A critical look at the Guidehouse report on Iowa's AEAs

Ted Stilwill served as director of the Iowa Department of Education under Governors Terry Branstad and Tom Vilsack. He has also worked with a national nonprofit on program evaluation and school improvement work with several state departments of education and large school districts.

Last fall, Iowa’s Department of Administrative Services entered into a contract with Guidehouse, a business consulting firm, to produce a report on special education in Iowa. The study was designed to bolster Governor Kim Reynolds’ effort to decimate the Area Education Agencies (AEAs) and weaken Iowa’s public education system.

The report (enclosed in full below) does not name its authors. How much it cost the state is not known. The Reynolds administration has not shared its directions to Guidehouse. The consulting firm has no apparent expertise or track record in the education world. Nothing in the report indicates that a single Iowan was engaged in its preparation.

Most importantly, I believe the Guidehouse conclusions about AEAs are flawed.

Of the three general negative charges against AEAs, none hold up to scrutiny, even when using data from the report.


The report asserts that there is little or no accountability for AEAs. From page 8:

As the analysis in this report will show, Iowa’s special education structure gives AEAs vast control over the education of students with disabilities with little oversight from school districts and the Iowa Department of Education.

From page 9:

Despite school districts funding the operation of AEAs, school district staff members – including school superintendents – are prohibited from sitting on AEA boards of directors and lack formal oversight and accountability mechanisms over AEAs.

So, the report’s sole basis for claiming lack of accountability is the legislated prohibition for local teachers and administrators to sit on their local AEA Board.

That conclusion ignores several important facts. The school district boards appoint the AEA board members, which certainly provides accountability from the local community side and is free from the possible conflicts of interest in staff serving on a governance function.

Inexplicably, the supposed lack of accountability totally ignores an active state accreditation system, annual reporting to the Iowa Department of Education, and annual budget approval by the department as well as the State Board of Education. The state uses the same sort of mechanism to hold school districts accountable. There is no evidence this process is not working for AEAs.


The Guidehouse report raises a concern about the academic achievement of Iowa’s special education students. From page 8:

In the most recent administration of NAEP [National Assessment of Educational Progress] in 2022, students with disabilities in Iowa scored below the national average, despite the state investing several thousand dollars more on a per pupil basis for special education students for that year in comparison to the national special education spending average.

If you look on page 21 of the consultant’s report, you see that in 2022, Iowa special education students scored one point below the national average, on a 500 point scale—on a test that only samples students in each state.

We should not even be using NAEP data for state-to-state comparisons because, as NAEP’s own website states,

Although every effort is made to include as many students as possible, different jurisdictions have different exclusion policies, and those policies may have changed over time. Because SD [students with disabilities] and EL [English learners] students typically score lower than students not categorized as SD or EL, jurisdictions that are more inclusive—that is, jurisdictions that assess greater percentages of these students—may have lower average scores than if they had a less inclusive policy.  

Practically speaking, school districts and states might exclude some of the more severely cognitively handicapped students from testing on a grade level oriented test, for what I believe are legitimate reasons. Including or excluding even a few very low scoring students would affect the overall average significantly.

In other words, Governor Reynolds’ claim that AEAs have been “failing our students with disabilities for 20 years” may not be warranted.

That doesn’t necessarily mean that current student performance is acceptable. But those test scores would not justify the governor’s plan to radically reduce non-special education services and centralize control and services at the state level.

While the reliance on NAEP data is questionable, the Guidehouse report also ignores other indicators. For example, the graduation rate for Iowa’s children with disabilities improved from 69.51 percent in 2016 to 80.43 percent in 2020. The dropout rate for students with Individualized Education Programs (IEPs) was 19.79 percent in 2016 but improved to 17.25 percent in 2020.

Those facts do not support the governor’s contention that Iowa has been failing special education students for 20 years. Incidentally, these numbers were extracted from the “STATE PERFORMANCE PLAN / ANNUAL PERFORMANCE REPORT: PART B” as part of “Indicator 1” and “Indicator 2,” which was attached to the consultant report.

