Corrective Action Plans

The District will implement and formalize internal controls to ensure compliance with Title I, Part A graduation rate requirements related to the documentation of student removals from the four-year adjusted cohort. The District will revise and standardize procedures requiring official written documentation to be obtained and maintained whenever a student is reported as having transferred out, including confirmation that the student enrolled in another school. A meeting will be held in the next few days with MDUSD staff responsible for enrollment, withdrawals, and CALPADS reporting will receive training on cohort rules, documentation requirements, and record retention expectations to ensure consistent application across all sites. The District will also establish periodic monitoring and internal review processes to verify that supporting documentation is maintained prior to removing students from the cohort and that records align with CALPADS data submissions. Responsible Person for Corrective Action Plan Christina Filios, Assistant Director: Educational Services Aurelia Buscemi, Director of Enrollment Services Melissa Brennan, DIrector of Student Services Implementation Date of Corrective Action Plan January 5, 2026 - Coordinator of Fiscal Compliance and Reporting will meet with District Administrators to provide Audit Finding and provide guidance on procedures and set expectations. The District will monitor this process during Fiscal Year 2025-26.

Finding 2024-001 : Title I - Compliance Requirement for Cohort Graduation Rate Not Met (30000) (50000) Assistance Listing #84.010-Title I, U.S_ Department of Education, California Department of Education Response: Dr. Ryan Gleason will work with the Educational Services Department to ensure that we follow this procedure for all students moving forward. The student in question attended a residential treatment facility and was not tracked beyond that placement.

The deficiency occurred due to such documentation not received or forwarded from former personnel, and perhaps inadequate training by former personnel on compliance requirements. Mana Maoli plans to facilitate increased training for all personnel using debit cards to increase competency and compliance under 2 CFR § 200.302(b)(3) and 2 CFR § 200.403(g). Prior to and during the course of the FY2023 audit, Mana Maoli has already taken steps to train our personnel before issuing debit cards to better ensure staff understand the importance of receipt retention. Staff training focuses on how to implement and comply with federal documentation retention policies. As our new training protocols continue to be implemented, we will monitor for more comprehensive receipt retention and approvals. Mana Maoli’s management will evaluate and monitor the training’s effectiveness in producing more timely receipt retention. The responsible persons for training staff are Ruth Faioso Leau, Finance Manager, and Erik Yoshimoto, Office Manager. We will assess, monitor, and verify ongoing compliance for the second half of FY2025 and will have the new training protocol fully implemented by the first half of FY2026. Each quarter, the Finance Director will review a sample of federal disbursements that supporting documentation is maintained. The results will be reported to senior management. In conclusion, we will be taking steps immediately to address the findings in the audit. If additional information is needed, please contact Ruth Faioso Leau, Finance Director at faioso@manamaoli.org or 808-753-8746.

Corrective Action Plan Finding number 2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Contact Person - Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092 Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from the school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024.

Going forward, we plan to implement robust policies and procedures to ensure the proper documention is obtained and maintained for each student who is removed from the adjusted cohort. This will involve establishing clear guidelines for confirming student transfers and ensuring that official written documentation is obtained and retained accordingly. Furthermore, we will conduct trainging sessions for relevant staff members involved in the documentation process to ensure understanding and adherence to the updated procedures. THis will help prevent similar issues from arising in the future and contribute to the accuracy and reliability of our graduation rate calculations.

Graduation Rate Cohort Finding-Action Plan The finding will be resolved on January 31, 2024. Sandra Bethley, Ph.D., Executive Director of Federal Programs will be responsible for the resolution of the finding. Effective January 4, 2024, the leadership team of the Office of Federal Programs will supervise the Graduation Rate Cohort initiative for the East Baton Rouge Parish School System. A Graduation Rate Cohort team will be established. The Graduation Rate Cohort team will develop written procedures for identified school personnel and principals to follow. A contact person from each high school will be identified. A meeting will be conducted with identified school personnel to explain the criteria and procedures for maintaining documentation for students departing from the high schools. Failure to comply with the procedures will result in immobilizing schoolwide Title I funds.

Capistrano Unified School District's Education and Support Services has adopted a written policy for Adjusted Cohort Graduation Rate procedures to ensure all supporting documentation for students removed from the cohort is maintained. This collaborative effort includes personnel in State and Federal Programs, Technology lnfomrntion Systems (TIS), Student Records, and School Site personnel. The anticipated completion date is November 17, 2023. If you need additional information regarding the Corrective Action Plan, please contact Michael Gomez at (949) 234-9244.

