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In 2011, the U.S. Department of Education offered states waivers to the Elementary and Secondary Education Act (ESEA). These waivers gave flexibility for some of the law’s more problematic requirements in return for implementing key principles, including requirements for turning around lowest-achieving schools. Which principles could states implement quickly and which were challenging? In this study’s survey of school-turnaround leaders in all 50 states, the lowest percentages of participants reported full implementation of assistance for school-turnaround principles ensuring effective school staff. Also, significantly fewer states without successful waivers applications had fully implemented this assistance. The study shows that human capital remains a key challenge for school turnaround. The study also examines the data using and comparing two different analysis methods.