Within the U.S. federalist system, State Educational Agencies (SEAs) administer the federal and state education policies that govern local educational agencies (LEAs), often with the goal of improving student experiences and outcomes. The context within which states govern K–12 public education has changed considerably over the past three decades. The passage of the No Child Left Behind Act and the Every Student Succeeds Act have expanded what SEAs are expected to do, even as their resources and staffing have often failed to keep pace (Manna, 2010; Murphy & Ouijdani, 2011; Childs & Russell, 2017). In response, states have increasingly turned to networks of intermediaries — regional service agencies, nonprofit organizations, and contracted providers — to help carry out functions once handled directly by state departments of education (Honig, 2004; Russell et al., 2015; Trinidad et al., 2026). Understanding how policy gets translated into practice requires attention to the role of these external entities within state-level governance systems (Provan & Kenis, 2008).
This study advances a framework for analyzing state-level governance systems as three interconnected levels: supervisory authority, administrative authority, and implementation decision rights (Table 1). The framework makes visible the different ways SEAs assign policy authority and decision rights to the SEA itself and external entities. Supervisory authority refers to the authority to establish statewide policy priorities, expectations, and oversight frameworks for the education system. Administrative authority refers to the power to translate policy into enforceable requirements, make determinations of compliance or approval, issue binding guidance, and allocate resources under law. Implementation decision rights refers to discretion over the design, delivery, and coordination of programs and services within policy and regulatory parameters.
Guided by this framework, this study uses an original comparative institutional analysis of California, Florida, New York, and Texas to examine how large states allocate supervisory authority, administrative authority, and implementation decision rights across educational entities. We map formal allocations of supervisory and administrative authority as defined in statute and regulation and delegation of implementation decision rights as outlined in official governance documents and state websites.
Distinguishing supervisory authority, administrative authority, and implementation decision rights as analytically distinct functions clarifies how state-level delegation operates. Prior research on state-level governance has largely treated delegation as a question of decision rights, focusing on the growing role of intermediaries, nonprofit organizations, and regional service providers in supporting districts and schools (5). Our framework allows us to distinguish between administrative authority and implementation decision rights to examine whether states delegate the authority to oversee and enforce policy in addition to discretion over how to deliver what is required under policy. This work is descriptive and conceptual, we do not examine how these arrangements operate in practice nor their effect on educational outcomes.
