Audit 393099

FINDING - The District did not always maintain required documentation to support adjustments to the high school cohort graduation rate. CRITERIA - Title 20, Section 7801(25), United States Code, requires that the District maintain appropriate documentation to support the removal of a student’s count from the 4-year cohort (defined as a group of students on the same schedule to graduate) used to calculate the high school cohort graduation rate. To remove a student’s count from the cohort, the District must require documentation, or obtain documentation from the Florida Department of Education, to confirm that the student transferred from the District, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Additionally, a student who is retained in grade or who enrolls in a program leading to a general equivalency diploma, or other alternative educational program that does not issue or provide credit toward issuance or a regular high school diploma, shall not be considered transferred out and shall remain in the adjusted cohort. The confirmation of a student’s transfer to another school or program requires documentation of such transfer from the receiving school or program in which the student enrolled. A student who was enrolled in a high school, but for whom there is no confirmation of the student having transferred out, shall remain in the adjusted cohort. CONDITION - To determine whether the District maintained appropriate documentation to support adjustments to the 4-year cohort and related high school cohort graduation rate, we requested District records to support the removal of 25 students selected from the 4,073 students removed from the 2024-25 fiscal year cohort graduation rate. Our review disclosed that District records did not comply with the Federal documentation requirements for the removal of 6 students from the cohort. While the District withdrawal forms for the 6 students typically indicated the students’ intention at the time of withdrawal, District records did not demonstrate that the students eventually enrolled in another school or program. Subsequent to our request in November 2025, school personnel obtained and provided to us confirmations that 4 of the 6 students enrolled in educational programs that would culminate in the award of a regular high school diploma. CAUSE - District personnel indicated that they were unaware of the Federal requirements to obtain and maintain documentation from the receiving school to confirm a student's enrollment and remove the student from the District's cohort count. EFFECT - While the noncompliance did not have a direct impact on funding, without the required documentation supporting adjustments to the 4-year cohort and related graduation rate calculation, the District cannot demonstrate that the calculation was accurate, limiting the usefulness of the graduation rate as an academic indicator. RECOMMENDATION - The District should enhance procedures to ensure that required documentation supporting adjustments to the 4-year cohort and related graduation rate calculation is obtained before adjustments are made. Such enhancements should include appropriate training and monitoring to ensure that the required documentation is maintained and supports that all students removed from the cohort graduation rate were removed for the reasons allowed by Federal requirements. DISTRICT RESPONSE - Miami-Dade County Public Schools (M-DCPS) adheres to Section 1003.23, Florida Statutes, as it pertains to withdrawal of all students enrolled in the District. Based on the DOE's Comprehensive Management Information System Automated Student Attendance Recordkeeping System Handbook: A withdrawal is official when one or more of the following occurs: 1. A parent or legal guardian notifies the school that the child is permanently leaving the school to enroll in another school or in home education. 2. A request for the student's school record is received from a public or private school, in- or out-of-state, in which the student is enrolled or plans to enroll. 3. The student has died. 4. The student transferred to a prison or juvenile facility. The following withdrawal procedures are in place for scenarios where a student needs to be removed from the cohort due to emigration: 1. The registering parent notifies the school, in person, that the student is withdrawing because of having to leave the country. 2. The registrar validates the individual requesting to withdraw the student is the registering parent/legal guardian. 3. The registrar goes to the Student Information screen and inputs Code W3B under the transaction code, and inputs in the School Location line, FLOR or out of Florida identifier. 4. The registrar complete the Notice of Withdrawal/Transfer screen in DSIS by inputting the New School Name, New School Address, (City, State, Country), and phone numbers in addition to the out of Florida identifier (FLOR). 5. The registrar prints the Notice of Withdrawal/Transfer screen and the registering parent signs and dates the document. 6. The registrar provides the registering parent with a copy of the signed Notice of Withdrawal/Transfer screen and keeps a copy of the documentation in the student's cumulative folder (CUM). Upon further review, the District examined the Every Student Succeeds Act High School Graduation Rate Non-Regulatory Guidance. The guidance indicates that for students who leave the country, documentation of withdrawal may include the parent's signed confirmation indicating the student is departing the United States. The District's current procedure requiring a parent or guardian signature on the PF15 aligns with this guidance and reflects the parent's formal acknowledgement that the student is leaving the country and no longer enrolled in the District. The District's withdrawal procedures strictly adhere to the Florida Department of Education (FDOE) Automated Student Attendance Recordkeeping System Handbook. Per State protocol, a withdrawal is deemed official when a parent or legal guardian notifies the school that the child is leaving to enroll in another school. M-DCPS considers the parent's signed acknowledgment at the point of withdrawal as official documentation of a change in status, rather than a mere statement of "intent". While the District followed established State recordkeeping protocols, we recognize the Auditor General's emphasis on the additional evidentiary requirements found in Title 20, Section 7801(25), United States Codes. To address the variance between State and Federal requirements, the District will consult with the Florida Department of Education to seek clarification and work toward reconciling State withdrawal codes with Federal graduation cohort documentation standards.