Foster Care: Education Could Help States Improve Educational Stability for Youth in Foster Care

Roughly 270,000 school-aged youth were in foster care at the end of fiscal year 2017. Youth in foster care may change schools frequently, which can negatively affect their academic achievement. ESSA, enacted in 2015, reauthorized the Elementary and Secondary Education Act of 1965 and included provisions to improve educational stability for youth in foster care. These included requiring state educational agencies to ensure youth placed into foster care stay in their current school, unless it is not in their best interest to do so.

GAO was asked to review implementation of these provisions. This report examines (1) the challenges SEAs and selected school districts face implementing the ESSA educational stability provisions for youth in foster care, and (2) how Education provides technical assistance and monitors state implementation efforts. GAO surveyed SEA foster care points of contact in the 50 states, District of Columbia, and Puerto Rico and all but one state responded. In addition to interviewing federal officials, GAO interviewed selected state and local educational and child welfare agency officials, and held discussion groups with foster youth and parents, in three states selected by number of youth in foster care, among other factors. GAO also held discussion groups with officials from 14 SEAs and 5 state child welfare agencies, and reviewed relevant federal laws, regulations, guidance, and technical assistance.

State educational agencies (SEAs) reported several challenges in implementing the provisions in the Every Student Succeeds Act (ESSA) related to educational stability for youth in foster care. In their responses to GAO's national survey, SEAs reported challenges, including high turnover among local educational and child welfare agency officials, and with identifying and arranging transportation to schools for students (see figure). Turnover of local staff can result in the loss of knowledge and experience needed to implement the provisions, according to SEA and local officials we interviewed. Regarding transportation, ESSA requires school districts to work with child welfare agencies to provide and fund transportation so that youth in foster care can remain in their current school when it is in their best interest. Six school district and child welfare agency officials we interviewed indicated that funding was a concern and some noted that transporting youth to their current school can result in extensive costs.

The Department of Education (Education) provided technical assistance in the form of written guidance, webinars, and in-person meetings to help states implement the ESSA educational stability provisions. Education officials said they also plan to monitor state implementation of the provisions. Most SEA officials reported in GAO's survey that they would like additional assistance and more opportunities to interact with other state officials. Education plans to convene a community of practice for several states in which participants will meet regularly for several months, and is exploring other technical assistance efforts. To share information about implementing the ESSA educational stability provisions, Education maintains an email address list of SEA foster care points of contact. GAO found that the list was inaccurate and not regularly updated. Education updated the list in late summer 2019 and plans to do so quarterly. Education also provides information online, but the information is scattered across different web pages. Twenty-two SEA officials reported on GAO's survey that a clearinghouse of information would be extremely helpful. Federal standards for internal control require agencies to externally communicate necessary information in a manner that enables them to achieve their objectives. Without a dedicated web page about implementing the provisions, states may not receive the assistance they need to improve educational stability for youth in foster care.

GAO recommends that Education develop an online clearinghouse of resources. Education agreed with GAO's recommendation.

Roughly 270,000 school-aged youth were living in foster care at the end  of fiscal year 2017. Youth in foster care experience much higher levels of  residential instability than their peers, and it is not uncommon for a  student to change schools when changing living placements. Studies  from two states, Colorado and California, showed that approximately 9  percent of youth in foster care in those states attended at least three  schools in one school year. We previously reported that student mobility  has a negative effect on students’ academic achievement. Specifically, we cited research that found that students who change schools more  frequently than other students tended to have lower scores on  standardized reading and math tests and drop out of school at higher  rates than their less mobile peers.

The Fostering Connections to Success and Increasing Adoptions Act of  2008 (Fostering Connections Act) aimed to improve educational stability  for youth in foster care by requiring, among other things, that state child  welfare agencies participating in the federal foster care program  coordinate with local educational agencies (LEAs) to ensure that youth in  foster care remain in the school in which they are enrolled at the time of  each placement (also referred to in this report as the current school or  school of origin), if it is in the best interest of the child. The Every Student  Succeeds Act (ESSA), which reauthorized the Elementary and Secondary  Education Act of 1965 (ESEA), included similar requirements for state  educational agencies (SEAs) participating in Title I, Part A of the ESEA to  generally maintain such children in their school of origin. ESSA also  established requirements for participating LEAs to collaborate with child  welfare agencies to develop and implement written procedures governing  how transportation to the youth’s school of origin will be provided,  arranged, and funded, if it is in the youth’s best interest to stay there. If it  is not in the youth’s best interest to remain in their school of origin, the  youth must immediately be enrolled in a new school, even if the youth is  unable to produce records normally required for enrollment. In addition,  under the amendments made by ESSA, each SEA is required to  designate a point of contact for foster care agencies. The U.S.

Department of Education’s (Education) Office of School Support and  Accountability oversees the implementation of Title I Part A, including the  ESSA educational stability provisions, while the Children’s Bureau within  the Department of Health and Human Services’ (HHS) Administration for  Children and Families oversees implementation of the federal foster care  program, including the provisions added by the Fostering Connections  Act.

You asked us to review the implementation of ESSA provisions related to  the educational stability of youth in foster care, including collaboration  between educational and child welfare agencies and any challenges  these agencies may encounter. This report examines (1) the challenges  states and selected local educational agencies face implementing the  requirements of ESSA related to educational stability for youth in foster  care, and (2) how Education provides technical assistance and monitors  states and localities to ensure compliance with these requirements,  including collaborating with HHS.

To address these objectives, we conducted a survey of SEA foster care  points of contact from the 50 states, the District of Columbia, and Puerto  Rico (referred to as “states” in this report). All but one state responded,  for an overall response rate of 98 percent (51 respondents). The survey  included questions about the practices states employed to implement the  ESSA educational stability provisions, challenges they faced, and their  views of federal technical assistance and guidance. We also conducted  site visits to Arizona, Georgia, and Ohio to obtain information on how  some SEAs, school districts, and child welfare agencies are implementing  these provisions. We selected these three states based on a mix of  factors, including the type of child welfare agency (state- or county-  administered) and whether the number of children in foster care  exceeded the national average. We also sought diversity in location;  variety in types of school districts; and percentage of students attending  school in urban, rural, or suburban districts. We selected three school  districts to visit in each state—an urban, rural, and suburban district— where we met with the school district officials responsible for  implementing the ESSA educational stability provisions and their primary  child welfare agency counterpart. We conducted three discussion  groups—two with SEA officials and one with state child welfare agency  officials—that focused on the educational stability provisions in ESSA. In  total, these groups included representatives from 14 SEAs and five state  child welfare agencies. During our site visits, we also held two discussion  groups with foster parents and three with current or former youth in foster  care to gain their perspectives on educational stability. We reviewed  selected provisions of ESSA pertaining to the educational stability of  youth in foster care, relevant federal guidance, webinars, and other  documents. Finally, we interviewed officials from Education and HHS.  For further information on our scope and methodology, see appendix I.

We conducted this performance audit from June 2018 to September 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe the  evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

ESSA Provisions Related to the Educational Stability of Youth in Foster Care

Enacted in December 2015, ESSA’s amendments to Title I, Part A (Title I)  of the ESEA included a number of requirements for SEAs and school  districts to ensure the educational stability of children in foster care. For  the purposes of this report, we refer to these requirements collectively as  the “ESSA educational stability provisions.”

Specifically, SEAs are required to describe in their Title I state plans the  steps they will take to ensure collaboration with the state child welfare  agency to ensure the educational stability of children in foster care,  including assurances that:

Such children enroll or remain in their school of origin, unless a  determination is made that it is not in the child’s best interest to attend  the school of origin. This decision shall be based on all factors relating  to the child’s best interest, including consideration of the  appropriateness of the current educational setting and the proximity to  the school in which the child is enrolled at the time of placement.

When a determination is made that it is not in a child’s best interest to  remain in the school of origin, the child is immediately enrolled in a  new school, even if the child is unable to produce records normally  required for enrollment.

The enrolling school shall immediately contact the school last  attended by the child to obtain relevant academic and other records.

The SEA will designate an employee to serve as a point of contact for  child welfare agencies and to oversee implementation of the above  provisions.

LEAs are required to provide in their Title I LEA plans assurances that  they will collaborate with the state or local child welfare agency to: designate a point of contact, if the corresponding child welfare agency  notifies the LEA in writing that the child welfare agency has  designated a point of contact for the LEA; and develop and implement clear written procedures governing how  transportation to maintain children in foster care in their school of  origin when in their best interest will be provided, arranged, and  funded for the duration of the time in foster care.

