Finding 1172470 (2025-005)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-05
Audit: 385643
Organization: Billings Public Schools (MT)
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: Six students were improperly removed from the graduation cohort, leading to inaccurate graduation rate data.
  • Impacted Requirements: The District must adhere to ESEA guidelines for removing students from the cohort, confirming valid reasons such as transfer or death.
  • Recommended Follow-Up: Ensure District staff follow ESEA guidance to accurately report graduation rates and prevent future errors.

Finding Text

Department of Education, passed through the State of Montana Office of Public Instruction, Federal Financial Assistance Listing 84.010, federal award numbers S010A240026 and S010240026, grant period 7/1/2024 – 9/30/2026 Title I Grants to Local Education Agencies Special Tests and Provisions Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Criteria – The District must report graduation rate data for all public high schools at the school, using the fouryear adjusted cohort rate. The Elementary and Secondary Education Act of 1965 (ESEA) sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)) states that to remove a student from the cohort, a District 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 District 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. Condition – During our testing of the removal of students from the adjusted cohort, it was noted that six students were removed for unallowable reasons. Cause – District staff were not following the guidance in ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)). Effect – Students were removed from the adjusted cohort due to dropout or lack of attendance, which are not allowable reasons to remove them from the adjusted cohort. This caused the graduation rate data to be inaccurate. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 13 students out of 55 students were selected for testing. Repeat Finding from Prior Year – No Recommendation – District staff should follow the guidance in ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)), to ensure graduation rate data is reported correctly. Views of Responsible Officials – There is no disagreement with the audit finding.

Corrective Action Plan

Department of Education, passed through the State of Montana Office of Public Instruction, Federal Financial Assistance Listing 84.010, federal award numbers S010A240026 and S010240026, grant period 7/1/2024 – 9/30/2026 Title I Grants to Local Education Agencies Special Tests and Provisions Finding Summary: During the auditor’s federal program testing of Title I, it was noted that several students were removed from the adjusted cohort for unallowable reasons. Corrective Action Plan: The District staff will follow the guidance in ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)), to ensure graduation rate data is reported correctly going forward. Responsible Individual: Laurie Kvamme, Chief Financial Officer Anticipated Completion Date: June 30, 2026

Categories

Special Tests & Provisions Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $4.57M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $3.19M
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $1.98M
10.553 SCHOOL BREAKFAST PROGRAM $796,911
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $471,756
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $397,106
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $380,624
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $321,025
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $241,543
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $188,473
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $180,503
84.425 EDUCATION STABILIZATION FUND $144,728
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $120,407
84.013 TITLE I STATE AGENCY PROGRAM FOR NEGLECTED AND DELINQUENT CHILDREN AND YOUTH $65,851
16.839 STOP SCHOOL VIOLENCE $53,590
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $47,433
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $42,075
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $40,215
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $38,144
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $12,449