Number of SEA

staff positions

paid at least

partially through

ESEA Title I Part A

IDEA Title I Part B

state spending

on personnel

2012ndash2013

Number

SEA staff pos

paid at le

partially thr

IDEA Title I

Fund College- and Career-Ready Students Fund Special Education - Grants to States

Arkansas 1108 289 $751616 13 $1669583 26

Illinois 4336 1075 $3340549 57 $7030890 82

Iowa 1411 361 $636931 10 $3561415 54

Kentucky 1565 194 $617982 16 $1061489 19

Missouri 2408 572 $2035000 34 $1920000 42

Nebraska 1090 288 $669930 8 $1073870 22

North Carolina 2577 236 $3428266 62 $4435578 53

Oklahoma 1774 575 $1508741 36 $1670752 25

Texas 8697 1262 $8078022 400 $8402772 269

Washington 2365 316 $203838 7 $1415963 26

Source Authorrsquos analysis based on data provided by state education agencies National Center for Education Statistics ldquoLocal Education Agency (School District) Universe Surveyrdquo 2011-12 v1

ldquoPublic ElementarySecondary School Universe Surveyrdquo 2011-12 v1a ldquoState Nonfiscal Public ElementarySecondary Education Surveyrdquo 2011-12 v 1a all available at httpncesedgovccde

Some saes have relied on ouside conracors or raining or consuling services

Missourirsquos Deparmen o Elemenary and Secondary Educaion using ESEA

ile 1 Par A unding pays more han $2 million a year o he Naional Insiue

or School Leadership991252an organizaion ha provides leadership raining9

Washingon saersquos Deparmen o Educaion pays almos $1 million annually rom

is ESEA ile I Par A unding o he BERC Group a consuling firm10 Similar o

above hese daa do no allow us o ideniy he exac naure o hese conracs

Sae leaders in sudy saes also suppor school-improvemen saff991252no only ohold schools accounable bu also o inervene when necessary For example Norh

Carolina pays or wha are ermed ldquodisric and school ransormaionrdquo coaches in

he Disric and School ransormaion division and ldquoinsrucional review coachesrdquo

on he needs assessmen eam e Arkansas Deparmen o Educaion unds six

ldquopublic school program advisorsrdquo hrough ESEA ile I Par A unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 12: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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6 Center for American Progress | Seeing Beyond Silos

Saes also use special educaion991252IDEA ile I Par B991252dollars o pay or a variey

o services someimes relying on privae parners and a oher imes relying on sae

insiuions o higher educaion For example he sae o Washingon pays abou

$600000 a year rom IDEA unds o Measured Progress Inc a company ha devel-

ops suden assessmens11 In Kenucky he sae agency pays Easern Kenucky

Universiy and Universiy o Kenucky around $500000 a year o rain inerpreersas well as or services relaed o dea blind or visually impaired sudens

Moving away rom hese wo unds we find ha saes differ in heir use o oher

ederal unding such as ile II Par A o ESEA which requires saes receiving

ESEA dollars o suppor programs ocused on improving he qualiy o eachers

or principals12 Missouri uses hese dollars o und direcor-level posiions in is

Office o College and Career Readiness Kenucky spends is ESEA ile II Par

A dollars on proessional developmen and echnical assisance hrough exernal

parners such as he New eacher Cener and he Kenucky Associaion o School

Adminisraors Illinois and Missouri have conracs wih heir insiuions ohigher educaion ha are paid or wih ESEA ile II Par A dollars suggesing ha

hose conracs are ocused on eacher qualiy bu his sudy did no collec such

programmaic inormaion Oher saes such as Washingon and exas rely on

oher organizaions such as he American Insiues or Research or eacher qualiy

improvemens Meanwhile Norh Carolina uses ESEA ile II Par A unds o sup-

por posiions responsible or educaor recruimen and developmen

rough he Perkins Ac saes have o provide programming in boh career

and echnical educaion13 In 2012ndash13 Illinois and Missouri unded posiions in

offices overseeing college- and career-readiness programs Norh Carolina unded

many posiions in career- and echnical-educaion offices and exas suppored

a range o sae saff members in inormaion echnology and ederal compliance

offices using Perkins unds

Saes also spend a grea deal o ederal money on assessing suden learning

Some o he saes in his repor have mulimillion dollar conracs wih ou-

side vendors or suden assessmen Illinois Norh Carolina and exas or

example have conracs wih NCS Pearson Inc paid in par hrough ESEA sae

assessmen grans Similarly Nebraska has assessmen conracs wih he DaaRecogniion Corporaion which suppors he developmen o heir saewide

suden assessmens14

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1732

Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 13: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

