No Child Left Behind (NCLB) was passed with a promise to "change the culture of America's schools." A focus on accountability for results is among its main vehicles for transformation, including the requirement that significant action be taken in schools and districts that continue to underperform academically. Toward that end, NCLB requires that if a school does not make adequate yearly progress (AYP) for five consecutive years, its district must create a plan to restructure the school. If the school does not make AYP for six consecutive years, its district must implement this plan. The language of the legislation places the burden of restructuring on the local education agency (LEA), which is normally the local district. But ultimate accountability for the implementation of the legislation is given to the state education agency (SEA)-i.e., the state department of education. Ambiguity remains, though, regarding the respective roles of LEAs and SEAs. As a result, each SEA has interpreted its role in school restructuring differently. To gain a better understanding of these differing interpretations, this paper examines how state departments of education have been involved in the planning and implementation of school restructuring under NCLB. The experience of these states can serve as a baseline to understand how the restructuring process works in practice and how it may evolve in the future. The information in this document is based on interviews with state officials as well as reviews of relevant documents. Appended is: States with Schools Implementing Restructuring Options in the 2004-05 School Year. (Contains 1 table and 13 endnotes.) [The U.S. Department of Education's Public Charter Schools Program provided funding for this document.]