Pupil Services and Attendance will continue to provide policy guidance on the LAUSD student withdrawal procedures through the following methods: 1. Pupil Services will maintain policies pertaining to attendance, enrollment, and withdrawals up to date. 2. Pupil Services published the Bulletin 4926.3 Enrollment, Attendance, and Withdrawal Policies and Procedures dated July 31, 2023, and is available for all LAUSD staff in the LAUSD E-Library. 3. Pupil Services has created a SharePoint available to all LAUSD staff employee where we have made available the Enrollment, Attendance, and Withdrawal Policies and Procedures Manual. This Manual outlines the LAUSD withdrawal policy and procedures for both elementary and secondary students along with the supporting documents necessary such as the Withdrawal Types and Reasons. This manual is also hyperlinked directly on Bulletin 4926.3 Enrollment, Attendance, and Withdrawal Policies and Procedures which is available for all LAUSD staff in the LAUSD E-Library. 4. Explore possible document validation for withdrawal reasons in the MiSiS Withdrawal Screen. 5. Pupil Services will provide training to the A-G Counselors on the Withdrawal Process and Procedures yearly by March 2024. 6. Pupil Services will provide training to the LAUSD Data team on accurate withdrawal procedures by December 2023. 7. Pupil Services will continue to offer training to the Pupil Services Lead Counselors through the informational sessions offered every other month. 8. Pupil Services will conduct a training on Withdrawal Process and Procedures to LAUSD Office personnel yearly by December 2023. 9. Pupil Services will continue provide ongoing reminders every other month through the Schoology communication platform regarding accurate enrollment, withdrawal procedures and the MYPLN Essential Tips training to support with the withdrawal process, codes, and documentation. 10. Pupil Services and Attendance will communicate with Region Administration on disseminating information to school-site designees with audit findings to participate in the MYPLN training on accurate enrollment and withdrawal codes during school year 2023-24. 11. Will obtain written acknowledgement for completion of the MYPLN Essential Tips training to support with the withdrawal process, codes, and documentation from the schools identified with audit findings by March 2024. Name: Elsy Rosado Title: Director, Pupil Services and Attendance Telephone: (213) 241-3844

Views of Responsible Officials, Corrective Action Plans, and Contact Information Pupil Services and Attendance will continue to provide policy guidance: 1. Provide ongoing reminders every other month through the Schoology communication platform regarding accurate enrollment, withdrawal codes and the MYPLN Essential Tips training to support with the withdrawal process, codes, and documentation. 2. Pupil Services and Attendance will continue to post resource tools such as the Certify Rules (this automated data validation tool allows users to efficiently identify data errors or omissions to improve the quality of student data in MiSiS) to support accurate enrollment and withdrawal procedures. 3. Pupil Services and Attendance will communicate with Local District Administration on disseminating information to school-site designees with audit findings to participate in the MYPLN training on accurate enrollment and withdrawal codes during school year 2023-24. 4. Pupil Services and Attendance will communicate with Office of Organizational Excellence to support in messaging the availability of the MYPLN training to support with the withdrawal process, codes, and documentation. 5. Will obtain written acknowledgement for completion of the MYPLN Essential Tips training to support with the withdrawal process, codes, and documentation from the schools identified with audit findings. Name: Elsy Rosado Title: Director, Pupil Services and Attendance Telephone: (213) 241-3844

Views of Responsible Official: P&N identified three students as not having exit documentation on file. All three of these students had withdrawn to transfer out of state to another school, but we never received paperwork from their new schools. Upon consultation with the Louisiana Department of Education, EQA has been instructed that in situations such as these, EQA is to re-code the students as dropouts. EQA made this adjustment, but due to the significant volume of transfers out, these three students were not re-coded appropriately. EQA will continue to diligently follow-up with each school?s principal and enrollment coordinator to verify that all transfer students for whom we don?t have evidence of enrollment in a new school are re-coded as drop-outs. We have put in process a system to review transfers on a quarterly basis. If we do not have evidence of enrollment in a new school, we re-code them as drop-outs.

Lycee Francais de la Nouvelle-Orleans' (a nonprofit organization) (Lycee) respectively submits the following corrective action plan for the year ended June 30, 2022. RESPONSES TO FINDINGS: 2022-002: Graduation Rate Cohort Documentation U.S. Department of Education Response: We agree with the auditors' comments. We are concurrently making updates to our policies, procedures, and related control processes as well.

Boston Public Schools (BPS) student withdrawal working group has been monitoring the number of students withdrawn from the district; reviewing associated documentation of the withdrawal; and working with school leaders and school administration both at the central office level as well as through the liaisons and leaders within the regional structure to upload appropriate withdrawal documentation or update withdrawal codes to reflect the evidence associated with each student?s withdrawal case. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov