The purpose of this study was to explore features of Supplemental Educational Services (SES) implementation at the district level. In the study beliefs, goals, and actions of district office administrators were analyzed against the backdrop of changing federal guidelines and challenges faced by SES implementers across Arizona. The case study focuses on implementation in the 2007-2008, 2008-2009, and 2009-2010 school years. The study uses the 2005 and 2009 Department of Education guidelines, survey responses from Arizona district and school implementers, as well as documents and interviews from an urban Arizona case district. The study separates the implementation activities into task areas, which are analyzed separately. Using a loose coupling perspective, the separate task areas are furthered used as coupling domains and represented in social network graphs. Results show that the case district personnel were highly focused on their primary role, maintaining district compliance with federal guidelines. The district personnel employed several changes over the case study period to centralize their control of SES operations within district. The employment and training of site level coordinators was the most impactful of the strategies. As boundary spanners, the coordinators allowed greater access to information, oversight, and influence at the site level. Despite the growing capacity and earnest efforts of the district personnel, the case district was still very far from being able to measure or assess the impact of SES on student achievement. Centralization in the scholastic task areas was relatively low, and had marginal changes over the case study period. Years into the program, there was still no avenue to accurately gauge the effectiveness. As the district personnel were chiefly concerned with compliance, they had suspended judgment on the program and focused primarily on improving their processes.