This dissertation analyzes administrative discretion in public policy implementation in application of a new framework of integrative approach to administrative discretion developed from deficiencies of the citizen participation, representative bureaucracy, and private-interest groups democracy frameworks. The new framework holds that public agencies use discretion to integrate in decision making views of elected authorities, private-interest groups, public-interest groups, and other groups that seek to influence implementation. The No Child Left Behind (NCLB) policy is used as the case study, and the U.S. Department of Education (DOE) is the implementation setting. The dissertation answers the following question: How integrative of group views was DOE’s discretionary decision making in the implementation of NCLB? This research applies a structured content analysis method that consists of content analysis and a content analysis schedule (see Jauch, Osborn, & Martin, 1980). Using a Likert question, the dissertation developed six integration levels of DOE’s discretionary decision making from not at all integrative to extremely integrative and found that most decisions were very integrative.