The ESSA requirements described above were generally required to be  implemented by December 10, 2016. In addition, SEAs and school  districts are required to publicly report on the academic achievement and  graduation rates of youth in foster care on their annual report cards.

States and localities also have some flexibility in implementing the ESSA  educational stability provisions. For example, ESSA does not prescribe a  specific process for determining whether it is in a child’s best interest to  remain in their school of origin. In making this determination, state and  local agencies have flexibility in determining which factors should be  considered when evaluating the appropriateness of a child’s current  educational setting, as well as any additional factors that pertain to a  child’s best interest. Similarly, school districts and child welfare agencies  generally determine the transportation procedures to use, provided they  meet the minimum statutory requirements. In addition, SEAs may choose  various approaches to help LEAs implement the ESSA educational  stability provisions. For example, SEAs may decide to independently, or  with their state child welfare agency, issue policies or guidance,  disseminate question and answer documents, or hold informational  meetings and webinars.

Federal Technical Assistance and Oversight

Education and HHS collaborated to provide states with joint non- regulatory guidance specific to the ESSA educational stability  provisions. In addition to this written guidance, Education provides  technical assistance to states, such as through the State Support  Network, one of its technical assistance providers. Each state also has  a point of contact at Education for questions, according to Education  officials. Education’s Office of School Support and Accountability  oversees state implementation of Title I, Part A of the ESEA, including the  amendments made by ESSA. Education’s oversight of SEAs includes  reviewing state Title I plans that describe how states will follow a variety  of federal requirements outlined in Title I, and periodic reviews of how  each state is implementing Title I. These reviews occur every few years.  HHS’s Children’s Bureau oversees state child welfare agencies’  implementation of Title IV-E, including the provisions in the Fostering  Connections Act, and also provides related technical assistance.

State and Local Officials Reported Several Challenges Related to Implementing the ESSA Educational Stability Provisions

State and local officials reported facing several challenges related to  implementing the ESSA educational stability provisions. Specifically,  officials reported challenges with (1) turnover among local child welfare  and educational agency staff, (2) obtaining school district input during the  process for determining whether it is in a youth’s best interest to remain in  their school of origin (referred to as best interest determinations), (3)  providing and funding transportation, (4) ensuring accurate identification  of youth in foster care, and (5) monitoring how school districts implement  these provisions. In addition, while we did not ask on our survey about the  requirement to immediately enroll youth in a new school if it is determined  that remaining in the school of origin is not in their best interest, or about  the requirement for the enrolling school to immediately contact the last  school attended to obtain relevant records, education and child welfare  officials we interviewed said they experienced challenges with immediate  enrollment and records transfer for special populations of youth.

Turnover among Local Child Welfare and Educational Agency Staff  Turnover of local educational and child welfare agency officials was  reported as a significant challenge that affects how many states and  localities implement the ESSA educational stability provisions, according  to our survey and interviews. Specifically, in our survey, 43 of 51 SEAs  reported turnover of local child welfare agency points of contact as at  least somewhat challenging. A similar number of respondents (39)  reported facing challenges with turnover of school district points of  contact (see fig. 1). During our discussion group, state child welfare  agency officials highlighted turnover of local child welfare agency and  school district staff as one of the most significant challenges their states  face in ensuring educational stability for youth in foster care.

In addition to turnover itself being a challenge, several other challenges  reported by SEAs are related to staff turnover, according to officials we  spoke with from four state and local educational and child welfare  agencies. Specifically:

Thirty-two SEA survey respondents identified maintaining an accurate  list of school district foster care points of contact for their state as  challenging, and officials from four state and local educational and  child welfare agencies we spoke with stated turnover makes it difficult  to keep these lists updated. One SEA point of contact said that when  she sends emails to school district points of contact, she receives  numerous responses each time from school district staff saying they  are no longer the point of contact. Officials we interviewed at one  school district noted that they tried to identify a new point of contact at  another school district, but the list on the state website had not been  updated.

Thirty-eight SEAs reported on our survey that ensuring that school  district points of contact are aware of their responsibilities is a  challenge. Eight state and local educational and child welfare agency  officials we interviewed echoed this observation and cited staff  turnover as leading to a lack of awareness of responsibilities or  protocols related to the ESSA educational stability provisions.

Local staff being unaware of their responsibilities under ESSA can  lead to conflicts, according to officials from two state and three local  agencies we interviewed, and resolving conflicts between school  districts and local child welfare agencies was a challenge reported by  three-quarters (38) of SEA survey respondents. For example, officials  at one local child welfare agency said they encountered school district  officials who did not believe a youth in foster care could attend their  current school, since their foster parent lived outside the school  district. To resolve the conflict, the school district point of contact  discussed the provisions with the school officials.

To alleviate challenges related to turnover, SEA points of contact we  surveyed and interviewed explained that they regularly provide  information to local school district and child welfare agency officials on the  ESSA educational stability provisions. To inform and remind local officials  about the provisions, a few of these officials said they send emails to  school district points of contact or provide training on the provisions at  orientation for new staff at child welfare agencies. In all three states we  visited, the SEAs and/or state child welfare agencies said they held joint  presentations for both school districts and local child welfare agencies,  and SEA officials in Georgia said they are considering holding regional  collaborative meetings every four to six months. In addition, most SEAs  reported on our survey that they work with their state child welfare  agencies to provide or develop assistance, guidance, and sample  documents or templates to facilitate implementation of the ESSA  educational stability provisions at the local level. (See tables 1 and 2 in  appendix II for more information on this assistance.)

School District Input for Best Interest Determinations  On our survey, 34 of 50 SEAs reported that ensuring school districts  participate in best interest determinations is a challenge (see fig. 2). Two  of five state child welfare agency officials in our discussion group also  described challenges related to the lack of collaboration between child  welfare agencies and schools on best interest determinations. While  ESSA does not prescribe who should be involved in the best interest  determination, the joint federal guidance encourages state and local child  welfare and educational agencies, including school districts, to develop a  process that involves all relevant parties. School district involvement,  however, depends on child welfare agencies informing them when a child  enters foster care or changes homes.

Officials we interviewed at several child welfare agencies indicated they  may not include school districts or schools in these determinations due to  time constraints. Child welfare officials explained that removing a child  from a home and placing them into foster care is a chaotic time and many  steps need to be taken to quickly provide the child with a safe  environment. During this time, caseworkers may lack the capacity to  collaborate with school districts or schools. Child welfare agency officials  at two local offices we visited explained that they prioritize a child’s health  and safety when placing a child in a new foster home and that they place  a greater focus on these issues than on educational stability.

Some child welfare agency officials we spoke with said they do not  always need school district input to make a best interest determination.  For example, officials at two local child welfare agencies said that in some  cases, the commute to a child’s current school may be so long that  remaining there is clearly not in a child’s best interest. Officials from one  state and two local child welfare agencies told us they assume it is in the  best interest of the child to remain at their current school. Officials from  the state child welfare agency said they do not believe they need to  consult with school districts to make that decision. Officials at another  local child welfare agency said it would not be helpful to collaborate with  school districts on the best interest determination, since the child welfare  officials do not believe where the child attends school is the highest  priority. However, youth we spoke with in our discussion groups told us  that changing schools can create several challenges (see text box).

Officials from other state and local child welfare agencies told us they  recognize the need to involve school districts and are taking steps to try  to include them in best interest determinations. For example, one state  child welfare agency we visited includes a line for the school district point  of contact’s signature on the state’s best interest determination form; however, we heard from officials at a local child welfare agency that the  school district point of contact may not be involved in making the best  interest determination, and the form may not be consistently used.  Officials at a local child welfare agency told us that they hold best interest  determination meetings with the school district by phone because these  meetings are faster to schedule than in-person meetings. Rather than  speaking with school district staff, officials from four local child welfare  agencies said they try to contact school staff that may be close to a child,  such as a counselor or teacher, but officials from three of these agencies  said they may not do so in every case.

Thirty-seven of 50 SEAs reported on our survey that assisting school  districts with identifying or arranging transportation is at least somewhat  challenging (see fig. 3).

