Detailed Information on the
Impact Aid Construction Assessment

Report actual data on the two newly developed annual performance measures and show progress meeting the targets.

Demonstrate improved efficiencies in making competitive awards in a more timely manner.

As data become available for the long-term and annual performance measures, refine measures so that they better reflect the goals of the program.

Improve oversight practices by adding site visits to the current monitoring system.

Improve competitive grant application process by requiring more rigorous budget information as well as an environmental impact study.

Measure: The average number of days elapsed between the initial Impact Aid discretionary construction award and the LEAs' awarding of contracts.

Explanation:A baseline was supposed to be set in FY 2006 but is not applicable because the discretionary grant program was not funded in FY 2006 or FY 2007. The long-term target remains 250 days but the annual targets will need to be reset once a baseline is established. Funding for the discretionary grant program was reestablished in FY 2008 and awards will be made in FY 2009. Data will not be available until FY 2010 at the earliest.

Measure: The percentage of schools in LEAs receiving Impact Aid Construction funds that report the overall condition of their school buildings is adequate.

Explanation:The annual targets were originally set at the long-term goal of 70 percent, but were adjusted in FY 2006 to increase each year until reaching the long-term goal in FY 2010.

Measure: The percentage of all Impact Aid formula construction payments made by July 31.

Explanation:This new efficiency measure is intended to track programmatic efficiency by reducing the amount of time it takes to process the formula construction grant payments under Section 8007(a) of the Impact Aid Program. The target for 2007 is to make at least 30 percent of payments by July 31st and to increase the percentage of payments made by July 31st in each subsequent year an additional 20 percent. The long-term goal is to make all of the formula payments in the summer so LEAs can begin construction projects before the school year begins. This measure was revised in 2007 because using dates as targets did not give as good of an indication of improvement in the efficiency of the program as using percentages.

Is the program purpose clear?

Explanation: The program authorizes formula (8007(a)) and competitive (8007(b)) grants to support school construction in local educational agencies (LEAs) that educate federally connected students or have federally owned land. Grants are used to repair, renovate, or alter a public elementary or secondary school facility to ensure the health, safety, and well being of students and school personnel. More generally, the Impact Aid program provides financial assistance to school districts affected by Federal activities through a variety of programs, including Basic Support Payments, Payments for Children with Disabilities, Facilities Maintenance, Construction, and Payments for Federal Property. See www.ed.gov/about/offices/list/oese/impactaid/index.html for more information.

Evidence: Section 8001(1) and (5) and Section 8007(b)(2) of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act of 2001.

Does the program address a specific and existing problem, interest, or need?

Explanation: Impact Aid grants address the loss in tax revenue an LEA faces due to the presence of Federal property. Even if no federally connected children reside on such land, the loss reduces the level of educational resources for all children. Those school districts that are eligible for Section 8007 formula and discretionary construction grants are the most seriously affected by the absence of taxable local property.

Evidence: Almost all school districts use property taxes to finance public elementary and secondary school expenditures. Impact Aid provides financial relief to school districts that are burdened by tax revenue loss since Federal property cannot be taxed.

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: There are no other Federal construction grant programs available for public school districts. Some States provide support for school construction, in varying ways, but they do not provide funding specifically to federally impacted LEAs or in a manner that takes the impact of Federal activity into consideration. Most school construction is financed through local tax revenue, often through the use of bonds. Almost all Section 8007 eligible school districts have a very limited local tax base to support bonding for construction. Some of these school districts have begun to turn to committing portions of their Section 8003 payments to guarantee bonds (that is, borrowing against payments made to LEAs through the Basic Supports Payment formula) to secure capital for school facilities projects, but many have concluded that they cannot do so. In evaluating applications for Section 8007(b) discretionary construction grants, the Department reviews other resources available to the LEA that may be used for Construction purposes, and such funds are taken into account in determining award amounts. Although the Department of Defense (DOD) and Bureau of Indian Affairs (BIA) provide construction funding for schools under their jurisdiction, those authorities do not duplicate Section 8007, because they do not support schools operated by LEAs.

