Finding 1140449 (2024-001)

Finding: The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Special Tests and Provisions for Title I Grants to Local Educational Agencies contains requirements related to maintaining accurate high school graduation rates. In order to determine these rates, a local education agency (LEA) must report graduation rate data for all public high schools using the four-year adjusted cohort rate with graduation rate data being reported both in the aggregate and disaggregated by certain subgroups. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Testing revealed nine (9) of twenty-five (25) instances in which official written documentation for students’ removal from the adjusted cohort was incomplete or not retained. The Jefferson County Board of Education (the “Board”) did not adequately monitor its policies and procedures to ensure compliance with the Special Tests and Provisions requirements of the Title I Grants to Local Educational Agencies. As a result, the Board failed to adequately complete and retain official written documentation of students’ removals from the cohort, which may result in inaccurate high school graduation rates. Recommendation: The Board should adequately monitor the Title I Grants to Local Educational Agencies program to ensure that it complies with the Special Tests and Provisions cohort requirements used in determining high school graduation rates.