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Introduction and summary | wwwamericanprogress

ree sudy saes repor using ederal unds in a consolidaed or combined ash-

ion Likewise Missouri suppors more han 30 posiions hrough a similar ESEA

unds pool In exas he sae educaion agency pays or more han 100 posiions

using more han 10 separae ederal unding sources is paper considers he

exas example in more deail below

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1532

Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1732

Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 14: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2332

Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 15: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogress

Why and how states work in silos

Saes have used ederal unding o suppor a variey o differen ypes o posi-

ions and programming Ye all oo ofen program saff members find hem-

selves working in silos wih he aciviies o one program being separaed rom

hose o ohers raher han he ideal working siuaion where saff coordinae

heir effors across programs In he absence o silos sae saff are ree o share

inormaion across unis and provide experise hrough collaboraive eams In

conras o previous research his sudy finds ha while here are indeed silos

hey migh no nearly be as pervasive across he individual sae educaion agen-cies as oher observers sugges

Many observers have idenified siloing as a major issue or sae educaion lead-

ers and heir agencies e Cener or American Progress has repored ha some

sae educaion chies said ha heir saff did no communicae or had limied

communicaion across agency offices15 Similarly researchers a he Cener on

Innovaion and Improvemen or CII a echnical assisance provider o SEAs

ound ha sae educaion agencies silo a leas in par in order o mee he

demands o differen ederal programs argeing various suden populaions16

Mos previous research on SEAs used inerviews or surveys bu did no review

he financial records o agencies Following he approach o researchers rom he

Cener on Reinvening Public Educaion we examined he organizaion o SEAs

based on saffing and finance inormaion provided by hese agencies raher han

relying solely on inerviews17 Using his approach we ound he siloing effec o

be less pronounced

Saes in his sudy differed in he number o ederally unded posiions and mos

o he sample saes unded only a small racion o hose posiions using more

han one und For example in Illinois ou o almos 200 ederally unded posi-ions in he sae board o educaion only abou 20 posiions are suppored by he

use o muliple ederal unds

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 16: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

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10 Center for American Progress | Seeing Beyond Silos

e Illinois Sae Board o Educaion or ISBE do keep some ederal dollars

separae bu suppor monioring posiions across muliple unds (see Figure

1) For example IBSE suppors 15 posiions hrough ESEA ile I Par A in he

ile Grans Division and more han 65 posiions in he sae Office o Special

Educaion wih IDEA unds However Illinois manages und disbursemen and

compliance monioring hrough posiions unded hrough muliple sreams

In Missouri here were around 150 sae educaion agency posiions unded in

some manner by he ederal governmen Mos o Missourirsquos SEA employees

were paid hrough muliple ederal unds under a consolidaed adminisraion

approach bu ohers were unded by jus one unding sream Sae leaders in

Missouri suppor a separae Office o Special Educaion wih 30 posiions unded

wih only IDEA dollars and no oher ederal educaion unding In Missourirsquos

Office o Qualiy Schools he sae unded 20 posiions only hrough ESEA ile

I Par A and no oher ederal educaion und (see Figure 2)

Boh saes keep special educaion services mosly separae rom ESEA-relaedservices or disadvanaged or minoriy sudens is pracice is consisen across

oher saes as well Arkansas or insance unds more han 25 separae posiions

hrough IDEA and Oklahomarsquos Deparmen o Educaion suppor some 15 sepa-

rae posiions (see Figure 2)

ESEATitle I Part A

ESEATitle II Part A

Educatorlicensure

(4)

IDEATitle I Part B

Office of Special

Education(66)

Assessments(1)

PerkinsTitle I

Collegeand careerreadiness

(4)

Title grants(14)

Assessments(7)

Collegeand careerreadiness

(1)

Funding and disbursements

Federal and state monitoring

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one federal grant The horizonal arrow

indicates offices that have positions funded with multiple funds

Source Authors analysis based on staffing data from Illinois State Board of Education

FIGURE 1

Staffing arrangements in Illinois by office and federal grant

Fiscal year 2012ndash2013

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1732

Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 17: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Why and how states work in silos | wwwamericanprogresso

I is eviden rom our analysis ha some siloing occurred a hese agencies a leas

when we look a ederally unded posiions However i is worh noing ha he

daa presened here are no definiive evidence ha saes are deliberaely keeping

saff responsibiliies separaed In ac when sae educaion researchers rom he

Cener on Educaion Policy or CEP inerviewed sae officials several years ago

hey concluded ha he No Child Lef Behind Ac or NCLB acually led agen-

cies o break down silos18 According o a sae official cied in by CEP ldquoPrior o

[NCLB] he SEA [he sae educaion agency] really here was more siloed ere

were cerain pars o he agency ha probably were no seeing ha connecion

beween wha hey did and he oucome o suden achievemen And wersquove really

worked o have cross-divisional work and inegraed eams working ogeherrdquo19

Neverheless in our analysis saes consisenly separaed special educaion

managemen rom oher ederally unded programs From our sudy we could no

deermine why bu i may be because saes wan o ocus on special educaion

sudens in differen ways han radiionally disadvanaged groups o sudens o

be air wha appear o be silos on paper migh no be silos in pracice

In he absence o silos saes agency saff exchange inormaion and provide

suppor o schools on echnical assisance eams Researchers rom he CII have

idenified examples o saes where special educaion saff work closely wih

school-improvemen saff20 In Georgia or example special educaion saff shared

ESEA

Title I Part A

IDEA

Title I Part B

Office of Special

Education(31)