Evidence: Once a Section 8007(b) discretionary construction program application has been scored and ranked, the Department reviews audited financial data for the most recent fiscal year to determine whether funds are available to the school district to undertake the project without Federal assistance. The Department also requests information from the applicants about other resources available, such as State funding for the project and funding from Indian tribes. These funds are generally assessed as available to partially fund the project, and the Federal funds are reduced to the amount needed to complete the project. In some instances, projects are not funded because the Department determines that the school district has sufficient funds on hand to complete the project.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: To date, the only grants that have been awarded are Emergency Grants, which must be used to repair, renovate, or alter a public elementary or secondary school facility to ensure the health, safety, and well being of students and school personnel. The other type of grants authorized are Modernization grants, which may be used to extend a public elementary or secondary school facility to ease overcrowding and provide facilities that support a contemporary educational program. The law specifies that applications for Emergency grants receive first and second priority in the competition, while applications for Modernization grants are treated as third and fourth priorities. The eligibility requirements for Emergency Grants are extremely tight and guarantee targeting to the LEAs with the greatest construction needs. In order to be eligible, LEAs must have no practical capacity to issue bonds (less than $25 million in taxable property), have minimal capacity to issue bonds (between $25 and $50 million in taxable property) and have already issued bonds at or above 75 percent of their bonding capacity, or be eligible for Basic Support Payments for Heavily Impacted LEAs [8003(b)(2)], and have a school facility emergency that poses a health or safety hazard.

Evidence: Section 8007(b)(3) of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act of 2001.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The program is well targeted, because grants go primarily to extremely poor school districts that have a major need for facilities imporvements and little ability to finance facilities projects on their own. More specifically, of the 175 districts that receive formula funds, 50% are Indian districts that have high levels of poverty and little or no tax base. Those same districts receive 100% of the competitive grants. For FY 2003, only 47% of these Indian LEAs reported that the overall condition of their school facilties was adequate. The remaining districts that receive formula grants are militray districts that also have very limited ability to raise local revenues for construction. 100% of the funding for this program is, thus, well targeted and directly addresses the program's purpose.

Evidence: Section 8007(b)(2) and (3) of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act of 2001. Grant award data and project abstracts. Impact Aid program performance measures.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The Department has two long-term performance measures that focus on outcomes and outputs that promote results and accountability. The outcome measure is the percentage of schools in LEAs receiving Impact Aid Construction funds that report that the overall condition of their school buildings is adequate. The baseline was set in 2001 at 44 percent of schools reporting adequate conditions. The long-term goal is for 70 percent of schools to report that the condition of their school bulidings is adequate. The past two years have seen a steady improvement from the baseline to 54 percent in 2004. The Department has also developed a new long-term output measure for 2006. The measure is the average number of days elapsed between the initial Impact Aid discretionary Construction award and LEA's awarding of contracts. The long-term goal is to reach an average of less than 150 days. A baseline of 219 days has been established for the 2002 awards. The Department plans to review data for 2003 and have a second data point in place by fall of 2005. The program purpose is to provide grants that are used to repair, renovate, or alter a public elementary or secondary school facility to ensure the health, safety, and well being of students and school personnel. The sole outcome measure directly addresses the purpose while the output measure supports the purpose by measuring the speed in which LEAs can start emergency repairs. The program has sound justification for not having an additional outcome measure since the existing one captures the purpose of the program and the output mesaure gauges the effectiveness of the program's operations in achieving outcomes on a timely basis.

Evidence: Data will come from program office files, Grant Application and Payment System (GAPS), and Basic Support Payment applications.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The current long-term target for the first measure is an increase to 70 percent of LEAs receiving 8007 funds reporting that their school buildings are in adequate condition. Given that the baseline in 2001 was 44 percent, this is an ambitous target and one that the Department hopes to reach by 2012. The program has set a long-term target of 150 days or less for the new long-term measure (days elapsed between the initial Impact Aid discretionary award and the LEA's awarding of contracts). The baseline for this measure is 219 days, based on the data from the 2002 awards, the first year of the discretionary grants program. 2003 awards were made in September 2004. 2004 awards were announced in March so a second data point will be available later in the year when all contracts are awarded.

Evidence: Targets and timeframes have been entered into the Department's Program Performance Management Database (PPMD) based on baseline data gathered from program office files, Grant Application and Payment System (GAPS), and Basic Support Payment applications.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The long-term goal is for at least 70 percent of the LEAs to report that their schools are in adequate condition. The Impact Aid program office collects data through the 8003 application process. 8003 applicants that also receive Construction grants report on the overall condition of their school buildings and assess whether they are adequate or not. The program has two new annual performance measures that measure the efficiency in which formula and discretionary Construction payments are made. Making payments earlier makes it possible for Construction projects to begin in the summer and make the necessary improvements before the school year begins. Both of these efficiency measures support the long-term goal of improved overall conditions of school buildings.

