Audit 397689

20 USC 6311(h)(2)(C) states the State educational agency shall ensure that each local educational agency collects appropriate data and includes in the local educational agency’s annual report the information described in paragraph (1)(C), disaggregated in the same manner as required under such paragraph. 20 USC 6311(h)(1)(C)(iii)(II) provides, each State report card shall include high school graduation rates, including four-year adjusted cohort graduation rates and, at the State’s discretion, extended-year adjusted cohort graduation rates for all students and disaggregated by each of the subgroups of students, as defined in 20 USC 6311(c)(2), homeless status, and status as a child in foster care. 20 USC 7801(25)(C) states, in part, the term “transferred out” means that a student, as confirmed by the high school or local educational agency has transferred to (I)another school from which the student is expected to receive a regular high school diploma; or (II)another educational program from which the student is expected to receive a regular high school diploma or an alternate diploma. The confirmation of a student’s transfer to another school or educational 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. 20 USC 7801(25)(C) states, in part, the term “transferred out” means that a student, as confirmed by the high school or local educational agency has transferred to (I)another school from which the student is expected to receive a regular high school diploma; or (II)another educational program from which the student is expected to receive a regular high school diploma or an alternate diploma. The confirmation of a student’s transfer to another school or educational 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. Due to deficiencies in internal policies and procedures, the Academy erroneously withdrew two out of seven students (28%) from their FY25 Graduation Cohort Report without the required documentation. Failure to have the appropriate controls in place may result in reporting students incorrectly on the cohort reports. The Academy should maintain the appropriate documentation to support withdrawals and also review the graduation cohort reports for errors.

34 C.F.R. § 299.5(a) states, [a local educational agency (LEA)] receiving funds under an applicable program listed in paragraph (b) of this section may receive its full allocation of funds only if the [state educational agency (SEA)] finds that either the combined fiscal effort per student or the aggregate expenditures of State and local funds with respect to the provision of free public education in the LEA for the preceding fiscal year was not less than 90 percent of the combined fiscal effort per student or the aggregate expenditures for the second preceding fiscal year. 34 C.F.R. § 299.5(b) states, in part, this subpart is applicable to Title I, Part A. In Ohio, the Ohio Department of Education and Workforce (ODEW) prepares the calculation of combined fiscal effort per student using information provided by the LEA. ODEW’s ESEA Maintenance of Effort Handbook states, in part, the [ODEW] Office of Federal Programs (OFP) uses the EMIS Final Student Reporting Period S for both Traditional and Community Schools (student FTE) and EMIS Period H (fiscal) data reported by LEAs for the Maintenance of Effort (MOE) determination. EMIS data submitted by LEAs is pulled into the Maintenance of Effort (MOE) module which calculates MOE using two methods – per pupil expenditures and aggregate expenditures. Fiscal year 2025 allocations are affected by the MOE calculation performed in fiscal year 2024 which compares fiscal year 2024 data to fiscal year 2023 data. Pursuant to Ohio Rev. Code § 3301.0714, schools must enter data concerning the enrollment and attendance of their students into EMIS, which is used by all schools to enter and review student enrollment and demographic data. Ohio Rev. Code § 3314.08(B) requires the governing authority of each community school to annually report the number of enrolled students in the community school. Part 2.1 of ODEW’s Fiscal Year 2024 EMIS Manual states, in part, if a student graduates after the last day of the prior school year but before July 1, the withdrawal information can be reported during the End of Year Student (S) Collections; however, if the withdrawal information is not reported during the Final Student (S) Collections, then it must be reported during the following year’s Beginning of Year Student (S) Collections. Part 2.4 of ODEW’s Fiscal Year 2024 EMIS Manual states, in part, students who have completed course requirements for credit toward graduation and have passed the appropriate statewide assessments required for graduation are required to be reported with a withdrawal code of “99”. Due to deficiencies in policies and procedures over reviewing EMIS data, for fiscal year 2024, three of ten students (30%) tested graduated prior to fiscal year 2024 but the Academy failed to remove them from the EMIS system and reported FTEs to ODEW for the students. As a result, ODEW used inaccurate student FTE information to calculate MOE. Failure to submit accurate student FTE information to ODEW could result in a failure to maintain fiscal effort in which case ODEW would be required to reduce the Academy’s Title I allocation. The Academy should implement controls over EMIS reporting to ensure all graduated students are properly withdrawn from the EMIS system and ODEW uses accurate information to calculate MOE.

2 CFR § 3474.1 provides that the Department of Education (ODE) adopts the Office of Management and Budget (OMB) guidance in 2 CFR part 200. Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the ODE, except as otherwise noted in that section. 2 CFR § 200.303 states a recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Due to deficiencies in internal policies and procedures, the Academy did not approve three out of six (50%) of invoices that were for allowable costs and activities prior to being paid. Failure to have the appropriate controls in place may result in the Academy using federal funds for unallowable costs or activities. The Academy should develop internal control policies over Federal awards to help ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.