Office of QualitySchools(22)

Fiscal and administrative services

Office of Data Systems Management

FIGURE 2

Staffing arrangements in Arkansas Missouri

and Oklahoma by office and federal grant

Fiscal year 2012ndash2013

ESEA

Title I Part A

IDEA

Title I Part B

Federaloperations

specialeducation

(26)

ESEA

Title I Part A

Schoolsupport

improvement(7)

IDEA

Title I Part B

Specialeducation

(19)

Federalprograms

(13)

Arkansas Oklahoma

Note Numbers in parentheses are estimated numbers of distinct position titles funded through one f ederal grant except for thoseindicated as positions supported by consolidated funds () The horizonal arrow indicates offices that support some positions using either

ESEA TItle I Part A or IDEA Title I Part BSource Authors analysis based on staffing data from Arkansas Department of Education Missouri Department of Elementary andSecondary Education and Oklahoma Department of Education

Missouri

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 18: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 1832

12 Center for American Progress | Seeing Beyond Silos

daa hey colleced wih saff ha moniored school qualiy21 In Wyoming special

educaion saff are members o he saersquos echnical assisance eams22 In he CIIrsquos

survey 20 ou o 50 saes repored ha special educaion saff and sae suppor

saff ldquowere linked hrough cross-division collaboraionrdquo23

Only hree o he saes in our sudy are Race o he op or RT granees wihNorh Carolina receiving is Phase 2 unding o he program saring in he 2010ndash

11 school year24 RT is a ederal compeiive gran program or saes i pro-

moed several sae-wide reorms such as evaluaing eacher perormance using

suden es scores and implemening college- and career-ready sandards or

sudens25 In some saes RT posiions are in heir own offices Norh Carolinarsquos

Deparmen o Public Insrucion or NC DPI akes a differen approach and has

more han 100 posiions suppored hrough RT dollars Many o hose posiions

are ocused on educaor recruimen or echnical assisance And while a ew NC

DPI posiions are specifically in a RT office mos saff are in offices no specifi-

cally designaed or RT Moreover he NC DPI suppor a leas 20 ransorma-ion coaches and more han 25 insrucional coaches or schools or disrics

ese coachesrsquo aciviies likely differ based on heir porolios26

While saes shared no consisen siloing patern i is clear ha some saes exhib-

ied his phenomenon more han ohers Saff a sae educaion agencies migh

silo hemselves or any number o reasons Neverheless when sae leaders are

asked abou he managemen issues hey ace hey ofen noe how ederal regula-

ions resric heir acions and essenially incenivize hem o separae heir saff

ino differen offices or differen ederal programs27

FIGURE 3

Staffing arrangements

in Texas

Fiscal year 2012ndash2013

Information technology services

Research and analysis

Organization development

Performance reporting

Grants administration

Statewide data initiativespublic education information

managment system

Accounting

School improvement support

Curriculum

Federal and state education policy

Federal program complianceFederal fiscal monitoring

College- andcareer-readiness initiatives

Note Graphic only includes offices with more

than 15 distinct positions that are federally-fund-

ed Offices are ordered roughly by number of

district positions with the largest office at the

top The horizonal arrow indicates offices that

are funded with mutliple funds

Source Authors analysis based on staffing data

from the Texas Education Agency

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

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httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

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About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 19: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

The federal role in state

education agency siloing

Sae educaion leaders silo primarily because i is a low-risk approach o mee

ederal requiremens28 rough he Office o Managemen and Budge or OMB

he ederal governmen requires eniies receiving ederal unds o repor how

employees who are paid hrough hose unds allocae heir ime29 In paricular

sae and disrics comply when heir employees spend heir ime in very close

alignmen wih how hose unds are billed For insance a sae saff member paid

50 percen rom ESEA ile I Par A unds and 50 percen rom ile II unds

mus spli heir work ime evenly beween he wo aciviies a is o say underhis scenario hal o he employeersquos ime mus be spen doing sae aciviies