To help school districts and local child welfare agencies identify  transportation options, SEAs in two states we visited provide guidance or  other documents to these agencies that describe potential transportation  options. School district and local child welfare agency officials we spoke  with reported using different approaches to transport youth, including  having foster parents, school district or child welfare staff, or the youth  drive to school; rerouting buses; hiring a taxi or other private  transportation service; or using public transportation. Sometimes they  reported combining these methods to transport youth to their current  school. However, eight school district and local child welfare officials  noted difficulties with their options, including limited options in rural areas  and lack of appropriate transportation for younger youth and those with  behavioral issues. For example, an Arizona local child welfare official  explained that while they can use taxis to transport youth, they are not  approved for use for children age 6 and younger. Foster parents and  youth we spoke with shared challenges they have experienced with  transportation to the school of origin (see text box).

Experiences of Selected Foster Parents and Youth with Transportation to School  of Origin  Multiple foster parents in two states we visited shared that they were told by child welfare  case workers that the foster parent(s) would have to transport children in their care to  school for those children to remain in their current school. They told us that sometimes  they could not drive the child due to distance or the needs of other youth in their care,  and the child transferred to a new school.  We also heard that other modes of transportation may be unreliable or cause difficulties  for a child’s schedule. For example:

One child in foster care in Arizona told us that she missed a week of school because  the taxi provided by the child welfare agency failed to pick her up.  A child in a foster care group home in Ohio said that despite being placed in a  school which was in the same school district as her school of origin, her commute  was long—she needed to take two public buses—and she sometimes missed  dinner.

On our survey, 30 of 50 SEAs reported that helping school districts  determine how to fund the additional transportation costsdefined in the  joint federal guidance as the difference between what a school district  would otherwise spend transporting a student to their assigned school  and the cost of transporting a child in foster care to their school of origin  is also challenging. Among these 30 SEAs, 12 noted it was very or  extremely challenging. Six school district and child welfare agency  officials we interviewed also indicated that funding was a concern and  some noted that transporting youth to their school of origin can result in  extensive additional costs (see text box).

Examples of Transportation Costs to Maintain Youth in Foster Care in Their  School of Origin

Over a school year, officials from a local child welfare agency said it spent  $155,000 to transport students in one school district.  According to officials at one school district, to transport one student, the school  district had to hire a van at an estimated cost of up to $30,000 per year.  In one month, another school district reported paying over $4,000 to transport  five students.

School district and child welfare officials said that they can rely on  multiple funding streams—local, state, and/or federal—to cover these  additional costs. Districts and local child welfare agencies reported that  they sometimes split these costs, depending on their state’s policies. (See  fig. 9 in appendix II for state-specific cost-sharing requirements reported  in our survey.) For example, in Arizona, one agency transports the child  to school and the other transports the child home and each pays for the  cost of their one-way trip. To assist localities with funding additional  transportation costs, nine SEAs said their state provides funding that  partially or fully covers these costs. While educational and child welfare  agencies may use federal funding through Title I or Title IV-E for the  additional transportation costs, some SEA, school district, and child  welfare agency officials we interviewed noted that they do not use these  funds. Officials at a few school districts said they use Title I funding for  other needs, while some child welfare agency officials explained their  agency does not use Title IV-E funds because they did not have state  “matching” funding, did not understand how to use the funds to reimburse  schools for their costs, or had some youth who are not Title IV-E  eligible.

Ensuring Accurate Identification of Youth in Foster Care  Thirty-two SEA survey respondents reported that ensuring school districts  can accurately identify youth in foster care is at least somewhat  challenging (see fig. 4). School district officials we spoke with expressed  similar concerns. Officials we interviewed in nine of 10 districts stated  they are not consistently aware of which students in their district are in  foster care, and seven explained that there is no systematic way for  school districts to be notified when a child enters or leaves care. Similarly,  officials in four local child welfare agencies said they have no systematic  way to inform schools when youth in foster care leave care or when their  status in foster care changes. Officials from two school districts also  stated their data systems have no way to indicate that a student is in  foster care, so even if the child welfare agency notifies them of a youth’s  status, they may not easily track the information.

Officials from two school districts said not knowing the status of youth in  foster care in their district impedes their ability to effectively implement the  ESSA educational stability provisions. For example, one district official  stated they would probably be transporting more youth to their school of  origin if they knew which students were in foster care. In addition, two  school district officials said that if they do not know which students are in  foster care, they cannot provide additional supports that may be available  to these youth, such as tutoring, financial assistance, or mental health  services. The ability of school districts to accurately identify youth in foster  care can also affect the accuracy of state and local report cards. Nine  SEAs reported on our survey that they rely exclusively on school districts’  identification of youth in foster care for their state report cards. Of those  nine, seven reported that ensuring that school districts accurately identify  these youth is a challenge, which may affect the accuracy of the  additional report card data required by ESSA.

Some states and localities we visited had different ways to inform school  districts when a youth’s foster care status changes, but officials noted  varying degrees of consistency in notifying the districts of changes.  Officials at two state child welfare agencies we visited told us they require  the person enrolling the youth in school to present an official document  that shows the youth is in state custody; however, they said schools are  not informed when a child leaves foster care. One county and one state  we visited had electronic data sharing agreements between child welfare  and educational agencies for the purposes of updating school district  records when a child enters and leaves foster care. Specifically, in that  county, once a child enters foster care under the custody of the county  child welfare agency, the school district’s database automatically receives  pertinent information from the child welfare agency, according to officials.  School and child welfare agency officials meet monthly to ensure data  accuracy. In Georgia, officials from the state educational agency said they  signed a data sharing agreement in spring 2018 with the state child  welfare agency to allow information about youth in foster care to be provided to school districts. The previous data sharing agreement  prevented the SEA from sharing the data with the school districts,  according to officials. In Idaho (a state that participated in our discussion  group), state officials said they ensure school districts are aware of youth  in foster care by using an automated letter (see text box).

Idaho’s iCARE System for Youth in Foster Care  When a youth enters foster care or changes placements, Idaho’s iCARE system  produces an automated letter that provides an initial communication from a child welfare  social worker to the school district, SEA foster care points of contact, and the school  principal.  When the youth’s school of origin is entered into the system, the letter automatically  populates the email addresses of the appropriate school district point of contact, SEA  point of contact, and school principal. The letter contains the social worker’s initial best  interest determination, and indicates if the student will need transportation to attend their  school of origin, which the school district point of contact is responsible for coordinating.  The school district point of contact has three days to provide input on the best interest  determination when school is in session and 14 days during the summer months. The  school district foster care point of contact and the child welfare social worker both must  sign off on the plan identified within the electronic letter.

Monitoring School Districts’ Efforts to Implement ESSA Educational  Stability Provisions  Under federal grant regulations, SEAs, which subgrant Title I funds to  school districts, are required to conduct regular monitoring and oversight  to ensure appropriate implementation of Title I by their school districts,  and 43 SEA survey respondents reported that their states used one of the  methods asked about in our survey to monitor how school districts  implement at least one of the ESSA educational stability provisions. For  example, over half (33) of SEAs reported that the Title I plans they  receive from school districts include an assurance related to at least one  of the ESSA educational stability provisions we asked about on the  survey.

More than two-thirds (36) of SEAs reported on our survey that effectively  monitoring school districts’ implementation of the provisions is a  challenge (see fig. 5). In their survey comments, eight SEA points of  contact said limited state resources hinder their ability to ensure that the  hundreds of school districts in their states properly execute the  provisions. Officials we interviewed from all three SEAs in our site visits  told us their states incorporate the educational stability provisions into  their existing procedures for overseeing implementation of federal  education programs. For example, SEA officials in Georgia told us that  during one of their state reviews, they look for evidence of local agency  collaboration, such as meeting agendas or emails. In Arizona, the SEA  point of contact said he examines school district transportation  procedures during on-site reviews. These on-site reviews occur for one- sixth of school districts in the state every year. (See table 3 in appendix II  for more information on SEA monitoring of school districts.)

Ensuring Immediate Enrollment and Obtaining Records  While we did not ask on our survey about challenges related to immediate  enrollment or obtaining records, seven state or local officials we spoke  with noted difficulties with enrolling or obtaining records for students with  disabilities who have individualized education programs, or students who  previously attended juvenile justice or residential treatment facilities.  Officials at a local child welfare agency and two school districts said that if  an individualized education program is missing from a child’s records,  they cannot know which services or classes a child might need and it may  delay the child’s enrollment in the school or require switching classes  again. Officials from Georgia’s SEA said they mitigate this challenge by  providing school districts the option to share individualized education  programs electronically, which enables other school districts that need the  records to more easily obtain them.

