In recognition of the increased demands facing state education departments in this accountability-focused era, Gail L. Sunderman and Gary Orfield present results from a study on the response of these agencies to the No Child Left Behind Act (NCLB). In this article, Sunderman and Orfield analyze issues of state capacity, compiling data from interviews, policy and program document analysis, and budget and staffing information. They find that state education departments, which are tasked with intervening in underperforming schools to ensure 100 percent proficiency for all students under NCLB, may not have the necessary human and financial resources or organizational capacity to adequately meet their increased responsibilities. In addition to issues of capacity, structural, functional, and political factors all limit the ability of state education departments to completely fulfill their new administrative roles. Sunderman and Orfield suggest that state education departments have shown good faith in their responses and suggest that the federal law turn its attention to necessary infrastructure improvement instead of further increased responsibilities. (Contains 7 tables, 1 figure and 4 notes.)