allowed by he ederal governmen ha improve he academic achievemen o

all sudens paricularly radiionally disadvanaged children and he remaining

hal o his or her ime mus be spen on allowed aciviies relaed o improving

he qualiy o eachers and principals When audiors monior sae agencies or

compliance hey mos ofen look or violaions o hese ypes o ime reporing

requiremens Undersandably when saes are aced wih his siuaion hey pre-

er he saes approach991252namely o have each employee work on only one specific

ederal program30 When sae educaion agencies ail o comply wih ederal rules

hey jeopardize heir uure unding or cerain communiies o sudens such as

hose sudens who receive special educaion services

However employees rouinely log heir ime across many proessional secors

So wha makes such reporing so burdensome or sae educaion agencies I is

no he reporing isel ha presens challenges Raher he issue has o do wih

ederal compliance When saes are ound o be noncomplian991252ou o line wih

ederal regulaions991252hey migh be placed in he posiion o having o pay back

he conesed dollars or risk geting negaive press coverage or audi findings31

ereore siloing occurs or good reasons even i he oucomes are less han idealSae or disric leaders devoe an inordinae amoun o energy and resources

o aspecs ha are mos commonly he ocus o agency audis in order o avoid

noncompliance bu his approach can ofen run conrary o wha ederal educa-

ion policymakers wan hem o achieve32 Moreover as CII researchers sugges

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

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22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 20: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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14 Center for American Progress | Seeing Beyond Silos

he compliance requiremens ha lead o siloing occur due o well-inenioned

purposes namely ha ederal policymakers wan o ensure cerain populaions o

sudens are given special ocus and addiional services33 o make sure his hap-

pens ederal policymakers se reporing and compliance requiremens or each

program and enlis audiors o monior saesrsquo use o ederal dollars or approved

services in each program wih an eye oward he inended argeed populaions

Overall educaion chies and analyss agree ha siloing undermines comprehen-

sive approaches o school reorm e Educaion Alliance a Brown Universiy

has repored sae siloing limied communicaion and collaboraion across unis

In heir repor hey cied one sae educaion agency official who suggesed ha

siloing hindered his agency rom having a ldquosysemic ocusrdquo or ldquoopimizing he sub-

parsrdquo34 According o he CII siloing also prioriizes compliance over perormance

managemen o programs35 I improvemen o low-perorming schools is now a

primary responsibiliy o sae agencies hen a ocus on meeing requiremens does

no leave much room or sae leaders o manage aciviies or improvemen

In 2012 in conjuncion wih governmen efficiency iniiaives by he Obama

adminisraion he US Deparmen o Educaion offered saes and disrics flex-

ibiliy wih respec o ederal ime reporing requiremens36 e firs year saes

and disrics could ake advanage o hese flexibiliies would have been he 2012ndash

13 school year According o he new guidance omas Skelly he DOErsquos acing

chie financial officer allows saes o repor employee work ime using alernaive

sysems37 Under previous guidance sae employees had o repor a monhly

ldquopersonnel aciviy reporrdquo38 Now saes can repor ime hrough an alernaive

sysem on a semiannual basis as long as he repors mee DOE requiremens

One example would be a long-erm regular schedule o aciviies ha he employee

ollows wih fideliy39 e DOE does no repor which saes have aken advanage

o his alernaive arrangemen so i is no clear how many saes use his approach

Neverheless while his policy reduces reporing burdens i does no direcly

address he audiing issues saes encouner and hereore leaves room or saes o

coninue o preer siloed arrangemens In a leter omas Skelly acknowledges

ha ldquoi is possible hellip or muliple programs o have he same cos objeciverdquo40 In

oher words here is indeed overlap across wha ederal unds allow ereoresae leaders should be able o use muliple unds o suppor agency saff who direc

comprehensive sae aciviies o suppor low-perorming schools

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 21: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2132

The federal role in state e ducation agenc y s iloing | wwwamericanprogresso

Even wih his policy in place many saes in our sudy ollow some sor o siloed

arrangemen during he 2012ndash13 school year bu no all o hem exas sood

ou as he excepion

How and why Texas stands out

e exas Educaion Agency or EA paid or more han 200 posiions across a

range o uncions rom research o inormaion echnology o school improve-

men wih muliple ederal unds ese posiions are a large porion o he more

han 700 oal posiions a he agency which oversees one o he larges educaion

sysems in he naion41 EA sae leaders paid or nearly 100 o hose posiions

wih money rom more han 10 separae educaion unds

e muliunded posiions ranged across offices and uncions Sae program direc-

ors wih ederal program oversigh such as he direcor or ederal and sae educa-ion policy received pars o heir salaries hrough ESEA ile I Par A IDEA ile