Education Could Take Steps to Improve Access to Technical Assistance and Plans to Begin Monitoring of the ESSA Educational Stability Provisions

Education Provided Technical Assistance, At Times Collaborating with HHS, but Could Improve Access to Information

Education has provided technical assistance to states, at times in  collaboration with HHS, to help states implement the ESSA educational  stability provisions. Education’s technical assistance included written  guidance, webinars, and in-person meetings, according to Education  officials.

Written guidance: Education and HHS jointly issued non-regulatory  guidance on June 23, 2016 to help state and local educational  agencies meet their obligations related to educational stability for  youth in foster care under ESSA. On the same day, Education and  HHS also issued a joint letter to chief state school officers and state  child welfare directors that provided an overview of the ESSA  educational stability provisions. Education sent an additional letter to  chief state school officers on December 5, 2016, that provided  information about the timelines for implementing the provisions. The  letter also requested states to provide Education with their state foster  care point of contact.

Webinars: Education and HHS hosted several webinars for state  educational and child welfare agencies that addressed a number of  issues related to implementation of the ESSA educational stability  provisions. In late summer 2016, Education and HHS hosted four  webinars on the roles and responsibilities of educational and child  welfare agency points of contact; best interest determinations and  immediate enrollment; transportation; and effective collaboration.  These webinars described the related ESSA requirements and  featured selected states’ approaches to implementing the provisions.  The State Support Network, one of Education’s technical assistance  providers, facilitated another series of webinars that were offered in  summer 2018 to address areas of implementation that states reported  to be particularly problematic. HHS staff also participated in the  webinar series, and topics included collaboration with child welfare  agencies, data systems, transportation, and roles and responsibilities  of points of contact.

In-person and other assistance: Education provided additional  assistance to state educational agencies through an in-person  meeting and continuously provides assistance upon request.  Education and HHS jointly held a session on sharing data to support  students in foster care during its Combined Federal Programs  Meeting for SEA officials in December 2018 in Washington, DC. At  this meeting, Education also facilitated a session during which foster  care points of contact networked with each other and subject matter  experts, shared resources, and discussed outstanding implementation  challenges. In addition, Education officials told us that they assign  each state a point of contact at Education, and states can request  technical assistance at any time through their assigned contact. This  contact can work with the appropriate offices within Education to  provide information requested by states and can facilitate further  technical assistance through the State Support Network. Education  officials said they respond to questions from states generally asking  about expectations and requirements for the ESSA educational  stability provisions.

Thirty-seven SEAs reported on our survey that they would like additional  federal assistance as they continue to implement the ESSA educational  stability provisions. Our survey showed that most SEAs were interested in  receiving additional guidance related to transportation cost sharing,  transportation funding options, and arranging transportation; data privacy;  and state monitoring of school districts’ efforts to implement these  provisions, among other topics (see fig. 6). (Also see fig.10 in appendix II  for all survey responses on these topics.) With respect to transportation  issues, several state officials commented that they would like more  information on how other states and localities are arranging and funding  transportation. Regarding data privacy, a few other officials commented  that they could use more information regarding privacy laws and what  information can be shared across agencies. A few SEA officials noted  that guidance on how they could monitor school district implementation  would be useful.

A majority of SEAs reported that opportunities for in-person and virtual  meetings with a federal point of contact and their SEA and state child  welfare agency counterparts, and a federally supported clearinghouse of  information with sample documents from other states, would be  moderately to extremely helpful (see fig. 7). (Also see fig. 11 in appendix  II for all survey responses on this topic.) State educational and child  welfare officials we interviewed explained that in-person and virtual  meetings are helpful because they allow them to ask the federal contact  questions and share and discuss issues with each other. Similarly, SEA  officials in our discussion sessions said they would like federal agencies  to organize more collaborative opportunities for SEA points of contact to  interact with their peers to help identify best practices they can adapt in  their state. Some states suggested Education could adopt methods it  uses for other programs, such as the Education for Homeless Children  and Youth program, to provide assistance and support to foster care  points of contact, such as facilitating regional phone calls and identifying  a point of contact specific to foster care at the federal level. According to  Education officials, in June 2019 the agency selected a staff person to  serve as the federal point of contact to work directly with SEA foster care  points of contact, and they told us Education maintains a designated  mailbox for all foster care-related correspondence (FosterCare@ed.gov).

Education officials informed us that they plan to develop a community of  practice for a small group of SEA foster care points of contact who will  meet regularly for several months, which may facilitate more peer to peer  interaction for a select number of states. Education plans to work with the  Legal Center for Foster Care and Education to convene and facilitate the  community of practice. According to Education officials, the community  of practice will provide networking opportunities for participants to ask  questions and obtain answers from their peers, and may include  discussions of promising practices at the state and local level, among  other areas. Officials said they will solicit interest from all SEAs about the  opportunity to participate in the community of practice. However, they will  limit the number of participants, depending on the level of interest, to 10  to 12 SEAs to promote discussion and sharing among states. Officials  noted that if more states are interested in participating in the community  of practice than they can accommodate, they will consider additional  ways to support and share information with those additional states.  Education officials also noted that they are exploring other types of  technical assistance to facilitate more interaction and information  exchange among states, such as a web portal where states can upload  and share documents.

Although Education is planning to develop a community of practice and is  exploring other types of technical assistance, it may not have effective  methods to reach all SEA points of contact to inform them of this  assistance. In the course of our follow up on our survey, we determined  that 22 of the current SEA points of contact were missing from  Education’s email list. Education primarily disseminates information  pertaining to the ESSA educational stability requirements to states  through email. Twenty-three SEAs reported on our survey that they were  not aware of webinars that Education offered in summer 2018. We  discussed the email list with Education officials in June 2019 and they told  us they had not conducted outreach to states to update the email list  since they initially identified the SEA points of contact in 2016. Rather,  officials said the email list was updated on an ad hoc basis, and  Education depended on states to inform them when they want someone  added to the email list. Subsequent to that discussion, in response to a  recommendation included in a draft of this report which Education  reviewed, Education officials told us they updated the email list in July  and August 2019, and planned to update it quarterly moving forward.  Education officials also acknowledged it could be useful to publicize the  email list on its website.

Education does not maintain information about its technical assistance  webinars or other relevant materials in a centralized online location.  Information relevant to implementing the ESSA educational stability  provisions is located on multiple Education web pages, and the materials  from the most recent 2018 webinars, including the recorded session and  related sample documents shared by a number of states, are only  available on a third party website for which there is no link from  Education’s website. In our survey, SEA points of contact reported that  they are interested in receiving additional information from other states.  Thirty-seven SEAs reported in our survey that a clearinghouse of  information with sample documents from other states would be helpful,  and 22 of these 37 reported that this would be extremely helpful. One  SEA official commented that it would be useful to have a clearinghouse  that could be shared with school districts and other relevant parties  nationwide. Federal standards for internal control maintain that  management should select appropriate methods of communication, such  as providing hard copy or electronic documents or conducting face-to- face meetings, and should periodically evaluate the methods of  communication in order to communicate quality information on a timely  basis. Without creating and maintaining a centralized online location for  SEAs to access all related information, Education cannot ensure that all  SEAs have access to technical assistance and guidance that could help  them implement the ESSA educational stability provisions.

Education Plans to Begin Monitoring Implementation of the ESSA Educational Stability Provisions in Fall 2020

Education officials told us that in 2020, they expect to fully implement the  monitoring protocols for reviewing how states are implementing the ESSA  educational stability provisions. Education officials said they plan to test  draft protocols as part of a pilot by fall 2019 to determine necessary  revisions and expect the final protocols to be implemented by fall 2020.  According to Education officials, once the protocols are implemented,  they plan to use a risk assessment approach to determine which states to  review each year, and anticipate reviewing approximately nine states  each year, depending on staff and resources. As part of their reviews,  Education officials told us they plan to visit two school districts in each  state under review to assess how the selected states are implementing  the ESSA requirements, and to determine whether districts are getting  appropriate support from the states. According to the draft monitoring  protocols, during its state reviews, Education plans to obtain information  on the following areas related to educational stability: SEA collaboration  with the child welfare agency, best interest determinations, immediate  enrollment, SEA foster care point of contact, and school district points of  contact and transportation procedures.

