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When the Music Stops: The Cost of NCLB's Data Demands

By Joyce Riha Linik

Like players in a game of musical chairs, state education agencies across the country are wondering if ample federal support will be there as they go about implementing the significant demands of the No Child Left Behind (NCLB) Act. And it's looking more and more like many states may be left standing on their own when federal allocations run out.

"The data requirements of NCLB are enormous," says Gail Pauley, Washington state director of Title I and Title V programs. Washington puts a mammoth amount of federally mandated data online so that they are accessible to families, teachers, administrators, and policymakers. State report cards are placed online and data are broken out by school district and individual school. Data reflecting state testing scores and adequate yearly progress (AYP) standings are also put online, as well as results from the state's consolidated program reviews.

Behind all these data are added costs, among them research and development for additional standards-based assessments, professional development to train teachers and administrators how to analyze and interpret the data to guide instruction, and training to help many teachers and paraprofessionals attain newly required credentials—not to mention the additional equipment, software, and sheer number of staff hours required to record and report the data being collected. As a result, states across the country are examining the costs of NCLB's data demands and whether federal funds will cover the added expenses.

Washington is one of 11 states currently collaborating with the nonpartisan Council of Chief State School Officers (CCSSO) on a project to better understand the cost of NCLB to individual states.

"About a year ago, states began to grapple with the issue of calculating the cost of complying with the NCLB law," says Sue Merritt, CCSSO cost consortium manager. "State legislatures were asking for this information from the SEAs [state education agencies]. State agencies were struggling with the basics of what to include in those costs and what process to use in calculating costs. In addition, states were working with limited budgets to hire a company to do the work of answering those questions.

"CCSSO staff members began to hear from states on this issue and a decision was made to offer states a way to pool their funds to purchase the services of a company to develop the process for calculating costs and offer technical assistance to make the calculations. To that end, CCSSO sent its member states an invitation to join a consortium of other states to work together for one year on this issue."

Priscilla Richardson, Washington state director for consolidated federal programs, says, "I think the reality is, for any of us who are participating, we do want to know how close or how far NCLB is from being fully funded to implement as it needs to be implemented in our state according to our state plan approved by the Department of Education."

But the purpose of Washington's participation in the study isn't to criticize. "We want to understand the requirements of the law and implementation costs in order to make informed decisions," says Pauley.

The consortium offered states the opportunity to conduct a better quality study than they could afford on their own. "[Participating states] wanted to get together and find a good, commonsense way to do it," says Richardson. "I think they looked around to see, OK, what's already been done. This is a hard thing to do and it's very time-consuming, and we don't want to have to reinvent the wheel each and every time. Plus, they'd seen the responses to some of the cost studies that other states had done and they didn't want to be doing something that was full of holes, as it were, and that would be just as easily dismissed because it didn't have a supportable, defensible foundation, a defensive methodology."

The consortium selected Augenblick, Palaich, and Associates (APA), a Denver-based financial consulting company, through a bidding process based on their proposal. APA caught the eye of consortium members for the work they had done on a similar study in Hawaii. "It looked like something that was scalable and could be adapted for other states," says Richardson, so APA was put to work developing templates for each state that would identify the necessary reforms for implementation of the federal law and to quantify the costs associated with those changes.

"They helped us develop a template that has a set of components that are common pretty much across all the states at both the state and district levels because they reflect the required components in NCLB, like having high standards, having an assessment system, and all that," explains Richardson, "and it also goes into all the individual title programs."

Then, the templates were individualized for each state. "Every state template is different because their approved tasks and activities, as specified in their state work plans, are different," notes Merritt.

"And then, what each state has done is that we have spent a lot of time reflecting on all of the activities—related to NCLB—carried out since 2002 and then ongoing activities through 2008," adds Richardson, "and we're costing out all those activities."

Important to note, though, is that "this is not an adequacy study," says Merritt. "We were not looking at whether NCLB as a law is adequate. We were not looking at whether a state plan was adequate."

And the study certainly wouldn't attempt to gauge, say, "how many kids won't be proficient in the year 2010 and how much will it cost to do the interventions that will be necessary, and where will their inadequacies lie," notes Richardson. "You just get into places where it's very hard to do any kind of defensible projections. So it was a decision among all the states that were involved in the project to not do an adequacy study."

"This is a study on the marginal costs of NCLB," Richardson explains, meaning "how much more is it costing administratively and operationally at both the state and district levels?"

If anything, the study attempts to be a bit conservative in terms of measuring added costs. "One of the things we did in a very deliberate way," says Merritt, was to examine only those costs associated with new activities and tasks to meet NCLB requirements. "If you had already spent money on research and development for a project that is now required under NCLB, but you did it before the law was put into place, that money—the funding for that project—could not be included in your costs for the study."

Connecticut is the first state involved in the CCSSO study to issue a report. "The cost estimates in this report are sobering," writes Betty Sternberg, Connecticut Commissioner of Education. "Through FY08, there is a burden of approximately $41.6 million on the State of Connecticut to meet the requirements of the No Child Left Behind Act." And, Sternberg points out, "these are state-level costs only; a report on local costs will be published in April 2005." Two key areas are largely responsible for Connecticut's shortfall: additional assessments and providing technical assistance and support for local education agency and schools in need of improvement.

While Washington state officials are waiting for the results of the study on their state costs before making any judgments, it's clear many are expecting similar results when their report is issued in June.

For starters, like Connecticut, Washington state will need to research, develop, and administer several new grade-level exams, one of the key areas of cost overage in the Connecticut study. Under NCLB, "a standards-based assessment has to be given in grades three through eight, plus one in high school," says Richardson. "Well, right now, we only assess—give the WASL—in grades four, seven, and 10. So we have to develop WASL-type, standards-based assessments for grades three, five, six, and eight. And they [the U.S. Department of Education] have given us a certain amount of money for assessment development, but it's our projection that the money for those assessments will not be adequate to cover the costs of administering those tests."

If Washington's study does yield results similar to Connecticut's, and other states follow with similar discoveries, perhaps there will be strength in numbers.

"If a group of states all use the same methodology and all come out with similar findings, it really does help in terms of making the point," says Richardson. "Because we'll have that many state delegations getting the information in Congress and that many governors and that many state legislatures and so forth. So, we'll see ...".