I Par B Perkins Ac program and oher ederal unding programs e same was

rue or oher posiions For example exas paid a projec manager in he educaion

daa sysems office sae direcors in he curriculum office and programmers in he

inormaion echnology services office all wih muliple ederal unds

e agency also suppored many privae conracors using muliple unds e

EA spen almos $2 million on inormaion echnology across many ederal

unds o privae conracors such as Caapul Sysems991252a Microsof I consuling

firm42991252or Soal echnologies also a echnology consuling firm43 e unds used

included ESEA IDEA and he Perkins Ac program e agency also paid $1

million o he global securiy company Norhrup Grumman or daa processing

and compuer renal44

Overall he EA used ederal unding essenially as a general pool o money

used o suppor all ederally aligned aciviies exasrsquo example suggess ha oher

sae agencies could do more and coninue o comply wih ederal regulaions

under he curren law

One example o how his general pool is used o suppor comprehensive work

is exasrsquo work on disric perormance managemen In paricular he EArsquos

Perormance Reporing Division has direcors programmers and program spe-

cialiss who all work across several ederal unding sreams Moreover he EArsquos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2232

16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2332

Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2532

Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 22: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2232

16 Center for American Progress | Seeing Beyond Silos

Division o Program Monioring and Inervenions includes ederally unded

specialiss and analyss e firs division991252perormance reporing991252manages

monioring or academic perormance and he later holds disrics accounable

or meeing ederal and sae educaion requiremens45 ese saffing arrange-

mens sugges ha here is a collaboraive approach o disric perormance

managemen

is sor o inormaion ha links sae agency saffing wih unding sreams is

generally no available o he public hrough sae websies so i is no possible

o explore wheher his pracice is unique o exas or i i occurs in oher saes

no included in our sudy Ye i is clear ha he EA example suggess ha saes

could do much more in he curren ederal sysem However his does no imply

ha he ederal condiions in place oday are he bes possible o ensure saes

mee curren ederal educaion goals

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2332

Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2432

18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2532

Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 23: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2332

Recommendations | wwwamericanprogresso

Recommendations

Conrary o previous research saes in our sudy have no appeared o exhibi he

same level o siloing behavior as were eviden o analyss in he pas Perhaps our

approach offers a new perspecive o agency finance and saffing given is level o

deail I his is a circumsance many sae educaion agencies ace oday hen our

goal is o offer encouragemen o ederal policymakers ha will oser even more

collaboraion wihin sae educaion agencies Sill or hose sae educaion lead-

ers who coninue o organize along hese old lines ou o habi and are no aware

ha oher approaches would sill comply wih ederal rules and o ederal policy-

makers we srongly sugges ha here is room or improvemen in ederal educa-ion regulaions and offer he ollowing recommendaions

1 Congress and the US Department of Education should strategically reduce

compliance and reporting requirements for state education agencies In an

era o sagnan or reduced unding and increased demand ederal policymakers

should ensure criical reorms coninue bu also reduce nonessenial compli-

ance requiremens Oher sae educaion agency analyss have made similar

recommendaions bu did no offer specific suggesions as o which require-

mens are essenial46 Forunaely he DOErsquos Office o Inspecor General or

OIG has aken he lead on providing recommendaions47 For example he

OIG suggess ha Congress and DOE make SEA monioring easier by seting

amouns or disric program adminisraion more uniormly across ederal

unds48 Some unds currenly do no have specific limis while ohers do One

could imagine a similar approach or sae educaion agencies I is no clear

which requiremens should say and which should go bu i should ulimaely

be deermined hrough he legislaive and regulaory process

e Cener or American Progress and is parners have advocaed or various

reorms o ESEA ile I wih an eye oward reducing he burdens aced bysae educaion leaders and heir saffs49 For example he ederal governmen

migh consider improving he ldquosupplemen-no-supplanrdquo es Currenly saes

and disrics have o monior heir ESEA ile I Par A spending on a cos-

by-cos basis requiring every separae aciviy o be moniored50 Under he

curren law saes mus ensure heir disrics do no use ederal unds o replace

programs ha were previously offered hrough sae and local unds Insead

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2432

18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2532

Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 24: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2432

18 Center for American Progress | Seeing Beyond Silos

ederal educaion regulaion expers Melissa Junge and Sheara Krvaric recom-

mend he ldquosupplemen-no-supplanrdquo es show ha sae and local spending is

ile I-neural meaning he unding is disribued o ile I and oher schools

in he same ways51 Such a modificaion could significanly reduce sae moni-

oring requiremens and disric reporing requiremens

Policymakers migh achieve enhancemens such as hese in he nex reauhori-

zaion process o he ESEA or hey migh ake he orm o waivers52

2 The US Department of Education should highlight federal compliance flex-

ibilities that exist and ensure that state education agencies are not incentiv-

ized to place staff in silos DOE should reissue is 2012 guidance regarding

flexibiliies or sae employee ime reporing In a leter o sae educaion

chies omas Skelly he DOErsquos acing chie financial officer allowed saes

o repor employee work ime less requenly and use alernaive repors ha

mee deparmen requiremens53 As oher analyss have suggesed issuing newguidance migh acually conuse sae leaders hereore DOE should simply