Education reviewed states’ plans for implementing Title I, however,  Education officials said that the plans contain little information about the  ESSA educational stability provisions. To receive Title I funds, states are  required to submit state plans to the Secretary of Education, and the  Secretary is required to approve the state plans if they meet the  requirements in the law. While state plans are required to describe the  steps the SEA will take to ensure collaboration with the state child welfare  agency to ensure the educational stability of children in foster care,  including various assurances, Education did not include specific  instructions for information states should include on these provisions in  the state plan template it developed for states.

Youth in foster care face enormous challenges in their everyday lives and  school can offer a stabilizing environment. Maintaining connections with  teachers and friends, in addition to remaining in a familiar academic  environment, can enhance the chances that a student is academically  successful. However, many children in foster care are at higher risk of  frequently changing schools, which can affect their academic  achievement. ESSA made changes to the Title I program to help improve  the educational stability of children in foster care. In the years since ESSA  was enacted, SEAs and school districts have taken different approaches  to implement its educational stability provisions, including collaborating  with their child welfare agency counterparts.

Most SEAs we surveyed reported common challenges with staff turnover  and assisting districts with arranging transportation, among others, which  can affect the successful implementation of the educational stability  provisions. In addition, SEA officials are seeking more opportunities to  understand how other states and localities have implemented the  provisions and learn from their peers. Despite the assistance Education  has provided to SEAs on a range of topics, the mechanisms Education  uses to inform states of assistance are limited. The email list it uses to  notify SEA foster care points of contact had not been systematically  updated until July 2019, and resources on educational stability are not  housed in one space. Without improvements in areas like these, states  will not have access to all of the available resources that can help them  improve the educational stability of youth in foster care, and ultimately,  their academic success.

The Secretary of Education should develop an online clearinghouse of  sample documents from states and localities who wish to share them,  past webinar recordings and their related documents, and links to other  relevant resources that all SEAs can access. (Recommendation 1)

We provided a draft of this report to Education and HHS for review and  comment. Education provided written comments, which are reproduced in  appendix III, as well as technical comments, which we incorporated as  appropriate. HHS did not have comments. We also provided relevant  excerpts to states we visited and incorporated their technical comments  as appropriate.

In its written comments, Education agreed with our recommendation to  develop an online clearinghouse and noted actions it plans to take to  implement it. Specifically, Education said in fall 2019, its Office of  Elementary and Secondary Education will restructure its entire website to  better organize its information, and create a new web page to house all  foster care-related information and resources. Additionally, Education  said this office will launch a virtual portal through which SEA foster care  points of contact may collaborate and share resources.

In addition, in a draft report sent to Education in August 2019, we  included a recommendation to Education to update its foster care point of  contact email list, and develop a process to update it at regular intervals.  Education noted in its comment letter that it had updated its email list and  that it will solicit updates to the email list on a quarterly basis, so we  subsequently removed this recommendation.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretaries of Education and Health and  Human Services, and other interested parties. In addition, the report is  available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at 617-788-0580 or nowickij@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of our report. GAO staff who made key contributions to this report  are listed in appendix IV.

This report examines (1) the challenges states and selected local  educational agencies face implementing the requirements of the Every  Student Succeeds Act (ESSA) related to educational stability for youth in  foster care, and (2) how the Department of Education (Education)  provided technical assistance and monitored states and localities to  ensure compliance with these requirements, including collaborating with  the Department of Health and Human Services (HHS). To address both  objectives and obtain national information, we held three discussion  groups with officials from state educational agencies and child welfare  agencies and conducted a web-based survey of state educational  agencies in the 50 states, the District of Columbia, and Puerto Rico. To  obtain more in-depth information, we visited three states—Arizona,  Georgia, and Ohio—where we interviewed officials from state and local  educational agencies and child welfare agencies. We reviewed relevant  federal laws and regulations, Education and HHS guidance to states, and  other research publications. We also interviewed officials from Education  and HHS’s Administration for Children and Families, and other  organizations that carry out efforts related to education and child welfare,  including the Legal Center for Foster Care and Education and Casey  Family programs, regarding the provisions, federal requirements and  guidance, and state and local implementation.

State Educational and Child Welfare Agency Discussion Groups

To learn about actions states have taken to implement the ESSA  educational stability provisions and challenges they have encountered,  we held three discussion groups, two with state educational agency  (SEA) officials, and one with state child welfare agency officials, during a  national meeting for SEA foster care points of contact and state child  welfare agencies in Greensboro, North Carolina in October 2018. To  solicit participants for these groups, we asked the meeting organizers to  forward an invitation we drafted to all individuals who registered for the  meeting to participate in our discussion groups, and also allowed  individuals to sign up once they arrived at the conference. Meeting  attendees self-selected to participate in the groups. Each of our  discussion groups with SEA officials had seven participants, for a total of  14 state agency officials representing 14 states. Our discussion group of  state child welfare agency officials had six participants representing five  states.

Discussion groups were guided by a GAO moderator using semi- structured interview protocols. These protocols included open-ended  questions that encouraged participants to share their thoughts and  experiences on implementing the ESSA educational stability provisions,  including how they monitored local agencies, and whether any additional  federal assistance is needed. To reach group consensus on the top  challenges facing states as they implement the provisions, we used a  nominal group technique. Officials from each state identified their state’s  top three implementation challenges. The group then created a list from  those named challenges and officials from each state used stickers to  identify their top challenges from the list.

Discussion groups are intended to generate in-depth information about  the reasons for participants’ attitudes on specific topics and to offer  insights into their concerns about and support for an issue. They are not  designed to (1) demonstrate the extent of a problem or generalize results  to a larger population, (2) develop a consensus to arrive at an agreed- upon plan or make decisions about what actions to take, or (3) provide  statistically representative samples or reliable quantitative estimates. For  these reasons, and because discussion group participants were self- selected volunteers, the results of our discussion groups are not  generalizable.

Survey of State Educational Agency Officials

To learn about actions states have taken to implement the ESSA  educational stability provisions and challenges they have encountered,  we conducted a survey of SEA officials in the 50 states, the District of  Columbia, and Puerto Rico. The survey was administered from January  to March 2019 and we had a 98 percent response rate. The survey used  a self-administered, web-based questionnaire, and state respondents  received unique usernames and passwords.

Our survey population was foster care points of contact at SEAs. We  used multiple sources to create an initial list of points of contact, including  a list provided by the Department of Education, SEA website pages  related to foster care, and information from knowledgeable experts in the  field. We reached out to each point of contact to ask them to confirm they  were the foster care point of contact for their state or identify the  appropriate point of contact. We instructed respondents to consult with  others who were familiar with their state’s implementation of the  provisions, if doing so would provide more accurate responses.

Our survey included 20 fixed-choice and open-ended questions. We  asked how SEAs collaborated with the state child welfare agency, how  they assisted local educational and/or child welfare agencies, what  challenges they encountered, and what assistance has been and would  be helpful from the Department of Education in implementing the  provisions. To draft the closed-ended questions and answer choices on  the survey, we drew from recommended practices suggested in HHS and  Education’s joint non-regulatory guidance to states, information shared  during webinars sponsored by HHS and Education, and interviews with  stakeholders, including our discussion groups with state educational and  child welfare agencies. A draft of the survey questionnaire was reviewed  by officials at Education, a knowledgeable stakeholder organization, and  an independent GAO survey professional for completeness and accuracy.  We made revisions based on their comments. We conducted three  pretests—one by phone and two in-person—with SEA foster care points  of contact from three different states to check that (1) the questions were  clear and unambiguous, (2) terminology was used correctly, (3) the  questionnaire did not place an undue burden on agency officials, (4) the  information could feasibly be obtained, and (5) the survey was  comprehensive and unbiased.

To obtain our 98 percent response rate (51 out of 52 SEAs), we made  multiple follow-up contacts by email and phone from January to March  2019 with points of contact who had not yet completed the survey. While  51 surveyed officials affirmatively checked “completed” at the end of the  web-based survey, not all officials responded to every question or the  sub-parts of every question. We conducted additional follow-up with a  small number of respondents to verify key responses.