Evidence: Efficiency data will come from the program office files and Grant Application and Payment System (GAPS). Data from LEAs for FY 2001-FY 2004 have been collected in the Basic Support Payment Applications and will continue to be collected annually.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The baseline for the existing measure was set at the level reported with the 2001 applications, 44 percent of LEAs reporting that their schools were in adequate condition. The long-term target is to reach 70 percent. The annual targets for 2006 and 2007 are 58 percent and 61 percent respectively. Baselines have been established for two new annual measures as well. The first new measure, the average number of days elapsed between the initial Impact Aid discretionary construction awards and the LEAs' awarding of contracts, is set with a baseline of 219 days for 2002. The annual targets begin in 2006 at 200 days and will decrease by 10 each year until reaching the long-term goal of 150. The annual targets are ambitous given that only 5 of the 20 LEAs in 2002 were able to award contracts within 150 days. The second new measure, the percentage of initial Section 8007(a) formula grants awarded in the second quarter of the fiscal year of the appropriation, is set with a baseline of 0. To date, awards have never been made by the end of the second quarter. The annual targets have been set for 2007 at 60 percent with a long-term goal of 90 percent.

Evidence: Data for the annual measures will come from program office files and the Department's Grants Application and Payment System (GAPS). Data from LEAs have been collected in the Basic Support Payment Applications for FY 2001-FY 2004 and will continue to be collected annually.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: LEAs and their project contractors for the construction awards are focused on correcting the most serious problems in the school facilities, so that all schools will eventually be safe and productive learning environments. Grantees submit copies of their contracts and the final certification that the work has been completed satisfactorily. Only one grantee from among the first slate of awards (FY 2002 awards) did not submit the certification on time. Program staff worked with the LEA to get it in and extend the liquidation period so that the applicant could receive the final 10% of its grant.

Evidence: Section 8003 applications. Section 8007(b) application narratives. Project contracts.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: No independent evaluations are available for this program at this time. However, the Department has recently developed and began implementing a strategy for evaluating its small and medium-sized programs.

Evidence:  

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Although the Administration has requested level funding rather than a level tied to achievement of specific goals, the program can show that for every $25 million dollars allocated, ED can fix 15-20 schools. ED has satisfied the second part of the question in that the Department's budget submissions show the full cost of the program (including S & E).

Evidence: Congressional Budget Justifications.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The program office has made improvements in its business processes to speed up the grant cycle, such as reducing the time for eligibility screening, and collecting audited financial reports earlier in the review process so that the office does not have to wait for those to be submitted. These types of process improvements have helped get on an award schedule that benefits the grantees. The Department has developed and is pursuing a strategy for the evaluation of its small and medium size programs. Finally, the Department has developed and is implementing additional performance measures for this program.

Evidence: Awards are now made in the spring of the second year of availability rather than the following fall. This has allowed schools to make necessary repairs and renovations a year earlier than they were previously able.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: Grantees provide annual performance data on the condition of their school buildings through their Impact Aid Basic Support Payments application.

Evidence: The information collected with the Basic Support Payment applications includes (on Table 10) all financial activity in construction-related funds or accounts and how LEAs are using funds for construction purposes, rather than for current expenditures. On Table 10, LEAs that receive Section 8007 grants must also report on the overall condition of school facilities, using a five-step scale from "Excellent" to "Replace."

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Grantees are held accountable for cost, schedule and performance results. In their applications, they provide a budget and outline the repairs that are to be made. Field readers, with expertise in managing school facilities or State school construction programs, assess the cost schedules and make adjustments if they are too high or not sufficient for the work required. Once awards are announced, 10% of each grant is released for preliminary work. The grantee must submit signed contracts for the project before the next 80% of the award is made available. The Department reviews the contracts for consistency with the project scope and cost. The final 10% of the award is released only after the grantee certifies to the satisfactory completion of the project. ED managers are held accountable for meeting the discretionary grant schedule entered in GAPS. Impact Aid program managers are also held accountable via the Education Department Performance Appraisal System (EDPAS) to support the operation of section 8007(b) by managing the receipt of applications, developing regulations and application materials, screening applications, conducting the field reader process, and/or completing the grant slate and award process.