emphasize ha hese flexibiliies sill apply54

While he DOErsquos flexibiliy policy would reduce burdensome reporing require-

mens i would no necessarily push sae leaders o make new decisions regard-

ing financial allocaions o make sure his policy works in pracice ederal

policymakers should ake anoher look a he audiing process One quesion

o consider is his Are saes being ound o be noncomplian even hough hey

are advancing key educaion prioriies We could no deermine he answer o

ha quesion rom our research or his paper alhough a complemenary CAP

repor suggess ha sae leaders repor ha ederal regulaions make i difficul

o mee ederal educaion goals55 a simply should no be he case

3 State education leaders should take another look at their regulatory envi-

ronment and find new ways to improve how they organize their agencies

e exas Educaion Agency example suggess ha here are oher ways o

approach he use o ederal educaion unds wihin he curren policy environ-

men For example sae leaders could assign saff members o monior he

same aciviies across muliple educaion unds and compensae hem accord-ingly hrough muliple educaion grans One place or SEAs o sar migh be

o orm eams across several divisions o work on a shared problem

Whaever approach ederal policymakers and sae educaion leaders ake i

should include a resh look a he regulaions and requiremens ha govern

saesrsquo educaional work

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2532

Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 25: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2532

Conclusions | wwwamericanprogresso

Conclusion

In heir pursui o ederal goals sae educaion leaders find hemselves resriced

by ederal regulaions ha preven hem rom meeing new demands e ederal

governmen provides financial suppor or he work required o adminiser ederal

programs bu i also ses condiions ha migh run couner o having saes mee

each undrsquos objecives Some saes have responded by unneling differen ederal

unds ino discree agency silos bu oher saes such as exas have shown ha

agencies can comply even when hey ake a more comprehensive approach Many

saes oday may already deploy more collaboraive approaches o saffing andoher saes should be able o ollow his model as well o ge a beter undersand-

ing abou he decisions o odayrsquos sae educaion leaders more SEAs should make

basic inormaion abou he use o ederal educaion dollars available o he public

Methodology

We requesed financial and saffing inormaion direcly rom sae educaion

agency officials We developed and disribued a daa quesionnaire seeking our

differen ses o inormaion in consulaion wih sae officials in wo saes In he

firs secion we asked or basic inormaion abou how many employees he sae

educaion agency employed Second we asked sae officials o provide inorma-

ion abou he oal amoun o ederal dollars used o compensae saff employees

in fiscal year 2013 by he ederal unding source991252or example ESEA ile II

Par A or improving eacher qualiy

Nex we asked saes o repor he posiion ile and organizaional uni o every

employee compensaed ully or parially hrough ederal educaion unds in fis-

cal year 2013 and indicae which specific unds saes used o compensae hesesaff members We did no reques employeesrsquo names For example a sae migh

repor ha hey paid a projec manager in he inormaion echnology office using

ESEA ile I Par A and IDEA ile I Par B unds Finally we asked sae leaders

o repor all conracs o more han $50000 ha saes paid wih ederal educaion

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 26: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2632

20 Center for American Progress | Seeing Beyond Silos

unds We asked or inormaion abou which unds were used and which spend-

ing caegory he sae charged991252or example suden assessmen Here we did ask

or he name o he conracor For example a sae migh repor ha a universiy

was paid $130000 or proessional developmen or eachers using ESEA ile II

Par A dollars

We analyzed saffing daa a he posiion level A sae migh have lised eigh posi-

ion iles and one office under ESEA ile III a ederal und supporing English

language learners For example in he school improvemen office he sae migh

use ESEA ile III o pay or a direcor an associae direcor five program man-

agers and wo adminisraive assisans is direcor migh also be lised in he

same office991252school improvemen991252under anoher und such as ESEA ile I

Par A In cases like his where we could reasonably ollow posiions across unds

we would repor ha he direcor o school improvemen was unded hrough

muliple ederal unds

Correction June 19 2014 Tis report incorrectly identified one of the types of fund-

ing streams used to support career and technical education and to pay state program

directors and private contractors in exas Te correct funding stream is the Perkins Act

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 27: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2732

About the author amp Acknowledgments | wwwamericanprogresso

About the author

Rober Hanna is a Senior Educaion Policy Analys a he Cener or American

Progress Prior o joining he Cener he worked on school research wih Dr

Ronald F Ferguson a he Harvard Kennedy School o Governmen Previously

Hanna augh mah a Boson College High School in Massachusets Hanna hasa maser o ars degree in he social sciences rom he Universiy o Chicago He

received his bachelorrsquos degree rom Harvard Universiy

Acknowledgments

e Cener or American Progress hanks he Eli and Edyhe Broad Foundaion

or heir ongoing suppor o educaion programs and o his repor e views and

opinions expressed in his repor are hose o he auhor and do no reflec he

posiion o he oundaion is repor is par o a larger muliyear projec on gov-ernance conduced in parnership wih he omas B Fordham Insiue which