Because this was not a sample survey, the survey has no sampling  errors. However, the practical difficulties of conducting any survey may  introduce errors, commonly referred to as non-sampling errors. For  example, unwanted variability can result from differences in how a  particular question is interpreted, the sources of information available to  respondents, or how data from respondents are processed and analyzed.  We tried to minimize these factors through our reviews, pre-tests, and  follow-up efforts. In addition, the web-based survey allowed SEA foster  care points of contact to enter their responses directly into an electronic  instrument, which created an automatic record for each state in a data  file. By using the electronic instrument, we eliminated the potential errors  associated with a manual data entry process.

To learn about actions states and localities have taken to implement the  ESSA educational stability provisions and challenges they have  encountered, we conducted site visits to three states to obtain information  from state and local educational agency officials, state and local child  welfare officials, foster parents, and current and former youth in foster  care. We selected the three states—Arizona, Georgia, and Ohio—to  represent a mix of factors, including type of child welfare agency (state or  county administered), number of children in foster care, number of school  districts, geographic dispersion, and variety in types of school districts  (urban, suburban, rural). In each state we visited an urban, suburban, and  rural school district, where we met with the school district officials  responsible for implementing the ESSA educational stability provisions,  and their primary child welfare agency counterparts. We also met with  state educational and child welfare agency officials. We used a semi- structured interview protocol for these meetings. We held discussion  groups with a total of 13 youth in foster care or formerly in foster care in  three states, and in two states, we held discussion groups with a total of  14 foster parents, to obtain their perspectives on implementation of the  provisions and educational stability generally. Although we cannot  generalize our findings beyond these states and localities, these visits  provided us with illustrative examples of how states and localities are  implementing the ESSA educational stability requirements.

We conducted this performance audit from June 2018 to September 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix II: Additional Survey Data to the question: “How much of a challenge, if at all, is each of the following items in implementing the  ESSA educational stability provisions?” The term “ESSA educational stability provisions” refers to the  amendments made by the Every Student Succeeds Act (ESSA) to Title I, Part A of the Elementary  and Secondary Education Act of 1965 that are related to the educational stability of youth in foster  care. These provisions have been codified at 20 U.S.C. §§ 6311(g)(1)(E), 6311(h)(1)(C), and  6312(c)(5).

Best interest determination documents, like meeting  documentation templates, questions to consider during the  meeting, or sample notices to inform parties of the decision  Sample memorandum of understanding/agreement for data  sharing between school districts and local child welfare agencies  for the purposes of identifying youth in foster care for the report  card reporting  17  10  school of origin when in their best interest will be provided, arranged, and funded for the duration of  the time in foster care.  This includes states that reported that they solely respond when alerted to issues and do not conduct  any other systematic monitoring activities. Specifically, nine states reported responding when alerted  to issues regarding the provisions on best interest determinations and immediate enrollment, and did  not report conducting any other monitoring activities. Similarly, 14 states reported solely responding  when alerted to issues regarding new enrolling schools immediately contacting schools of origin to  obtain relevant academic and other records, and did not report conducting any other monitoring  activities. Finally, seven states reported responding when alerted to issues related to the provision on  transportation procedures, and did not report conducting any other monitoring activities or did not  know if their state monitors LEAs in other ways.  educational stability of youth in foster care. These provisions have been codified at 20 U.S.C. §§  6311(g)(1)(E), 6311(h)(1)(C), and 6312(c)(5).

Appendix III: Comments from the U.S. Department of Education

Appendix IV: GAO Contact and Staff Acknowledgments

In addition to the contact named above, the following individuals made  important contributions to this report: Elizabeth Morrison (Assistant  Director), Kate Blumenreich (Analyst-in-Charge), Aimee Elivert, and  Kelsey Kreider. Also contributing to this report were Steven Campbell,  William Chatlos, Sarah Cornetto, Holly Dye, Jill Lacey, Jessica Orr,  Catherine Roark, and Curtia Taylor.

Youth in foster care may often change schools, which can impair academic achievement. Federal law seeks to improve their educational stability. For example, it requires states to ensure youth stay in the original school they attended before being placed with a new family, unless doing so isn’t in their best interest.

State agency officials told us local staff turnover and the cost of transporting students to their original school were among the challenges to providing stability. They also said a way to exchange information about stability efforts would be helpful. We recommended Education develop a website where states can share information.


Defense Management: Observations on Changes to the Reporting Structure for DOD's Corrosion Office and Its Implementation of GAO Recommendations

Corrosion negatively affects DOD equipment and infrastructure and can lead to reduced asset availability, deterioration in performance, and increasing weapon system and infrastructure costs. According to a study contracted by DOD, the cost impact of corrosion to DOD in fiscal year 2016 was $20.6 billion.

Senate Armed Services Committee Report 115-262 accompanying a bill for the John S. McCain National Defense Authorization Act for Fiscal Year 2019 included a provision for GAO to review aspects of the DOD Corrosion Office. This report examines (1) how the restructuring within the Office of the Secretary of Defense has affected DOD's Corrosion Office, including its performance of its statutory roles and responsibilities; and (2) what actions, if any, DOD has taken or has planned to implement recommendations GAO made from calendar years 2003 through 2018 related to corrosion management.

GAO analyzed DOD documents, such as guidance and required reports provided to Congress, and interviewed DOD officials to address these objectives. GAO also assessed DOD's actions against its prior recommendations to determine the extent to which DOD had addressed the recommendations or has actions underway to address those recommendations.

The Department of Defense (DOD) relocated the Office of Corrosion Policy and Oversight (Corrosion Office) within the restructured acquisition and sustainment organization in fiscal year 2018. Prior to the restructure, the Corrosion Office reported directly to the Under Secretary of Defense for Acquisition, Technology, and Logistics. As part of the restructure, DOD relocated the Corrosion Office within the Office of the Under Secretary of Defense for Acquisition and Sustainment, where it reports to the Deputy Assistant Secretary of Defense for Materiel Readiness. It continues to perform its statutory roles and responsibilities under the new oversight organization. For instance, it is continuing to

develop and recommend corrosion policy guidance;

develop and implement a long-term strategy to reduce corrosion;

review corrosion programs and funding levels proposed by the military departments, and submit related recommendations to the Secretary of Defense; and

monitor and ensure that corrosion prevention and mitigation are incorporated into acquisition and maintenance processes.

DOD is also making or planning changes to the operation of the Corrosion Office, specifically planning to increase corrosion advocacy throughout DOD, oversight of the Corrosion Office, corrosion accountability of the military departments, and corrosion transparency and its alignment with materiel readiness.

DOD's Corrosion Office has taken or planned actions to implement most recommendations GAO made in calendar years 2003 through 2018 related to corrosion management. Specifically, GAO made 35 recommendations to the Corrosion Office in 11 corrosion-related products on topics such as strategic planning, performance management, and mandatory oversight reports. In comments on these products, DOD concurred with 16 of those recommendations, partially concurred with eight, and non-concurred with 11. As of March 2019, DOD had taken action or planned to take action on most of GAO's prior recommendations (see figure).

Specifically, DOD's Corrosion Office had taken action on 18 recommendations. Corrosion Office officials also described to GAO their plans to take action to implement 12 additional recommendations. These planned actions include, among other actions, updating existing guidance and developing new policy or processes. DOD stated that the Corrosion Office does not plan to take action on the remaining five recommendations. GAO continues to believe that its recommendations are valid.

Corrosion negatively affects Department of Defense (DOD) equipment  and infrastructure, and it can lead to reduced asset availability,  deterioration in performance, and an increasing total cost of maintaining  weapon systems and infrastructure. In addition to corrosion’s effects on  military readiness, it can cause environmental damage and loss of capital  investments, and it can create safety hazards for servicemembers. DOD  contracted a study on corrosion that reported the cost impact of corrosion  as $20.6 billion in fiscal year 2016.

Since 2002 statutes have required DOD to report specific information on  corrosion topics to Congress and have created a central DOD authority to  organize and manage corrosion policy and practices among the military  departments. The Bob Stump National Defense Authorization Act for  Fiscal Year 2003 amended Title 10, U.S. Code, by adding section 2228,  which led to the creation of the Office of Corrosion Policy and Oversight  (referred to hereinafter as the Corrosion Office) within the Office of the  Under Secretary of Defense for Acquisition, Technology, and Logistics.  In 2008 the Duncan Hunter National Defense Authorization Act for Fiscal  Year 2009 directed each of the military departments to designate a  Corrosion Control and Prevention Executive (referred to hereinafter as a  Corrosion Executive) to serve as the senior official in the Departments of  the Army, Navy, and Air Force to coordinate department-level corrosion  prevention and control activities with, among other entities, the Corrosion  Office. In 2018 the Corrosion Office was relocated within DOD, after  section 901 of the National Defense Authorization Act for Fiscal Year  2017 (Pub. L. No. 114-328) required DOD to restructure the Office of the  Secretary of Defense, among other things.

