Hawaii Costing-Out 2004, NCLB

The scope of this study was narrow. It estimated the marginal cost of administering those provisions of ESEA that are new with the enactment of NCLB in 2002. The study did not examine: (1) the cost of any state or federal requirement that was in existence prior to 2002; (2) the cost of providing students with the opportunity to meet state student learning standards, as adequacy cost studies do; (3) the cost of helping 100 percent of students to reach “proficiency,” as NCLB requires; or (4) whether the state has the revenue to pay for the costs estimated.


Study Title: “Estimating the New, Marginal Costs of No Child Left Behind in Hawaii ”


Date Completed: July 2004


Calculated Marginal Administrative Costs: Marginal cost of NCLB administration: $56.1 million for 2003-04 ($31.5 million in ongoing costs and $24.6 million in developmental, or one-time, costs).

Projected future ongoing marginal costs:

$29.9 million for 2004-05

$36.2 million for 2005-06

$45.8 million for 2006-07

$47.6 million for 2007-08

note: does not include costs of adding science assessments, as required

The estimated per pupil cost for new NCLB administration is an additional 2%-3.5% of per student spending in Hawaii.


Special Features of the Study: Largest estimated expenditures for 2003-04: (1) Developmental costs – $14.6 million for data management associated with NCLB. (2) Ongoing Costs- $9.0 million for federal title programs (e.g. Title I and Title II).

The cost of Technical Assistance to those schools “in need of improvement” (INOI) is projected to rise, as almost every school is predicted to be in INOI status by 2007-08. For 2003-04, the ongoing cost for providing technical assistance to schools in this status is estimated at $7.0 million.

Future ongoing costs were estimated relative to 2003-04 based on expected proportional changes or on information that would drive costs in the future. In the case of services to be provided in the future, costs were driven by the number of schools or students. APA made these estimates, as the study notes that employees of the DOE were uncomfortable making these projections.


Methodology: APA developed a new “activity-based” five-part approach to define and assess the marginal administrative costs of NCLB implementation. The researchers used as a basis Hawaii ‘s federally-approved NCLB plan, which outlines the measures to be taken to comply administratively with the federal law. The cost study steps were as follows:

Specify aspects of NCLB that the study covers : The researchers decided that they would assess the implementation of NCLB’s testing, reporting, data collection, school improvement actions and “corrective actions” requirements, plus any new ESEA requirements, such as those related to educator qualifications.

Specify the actions Hawaii is taking to implement those aspects of the law : this step includes the employment of staff, the purchase of supplies, and the management of contracts. Here, the researchers relied on staff at the DOE to estimate the resources needed.

Distinguish the costs associated with these actions from the costs of those actions that would have been undertaken to implement Hawaii ‘s own accountability system.

Specify the years in which those actions are taking place.

Specify the real cost of those actions: this step includes cost of salaries, benefits and overhead.

Because the researchers sought to focus on new NCLB administrative costs only, they relied on employees of the Hawaii Department of Education (DOE) whose work focused on NCLB and educators who worked in the state’s “complex areas,” which are analogous to school districts in other states. Hawaii is unique among states b/c it has one statewide school district, so the state DOE sometimes acts in the role of the school districts in other states.

The researchers describe their “activity-based” approach as one that identifies the specific steps that must be taken to accomplish a task required by NCLB. For example, in order to comply with the requirement to provide Supplemental Educational Services (SES) to certain students, the DOE must match contractors to eligible students and identify qualified SES providers, by reviewing potential providers’ proposals.


Implementation: None


Recommendations: None


Prepared for: The Hawaii Education Policy Center (HEPC) at the University of Hawaii


Prepared by: Augenblick, Palaich, and Associates