evaluaes he governance arrangemens o our naionrsquos K-12 educaion sysem and

how hey may be improved

e auhor would also like o hank he ollowing sae educaion agency saff

members in several saes who devoed a grea deal o ime o ulfill our reques

Mathew Pakos rom Massachusets Deparmen o Elemenary and Secondary

Educaion and rish Boland rom he Colorado Deparmen o Educaion or

heir eedback on early versions o he sae finance quesionnaire used or his

paper Melissa Lazariacuten and iffany Miller a American Progress or heir com-

mens on drafs o his paper and Cynhia Brown or he iniial research design

and helped wih inviing sae educaion chies and heir agencies o paricipae in

our sudy Parick Murphy Melissa Junge and Sheara Krvaric also provided crii-

cal insighs ino sae educaion finance sae agency saffing and ederal educaion

regulaions all o which inormed his paper

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 28: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2832

22 Center for American Progress | Seeing Beyond Silos

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 29: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 2932

Endnotes | wwwamericanprogresso

Endnotes

1 Thomas B Timar ldquoThe Institutional Role of State Educa-tion Departments A H istorical Perspectiverdquo American Journal of Education105 (3) (1997) 231ndash260

2 US Department of Education ldquo Elementary and Sec-ondary Education Actrdquo available at httpwwwedgov

esea (last accessed May 2014) An act to reauthorize theIndividuals with Disabilities Act and for other purposes Public Law 108-446 108th Cong (December 3 2004)available at httpideaedgovdownloadstatutehtml

3 Melissa Junge and Sheara Krvaric ldquoThe ComplianceCulture in Educationrdquo Education Week October 242011 available at httpblogsedweekorgedweekrick_hess_straight_up201110the_compliance_cul-ture_in_educationhtml

4 Ibid

5 Cynthia G Brown and others ldquoState Education Agen-cies as Agents of Change What It Will Take for theStates to Step Up on Education Reformrdquo (WashingtonCenter for American Progress 2011) available athttpwwwamericanprogressorgissueseducationreport201107279901state-education-agencies-as-

agents-of-change

6 US Department of Education ldquoImproving BasicPrograms Operating by Local Education Agencies ( TitleI Part A)rdquo available at httpwww2edgovprogramstitleipartaindexhtml (last accessed May 2014)

7 An act to reauthorize the Individuals with Disabilities Actand for other purposes Public Law 108-446

8 The per-school ratios do not reflect the workload orfocus of agency staff but there is no clearly superiormeasure for comparing state staff spending acrossstates including this one

9 National Institute for School Leadership ldquoWhat WeDordquo available at httpwwwnislnetwhat-we-do (lastaccessed May 2014)

10 The BERC Group ldquoAboutrdquo available at httpwwwbercgroupcomabouthtml(last accessed May 2014)

11 Measured Progress ldquoAbout Usrdquo available at httpwwwmeasuredprogressorgabout-us (last accessed May2014)

12 US Department of Education ldquoTitle II - Preparing Training and Recruiting High Quality Teachers andPrincipalsrdquo available at httpwww2edgovpolicyelseclegesea02pg20html (last accessed May 2014)

13 US Department of Education ldquoCarl D Perkins Careerand Technical Education Act of 2006rdquo available athttpwww2edgovpolicysectechlegperkinsindexhtmlexp=1 (last accessed May 2014)

14 Memo from John Moon to Roger Breed May 7 2012available at httpwwweducationnegovStateBoard

Support_materials2012MaySB_05_12_pr_DRC_con-tractpdf

15 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

16 Thomas Kerins Carole Perlman and Sam ReddingldquoCoherence in Statewide Systems of Support rdquo (LincolnIL Academic Development Institute 2009) available athttpwwwadiorgaboutdownloadsCoherencein-theStatewideSystemofSupportpdf

17 Patrick J Murphy and Monica Ouijdani ldquoState Capac-ity for School Improvement A First Look at AgencyResourcesrdquo (Seattle Center on Reinventing PublicEducation 2011) available at httpwwwcrpeorgsitesdefaultfilespub_states_statecap_Aug11_0pdf

18 Angela Minnici and Deanna D Hill ldquoNCLB Year 5Educational Architects Do State Education Agen-cies Have the Tools Necessary to Implement NCLBrdquo(Washington Center on Education Policy 2007)available at httpwwwcep-dcorgdisplayDocumentcfmDocumentID=313

19 Ibid p 8

20 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

21 Ibid Georgia Department of Education ldquoGAPSS

Analysisrdquo available at httpwwwgadoeorgschool-improvementpagesGAPSSaspx (last accessed May2014)

22 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

23 Ibid Figure 23 p 29

24 Letter from Joseph C Conaty to Gov Beverly PurdueSeptember 24 2010 available at httpwww2edgovprogramsracetothetopphase2-awardsnorth-carolinapdf