Evidence: Grant files; EDPAS agreements

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Funds for the Construction program must be obligated by the Department within two years of appropriation. Thus far, all funds have been obligated in the required timeframe. Two competitions, for FY 2002/3 and FY 2003/4 funds, were conducted in 2004 and early 2005 in an effort to shorten the grant cycle so that awards could be made earlier in the two years of availability. The most recent awards, for FY 2004/5 funds, were made in mid-March to facilitate their use during the summer construction season. For the discretionary awards, the final payments are not made until the Department receives a written contract with assurances about the completion of the work as intended in the original application. For formula grants, grantees report on their expenditures for all construction-related funds and accounts in Table 10 of their section 8003 applications.

Evidence: Grant files

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The Impact Aid discretionary construction program is a recent authority, and competitive procedures were developed and refined in the past three years. With each competition, the Department identifies and implements improved procedures for this program so that awards are made as efficiently as possible. Less than $20,000 is spent annually for field reader costs, and the competition is managed with less than two FTE. In addition, the Department has developed and is implementing two performance measures that measure the efficiency of program operations.

Evidence: Impact Aid Program procedures.

Does the program collaborate and coordinate effectively with related programs?

Explanation: There are no other Federal construction grant programs available for public school districts. The Department shares information about the program with the States in which the applicant LEAs are located.

Evidence:  

Does the program use strong financial management practices?

Explanation: Recent audits have identified no deficiencies in the financial management of this program.

Evidence: The Impact Aid program has received a clean audit for two consecutive years. To respond to a finding of inadequate segregation of duties, the Impact Aid Program Director formally reviewed with staff the proper procedures for ensuring the review and approval of each payment transaction by multiple staff members. The program also made several enhancements to the Impact Aid System (IAS) so that each action in the system would require approval by two different users.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: Material internal deficiencies have not been identified for this program for the past three years. The Impact Aid Program managers have taken steps to ensure that they have a management system in place that effectively prevents problems. For example, to respond to finding of inadequate segregation of duties, the Impact Aid Program Director formally reviewed with staff the proper procedures for ensuring the review and approval of each payment transaction by multiple staff members. The program also made several enhancements to the Impact Aid system (IAS) so that each action in the system would require approval by two different users.

Evidence: The program has taken steps to correct earlier management deficiencies and has a two-step approval process to process and monitor payments.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Not Applicable; see 3.CO2.

Evidence:  

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: Not Applicable; see 3.CO3.

Evidence:  

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: While the pool of funded applicants has so far been limited to districts that receive Basic Support Payments and have minimal or no capacity to issue bonds for school construction, all eligible applicants are encouraged to apply. Applications are reviewed by external readers with expertise in the field, and the program provides outreach and technical assistance to the applicants.

Evidence: Panels of expert readers review the applications in the highest priority group (as determined by the statute) with limited or no capacity as well as first-priority applications that were not funded the previous year. Emergency repair applications are scored based on (1) need for project, (2) urgency, (3) effects of Federal presence, and (4) ability to pay. Staff also review financial audits to determine the availability of other funds for the proposed projects.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The program tracks the progress of grantees through a monitoring system that includes review of project contracts, telephone monitoring, and tracking the disbursement of awards. Meetings with grantees that attend Impact Aid Association conferences are held to obtain progress reports on projects.

Evidence: Grant files; program records.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: The Impact Aid Program collects data through Table 10 of the 8003 application. LEAs that receive Construction grants report on the overall condition of their school buildings and assess whether they are adequate or not. These data are reported to the public in the aggregate through the Department's performance and accountability report. The data are also presented to school districts that attend the meetings of the National Association of Federally Impacted Schools and the National Council of Impacted Schools.

Evidence: ED Performance and Accountability Report

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Data measuring performance on one of the current measures show improvement. Since 2002, an increasing percentage of schools that receive Construction funds have reported that the overall condition of their school buldings is adequate.

Evidence: PPMD, ED Performance and Accountability Report

Does the program (including program partners) achieve its annual performance goals?

Explanation: The program is not yet achieving its performance objective, but data for the long-term performance measure show improvement. Annual performance measures have been developed this year and results are not yet available.

Evidence: ED Performance and Accountability Report

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The Impact Aid discretionary construction program is a recent authority, and competitive procedures were developed and refined in the past three years. With each competition, the Department identifies and implements improved procedures for this program so that discretionary awards are made as quickly and efficiently as possible. Less than $20,000 is spent annually for field reader costs and the competition is managed with less tha two FTE. A new efficiency measure has also been developed to track the efficiency in making 8007(a) formula grant awards.

Evidence: Impact Aid Program procedures and grant files

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: There are no comparable programs at the federal, state, or local government level.

Evidence:  

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: No evaluations have been conducted under the current program.

Evidence: