Finding 1166281 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-23
Audit: 377357
Auditor: NIGRO & NIGRO PC

AI Summary

  • Core Issue: The District failed to keep written documentation proving that a student transferred to another school or program, which is necessary for calculating graduation rates.
  • Impacted Requirements: According to 34 CFR, section 200.19(b), the District must maintain official documentation for students removed from the adjusted cohort to ensure accurate graduation rate calculations.
  • Recommended Follow-Up: The District should establish better controls for documenting student removals from the adjusted cohort and ensure all necessary documentation is properly maintained.

Finding Text

Criteria: 34 CFR, section 200.19(b) states, in part: High schools – (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regarding reporting and determining AYP, respectively, each State must calculate a graduation rate, defined as follows, for all public high schools in the State: (i) (A) A State must calculate a “four year adjusted cohort graduation rate,” defined as the number of students who graduate in four years with a regular high school diploma divided by the number of students who form the adjusted cohort for that graduating class. (B) For those high schools that start after grade nine, the cohort must be calculated based on the earliest high school grade. (ii) The term “adjusted cohort” means the students who enter grade 9 (or the earliest high school grade) and any students who transfer into the cohort in grades 9 through 12 minus any students removed from the cohort. (A) The term “students who transfer into the cohort” means the students who enroll after the beginning of the entering cohort's first year in high school, up to and including in grade 12. (B) To remove a student from the cohort, a school or LEA must confirm in writing that the student transferred out, immigrated to another country, or is deceased. (1) 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. (2) A student who is retained in grade, enrolls in a General Educational Development (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.Condition: During our review of the District’s Title I program, we noted that the District did not maintain written documentation supporting that a student had enrolled in another school or in an education program that culminates in the awarding of a regular high school diploma. The District is required to maintain official written documentation supporting that a student has enrolled in another school or in an educational program that culminates in the awarding of a regular high school diploma. A student who is retained in-grade or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rates and must remain in the adjusted cohort. Cause: The District did not maintain adequate documentation to support the removal of a student from the regulatory adjusted cohort.Effect: We were unable to determine whether the District implemented policies and procedures for documenting the removal of students from the regulatory adjusted cohort. Questioned Costs: NoneContext: The CDE uses the student-level data maintained in CALPADS to calculate the four-year adjusted cohort graduation rate for all LEAs in the state. We selected nine students who were identified in CALPADS as transfer students who withdrew from the District. The District was unable to provide any written documentation to confirm that one of these students transferred out of the District and emigrated to another county or enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Recommendation: We recommend that the District implement appropriate controls necessary for documenting the removal of students from the regulatory adjusted cohort, and ensure that the supporting documentation is maintained. Views of Responsible Officials: The District agrees with the auditor’s recommendation as stated above. The District acknowledges that it can be challenging to obtain documentation for students who leave the District without notification or formally withdrawing.

Corrective Action Plan

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.

Categories

Reporting

Other Findings in this Audit

  • 1166280 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $1.11M
10.553 SCHOOL BREAKFAST PROGRAM $1.07M
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $996,293
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $877,129
10.555 NATIONAL SCHOOL LUNCH PROGRAM $465,765
17.259 WIOA YOUTH ACTIVITIES $360,590
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $350,120
84.027 SPECIAL EDUCATION GRANTS TO STATES $346,220
12.000 JUNIOR RESERVE OFFICERS' TRAINING CORPS $314,601
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $161,463
10.558 CHILD AND ADULT CARE FOOD PROGRAM $98,974
93.600 HEAD START $91,103
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $87,681
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $79,843
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $30,750
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $15,157