Senate Armed Services Committee Report 115-262 accompanying a bill  for the John S. McCain National Defense Authorization Act for Fiscal Year  2019 includes a provision for us to review aspects of DOD’s Corrosion  Office. This report examines (1) how the restructuring within the Office of  the Secretary of Defense has affected DOD’s Corrosion Office, including  its performance of its statutory roles and responsibilities; and (2) what  actions, if any, DOD has taken or has planned to implement  recommendations GAO made from calendar years 2003 through 2018  related to corrosion management.

In addressing our first objective, we analyzed guidance documents to  identify and review the ongoing oversight, procedural, and management  changes within the Corrosion Office. Also, we interviewed officials in the  Office of the Deputy Assistant Secretary of Defense for Materiel  Readiness, the Corrosion Office, and the military departments. In  addressing our second objective, we reviewed our prior products issued  in calendar years 2003 through 2018 in order to identify all relevant  corrosion recommendations made to the Corrosion Office directly or to  the DOD oversight entity that would in turn have directed the Corrosion  Office to address the particular recommendations made during this time  frame. We chose this time frame because the Corrosion Office was  established in 2003. We excluded from our analysis any previous  corrosion recommendations that were no longer relevant due to a DOD  policy change. In addition, we reviewed our prior products to identify  DOD’s initial response to these corrosion recommendations. We then  interviewed cognizant officials or reviewed documents ranging from policy  guidance to required reports provided to Congress to obtain information  on DOD’s subsequent actions, if any, for each recommendation. We  reviewed this information to determine whether, as of March 2019, DOD  had taken action, had plans to take action, or had no planned action to  address each recommendation.

We conducted this performance audit from July 2018 to May 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Corrosion is defined in section 2228 of Title 10, U.S. Code, as the  deterioration of a material or its properties due to a reaction of that  material with its chemical environment. Corrosion can take varied forms,  such as rusting, pitting, galvanic reaction, calcium or other mineral build- up, degradation due to ultraviolet light exposure, and mold, mildew, or  other organic decay. Corrosion can be either readily visible or  microscopic.

To provide leadership on corrosion matters, including the development of  policy guidance and oversight, consistent with section 2228, DOD has  established an organizational structure that includes the Corrosion Office  and Corrosion Executives. The Director of the Corrosion Office is to  provide oversight and coordination of corrosion control and prevention  efforts for the department. The military departments have each assigned  officials to serve as Corrosion Executives. The Corrosion Executives  operate within the chain of command of their respective military  departments, while also coordinating with the Corrosion Office.

DOD Has Relocated the Corrosion Office, but It Continues to Perform Its Statutory Roles and Responsibilities and Is Making Plans for Future Operations

DOD Relocated the Corrosion Office within the Restructured Acquisition and Sustainment Organization in Fiscal Year 2018

Prior to August 2018, the Corrosion Office reported directly to the Under  Secretary of Defense for Acquisition, Technology, and Logistics. In 2018  the Corrosion Office was relocated within DOD, after section 901 of the  National Defense Authorization Act for Fiscal Year 2017 (Pub. L. No. 114- 328, hereinafter referred to as the Act) required DOD to restructure parts  of the Office of the Secretary of Defense. Among other things, the Act  eliminated the Under Secretary of Defense for Acquisition, Technology,  and Logistics, and it created:

The Under Secretary of Defense for Research and Engineering, who,  among other things, serves as the principal advisor to the Secretary of  Defense on all research, engineering, and technology development  activities and programs in DOD.

The Under Secretary of Defense for Acquisition and Sustainment,  who, among other things, serves as the principal advisor to the  Secretary of Defense on acquisition and sustainment in DOD. In  addition, the Under Secretary establishes policies on and supervises  all elements of DOD relating to acquisition and sustainment.

As part of this restructure, effective August 1, 2018, DOD relocated the  Corrosion Office within the department’s restructured acquisition and  sustainment organization, as shown in figure 1. The Corrosion Office is  now located within the department’s Office of the Under Secretary of  Defense for Acquisition and Sustainment. Within this office, the Deputy  Assistant Secretary of Defense for Materiel Readiness oversees the  Corrosion Office. The Deputy Assistant Secretary of Defense for Materiel  Readiness is a principal advisor to the Assistant Secretary of Defense for  Sustainment; provides integration and oversight of DOD’s maintenance  program; and develops policies and procedures for materiel readiness  and maintenance support of DOD’s major weapon systems and military  equipment.

The Deputy Assistant Secretary of Defense for Materiel Readiness stated  that he is supportive of the Corrosion Office’s mission and views its move  to the Materiel Readiness organization as fitting in with the other areas  under his oversight. Officials representing the military departments’  Corrosion Executives also stated that they support DOD’s organizational  movement of the Corrosion Office. They stated that they continue to find  the Corrosion Office to be helpful in establishing corrosion prevention  standards and in providing opportunities for networking and information  sharing by means of triannual corrosion forums. In addition, they stated  that they have found the Deputy Assistant Secretary of Defense for  Materiel Readiness to be supportive of corrosion oversight and prevention  in their meetings with him.

Since August 1, 2018, the Corrosion Office has had an acting director.  According to a Corrosion Office official, the Deputy Assistant Secretary of  Defense for Materiel Readiness is involved in the ongoing hiring process  for a permanent director. According to a Corrosion Office official, the time  frame in which a permanent director is projected to be in place is Spring  2019.

The Relocated Corrosion Office Continues to Perform Its Statutory Roles and Responsibilities

Section 2228 of Title 10, U.S. Code, contains provisions regarding the  duties and responsibilities of the Director of the Corrosion Office.  Specifically, these duties and responsibilities include the following: overseeing and coordinating efforts throughout DOD to prevent and  mitigate corrosion of military equipment and infrastructure, and  developing and recommending corrosion policy guidance to be issued  by the Secretary of Defense; developing and implementing, on behalf of the Secretary of Defense,  a long-term strategy to reduce corrosion and the effects of corrosion  on military equipment and infrastructure;  reviewing corrosion programs and funding levels proposed by the  military departments during the annual internal DOD budget review  process as those programs and funding proposals relate to programs  and funding for the prevention and mitigation of corrosion, and  submitting recommendations regarding those programs and proposed  funding levels to the Secretary of Defense; providing oversight and coordination of efforts within DOD to prevent  or mitigate corrosion during the design, acquisition, and maintenance  of military equipment, as well as the design, construction, and  maintenance of infrastructure; monitoring DOD acquisition practices to ensure that the use of  corrosion prevention technologies and the application of corrosion  prevention treatments are fully considered during research and  development in the acquisition process; and ensuring that, to the extent determined appropriate for each  acquisition program, such technologies and treatments are  incorporated into that program, particularly during the engineering and  design phases of the acquisition process.

The Corrosion Office continues to perform the duties outlined in section  2228, as evidenced below. Specifically, the Corrosion Office is taking the  following actions:

Developing and recommending corrosion policy guidance. DOD  previously developed and issued an instruction that establishes policy,  assigns responsibilities, and provides guidance for corrosion  prevention and mitigation. The Corrosion Office, via a working group  in a working integrated product team, plans to update this DOD  instruction. The working group intends for the updated DOD  instruction to reflect the Corrosion Office’s movement within DOD’s  restructured acquisition and sustainment organization; any statutory  changes made to section 2228 since it was last issued; direction from  the new acquisition and sustainment leadership; and any changes  made to address the findings and recommendations in our 2018  report.

Additionally, the Corrosion Office plans to create a new DOD manual  on corrosion that, according to Corrosion Office officials, will contain  operating procedural details on, among other items, conducting and  recording the Corrosion Office’s review and evaluation processes.  According to Corrosion Office officials, the Corrosion Office’s target  time frame for updating this DOD instruction and creating this new  manual is by the end of calendar year 2020.