25 US Department of Education Race to the Top ProgramExecutive Summary (2009) available at httpwww2edgovprogramsracetothetopexecutive-summarypdf

26 The State of North Carolina ldquoRace To The Top Applica-

tionrdquo (2010) p 198 available at httpwwwdpistatencusdocsrtttstateinitialturning-aroundpdf

27 Brown and others ldquoState Education Agencies as Agentsof Changerdquo

28 Melissa Junge and Sheara Krvaric ldquoFederal complianceworks against education policy goalsrdquo (WashingtonAmerican Enterprise Institute 2011) available at httpwwwaeiorgarticleeducationk-12federal-compli-ance-works-against-education-policy-goals

29 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments (The WhiteHouse 2004) available at http wwwwhitehousegovombcirculars_a087_2004

30 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo

31 Ibid

32 Ibid

33 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 30: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3032

24 Center for American Progress | Seeing Beyond Silos

34 Chris Unger and others ldquoHow Can State EducationAgencies Support District I mprovement A Conversa-tion Amongst Educational Leaders Researchers andPolicy Actorsrdquo (Providence RI The Education Allianceat Brown University 2008) available at httpwwwbrowneduacademicseducation-alliancesitesbrowneduacademicseducation-alliancefilespublicationsSymposiumpdf

35 Kerins Perlman and Redding ldquoCoherence in StatewideSystems of Supportrdquo

36 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012 available at httpwww2edgovpolicyfundguidgposbultime-and-effort-reportinghtml

37 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

38 Office of Management of Budget Cost Principles forState Local and Indian Tribal Governments

39 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

40 Letter from Thomas P Skelly to chief state school officerSeptember 7 2012

41 Texas has the second largest student enrollment inthe United States after California National Center for

Education Statistics Table 20340 Enrollment in publicelementary and secondary schools by level grade andstate or jurisdiction Fall 2011 (US Department of Educa-tion 2011) available at httpncesedgovprogramsdigestd13tablesdt13_20340asp

42 Catapult Systems ldquoThe Microsoft Consulting Com-panyrdquo available at httpwwwcatapultsystemscomcompanylinkid=mgm (last accessed May 2014)

43 Soal Technologies ldquoAbout Usrdquo available at httpso-altechcomabout-us (last accessed May 2014)

44 Authorrsquos analysis of data collected from the TexasEducation Agency

45 Texas Education Agency ldquoPerformance Reporting Divi-sionrdquo available at httpwwwteastatetxusperfreport (last accessed May 2014)

46 Junge and Krvaric ldquoFederal compliance works againsteducation policy goalsrdquo Patrick Murphy ldquoHelp WantedFlexibility for Inn ovative State Education Agenciesrdquo(Washington Center for American Progress 2014)

47 Office of Inspector General An OIG Perspective onImproving Accountability and Integrity in ESEA ProgramsPerspective Paper (US Department of Education 2007)

available at httpwww2edgovaboutofficeslistoigauditreportsfy2008s09h0007pdf

48 Ibid

49 Raegen T Miller Frederick M Hess and Cynthia GBrown ldquoReauthorization of the Elementary and Second-ary Education Act O ffers a New Chance to ImproveEducationrdquo (Washington Center for American Progressand American Enterprise Institute 2012) available athttpwwwamericanprogressorgwp-contentup-loadsissues201203pdftitleI_recspdf

50 Melissa Junge and Sheara Krvaric ldquoHow the Supple-ment-Not-Supplant Requirement Can Work Against thePolicy Goals of Title Irdquo (Washington Center for AmericanProgress and American Enterprise Institute 2012)available at httpwwwaeiorgfiles20120306-how-the-supplementnotsupplant-requirement-can-work-

against-the-policy-goals-of-title-i_111823556546pdf

51 Ibid

52 Similar recommendations have been made by PatrickMurphy in the report Murphy ldquoHelp Wantedrdquo

53 Letter from Thomas P Skelly to chief state school of-ficers September 7 2012

54 Murphy ldquoHelp Wantedrdquo

55 Murphy ldquoHelp Wantedrdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

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The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

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8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3132

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo

Page 32: Seeing Beyond Silos: How State Education Agencies Spend Federal Education Dollars and Why

8122019 Seeing Beyond Silos How State Education Agencies Spend Federal Education Dollars and Why

httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 3232

The Center for American Progress is a nonpartisan research and educational institute

dedicated to promoting a strong just and free America that ensures opportunity

for all We believe that Americans are bound together by a common commitment to

these values and we aspire to ensure that our national policies reflect these values

We work to find progressive and pragmatic solutions to significant domestic and

international problems and develop policy proposals that foster a government that

is ldquoof the people by the people and for the peoplerdquo