It is also not clear how reducing or eliminating AEA services in media and instructional services would improve special education learning. In fact, most special education students are with regular education teachers most of the time. Improving instruction in regular education classrooms would seem to greatly benefit special education students who might otherwise struggle there. Eliminating AEA instructional services, the primary provider of continuing education for regular education teachers, does not seem like a good plan.


A third major criticism of the AEAs is that Iowa spends too much on special education. The report asserts, “Iowa spends $5,331 more per-pupil on special education than the national average.”

Iowa might spend more on special education students than many other states, although the actual data can be confusing. This is not a new situation, nor is it under the AEAs’ control.

As the report notes, AEA funding is set primarily by the Iowa legislature. From my admittedly dated observations, Iowa’s system for special education is more sophisticated, with stronger programs than those found in many states. For example, there is evidence that Iowa has far fewer parent complaints and legal cases about substandard services than other states. In addition, Iowa was one of the first states to provide comprehensive support for autistic kids.

Furthermore, identifying and comparing special education costs is not as simplistic as the Guidehouse report indicates. For example, see the table on page 96.

The table lists Iowa’s adjusted special education spending per pupil at $14,387, the number cited elsewhere in the report. But nine states are said to spend zero dollars, and several others seem to understate the spending. It does not inspire confidence that the Guidehouse data accurately captures costs or represents apples to apples comparisons.

For another perspective, here is a link to a state-by-state review of special education costs from the Education Commission of the States, which provides very different figures for each state’s special education spending. Iowa pays for membership in this organization, and the governor and Iowa Department of Education director are among Iowa’s representatives on the commission.

The Education Commission of the States shows Iowa spending $6,324/pupil, with many states spending more. That is not consistent with the $14,387 per student figure quoted in the Guidehouse report. There is more than one way of analyzing these costs.


In summary, the consultant’s report has obvious flaws and seems selective in the data it chooses to highlight. I am suspicious of a report requested by the Department of Administrative Services rather than the Iowa Department of Education. The education department would have access to more expertise to guide the study. If the Department of Administrative Services received a groundswell of concern about special education and AEAs, where is the documentation of those concerns? Why was the report requested, in the absence of documented concerns?

The underlying question is why the governor does not support public schools. Her administration has diverted hundreds of millions of dollars to private schools for the first time in state history. Most of the new charter schools recently approved by the state will be run by out of state companies.

Reynolds has appointed education department directors with expertise in funding private schools, but little background in supporting the schools more than 90 percent of Iowa students attend. While she has offered more dollars for teacher salaries, her current AEA proposal will make educators’ jobs more difficult, with less support.

When Governor Terry Branstad appointed me director of the Department of Education in 1995, he often spoke personally of the importance of public education. When I later led the same department under Governor Tom Vilsack, I could not have asked for a stronger ally in supporting or improving public education. I have to wonder what has changed.

Full text of Guidehouse report on Special Education in Iowa:

About the Author(s)

Ted Stilwill

  • The bull in the china shop

    Parents know that education is a long term effort. It typically improves with small changes that are carefully thought and understood by everyone involved. Major changes that are unilaterally imposed destroy mutual trust, discourage kids and teachers, and often lead to lasting and resounding failures.

  • like with the Federalist Society takeover of the Supreme Court

    this is part of a wider campaign to gut government regulations and services on behalf of our homegrown versions of oligarchs and to transfer even more wealth and power their way:

  • Did Terry Branstad select Kim Reynolds as his successor...

    …because he knew he would look better by comparison after she took office? I first heard that speculation as a joke a few years ago, but now, for me, it has lost its humor.

  • Former State Representative

    Congratulations, Ted. Along with Dave Tilly, former Deputy Director of the Department of Education, you have revealed that the report about Iowa’s Area Education Agencies (AEAs) by the out-of-state consulting firm is professionally and intellectually flawed. But I guess Kim Reynolds got what she wanted and paid for.

  • No title

    Hello Ted,
    I am glad you are still active in advocating for education in Iowa! I am trying to help down here in Southwest Iowa. Thank you for sharing your expertise.
    Elizabeth Wearin