Also, since July 2018 the Corrosion Office has been reviewing other  DOD policy guidance to identify relevant documents in which  corrosion content should be added or updated. Corrosion Office  officials stated that the new director will update existing corrosion  prevention and mitigation policy guidance, directives, and instructions  in coordination with the military departments’ Corrosion Executives,  under the guidance of the Deputy Assistant Secretary of Defense for  Materiel Readiness.

Developing and implementing a long-term strategy to reduce  corrosion and its effects. In 2015 DOD issued a long-term strategy for  preventing and mitigating corrosion that calls for implementing DOD- wide standards and improving strategies and processes to prevent,  detect, and treat corrosion. According to Corrosion Office officials,  there was a planning meeting for the working integrated product  teams’ leads and co-leads in mid-March 2019. At this meeting, the  team leads and co-leads prepared a draft update to the long-term  strategy, which had last been updated in 2015. These officials told us  that examples of changes included in the draft update are revised  goals, objectives, and metrics. In addition, these officials told us that  the draft update was aligned to reflect the DOD sustainment and  materiel readiness mission statements and objectives articulated by  the Assistant Secretary of Defense for Sustainment and the Deputy  Assistant Secretary of Defense for Materiel Readiness. According to  Corrosion Office officials, this draft plan is being reviewed internally,  and the Corrosion Office’s target time frame is to update it by the end  of calendar year 2020.

Reviewing corrosion programs and funding levels proposed by the  military departments and submitting related recommendations to the  Secretary of Defense. As it did prior to the restructure, the Corrosion  Office continues to review the military departments’ proposed  corrosion-related programs and funding levels during the annual  internal DOD budget review process. In addition, it continues to  annually submit a report to Congress on corrosion funding with the  defense budget materials. As part of this process, the Corrosion  Office collected information from the Corrosion Executives on the  corrosion control and prevention programs within the respective  military departments. The Corrosion Office in Autumn 2018 included  the information provided by each Corrosion Executive as appendixes  in its annual report on corrosion funding. The fiscal year 2020 report  was submitted to Congress on February 15, 2019.

Monitoring and ensuring that corrosion prevention and mitigation are  incorporated into acquisition and maintenance programs. As we  reported in November 2018, Corrosion Office officials told us that they  continue to perform the Corrosion Office’s acquisition and  maintenance-related duties. For instance, the Corrosion Office  continues to review acquisition documentation, such as Systems  Engineering Plans, and to maintain information on hundreds of  technologies for preventing and mitigating corrosion. In November  2018 we recommended that the Corrosion Office develop a process to  maintain documentation of its reviews of corrosion planning for major  weapon system programs. Further, we stated that these records, at a  minimum, should show what comments were made by the Corrosion  Office in its reviews and evaluations, and should track the actions  taken to resolve those comments.

DOD concurred with this recommendation and stated that the  Corrosion Office would develop and maintain such a process. More  specifically, Corrosion Office officials stated that they plan to describe  this process in a new DOD manual on corrosion. According to  Corrosion Office officials, the DOD manual will also include  information on considering corrosion during the weapon system  program-planning evaluation process. In addition, the Corrosion Office  plans to develop an internal data system that these officials told us will  track its reviews and evaluations along with the weapon system  programs’ responding actions. According to Corrosion Office officials,  their target time frame is to create this new manual and internal data  system by the end of calendar year 2020.

Corrosion Office officials told us that they have not changed the way in  which they carry out additional authorities identified in section 2228. For  example, the Corrosion Office continues to develop and deliver corrosion  training with the Defense Acquisition University. In addition, it continues to  interact with industry, trade associations, other government corrosion  prevention agencies, academic research and educational institutions, and  a scientific organization engaged in corrosion prevention.

DOD Is Making or Planning Changes for Some of the Ways in Which the Corrosion Office Operates

According to the Deputy Assistant Secretary of Defense for Materiel  Readiness, he is working to change some of the ways in which the  Corrosion Office operates. Specifically, he is working to increase the  following:  corrosion advocacy throughout DOD; oversight of the Corrosion Office;  the accountability of the military departments and the Corrosion Office  to mitigate corrosion; and  the transparency of corrosion and its alignment with materiel  readiness.

One of the efforts made by the Corrosion Office for achieving these  objectives is by providing funding for corrosion technology demonstration  projects proposed and implemented by the military departments.  According to Corrosion Office officials, the Deputy Assistant Secretary of  Defense for Materiel Readiness changed the process for awarding fiscal  year 2019 funding by obtaining feedback from the military departments’  Corrosion Executives as to which project proposals should receive funds.  Officials representing the military departments’ Corrosion Executives  confirmed that they were able to provide such feedback. Corrosion Office  officials told us that, as of April 2019, they had selected and funded  demonstration projects for fiscal year 2019 in part based on the  information provided by the military departments. In addition, the Deputy  Assistant Secretary of Defense for Materiel Readiness stated that he  wanted to have more of an emphasis on funding demonstration projects  that would be beneficial to all of the military services.

According to Corrosion Office officials, another effort they undertook at  the direction of the Deputy Assistant is that of working to make the  Corrosion Office more cost-efficient by streamlining the number of  professional services and other support contracts it awards. For example,  Corrosion Office officials stated that by consolidating five contracts for  professional services and reporting on the cost of corrosion into a single  contract by a target date of mid-July 2019, they estimate achieving  savings of approximately $2 million. In another effort, the Deputy  Assistant Secretary of Defense for Materiel Readiness provided written  feedback to each of the military departments’ Corrosion Executives in  March 2019 on their respective departments’ corrosion control and  prevention programs. Specifically, the feedback concerned whether each  military department’s calendar year 2018 corrosion report complied with  statutory requirements; each department’s strengths and weaknesses  related to its corrosion efforts; and recommendations each department  had identified for itself to implement.

DOD’s Corrosion Office Has Taken Action or Plans to Take Action to Implement Most of GAO’s Recommendations

In calendar years 2003 through 2018, we made 35 recommendations to  the Corrosion Office in 11 corrosion-related products on topics such as  strategic planning, performance management, and mandatory oversight  reports. In responding to these products, DOD initially concurred with 16  of those recommendations, partially concurred with eight, and non- concurred with 11.

As of March 2019 DOD’s Corrosion Office had taken action or had plans  to take action on most of our recommendations. Specifically, out of 35  recommendations, DOD’s Corrosion Office had taken action on 18 recommendations, including sufficient action  for us to close those recommendations as implemented; planned to take action to implement 12 additional recommendations.

These planned actions include, among other actions, updating  existing guidance and developing new policy or processes; and did not plan to take action on the remaining five recommendations.

Corrosion Office officials stated that they did not plan to take action on  these recommendations for a variety of reasons. For instance these  officials stated that the Corrosion Office did not have the authority  over the military departments to take the recommended actions. We  continue to believe our recommendations are valid.

Appendix I summarizes all 35 recommendations and DOD’s response to  each recommendation at the time of our report and provides information,  as of March 2019, on DOD’s actions or planned actions to address each  recommendation. In some instances DOD had taken action or planned to  take action on recommendations with which it had not concurred at the  time of our report.

We provided a draft of this report to DOD for review and comment. DOD  concurred with the draft and had no technical comments.

We are sending copies of this report to the appropriate congressional  committees and to the Acting Secretary of Defense and the Under  Secretary of Defense for Acquisition and Sustainment. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.

If you or our staff have any questions about this report, please contact  me, Diana Maurer, at (202) 512-9627 or maurerd@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs are  listed on the last page of this report. GAO staff who made key  contributions to this report are listed in appendix II.

Appendix I: GAO Recommendations to the Department of Defense (DOD) Corrosion Office and DOD’s Response and Actions

Appendix II: GAO Contact and Acknowledgments

In addition to the contact named above, Marilyn Wasleski (Assistant  Director), Dawn Godfrey, Shvetal Khanna, Amie Lesser, Edward Malone,  Nathan J. Napolitano, Carter Stevens, and Cheryl Weissman made key  contributions to this report.

Corrosion erodes DOD equipment and infrastructure. It can, for example, put a weapon into the shop for repairs instead of being available for use. Corrosion cost DOD an estimated $20.6 billion in fiscal year 2016. DOD's Office of Corrosion Policy and Oversight is charged with combating this problem.

We found that DOD is making changes to how this office operates to more effectively address corrosion issues. We also found that this office is working to address 30 of the 35 recommendations we’ve made regarding corrosion since 2003—such as establishing a process to assess the effectiveness of various anti-corrosion efforts.