Post on 03-Jun-2018
8122019 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
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
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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
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
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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
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
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
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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
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
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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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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
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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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
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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
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
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
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
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
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
8122019 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
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
httpslidepdfcomreaderfullseeing-beyond-silos-how-state-education-agencies-spend-federal-education-dollars 732
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
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
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
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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
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
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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
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
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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
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
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
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
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
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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
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
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
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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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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
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
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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
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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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
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
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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
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
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
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
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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
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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
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
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
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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
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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
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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
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
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
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
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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
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
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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
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
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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
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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
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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
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
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
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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
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
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
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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
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
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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
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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
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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
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
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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
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
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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
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
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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
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
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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
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
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
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
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
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
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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
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
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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
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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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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
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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
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
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
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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
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
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
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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
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
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
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
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
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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
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
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
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
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
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
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
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
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
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
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
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
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
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
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