Finding Text
Criteria: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23),(25))) require a local educational agency to have official written documentation that a student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma in order to remove a student from the graduation cohort. A student who is retained in grade, enrolled in a GED program, or leaves school for any other reason may not be counted has having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Condition: During our testing of compliance and controls over the graduation cohort, we identified two instances in which the District was unable to provide supporting documentation to demonstrate that the students enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Context: Exceptions were identified for two of the three students sampled. Questioned Costs: None. Cause: Lack of review process to ensure that when a student is removed from the graduation cohort proper documentation is obtained and maintained to support the student’s removal from the graduation cohort. Effect: School site’s graduation rate will be overstated on the school site’s annual report card. Recommendation: We recommend the District train school site staff on allowable documentation to remove students from a graduation cohort as well as regarding other cohort codes. Subsequently the District should assist school sites in developing the record retention process to ensure documentation is available upon request. Lastly, the District should conduct an audit over pupils who have been historically removed from the graduation cohort and ensure that proper documentation is on file to support their removal. If documentation does not exist, then those pupils codes should be revised accordingly. Views of Responsible Officials: The District recognizes the importance of maintaining accurate graduation cohort records and acknowledges the finding. The District is committed to improving procedures to ensure that all cohort removals are supported by appropriate documentation and meet applicable compliance requirements. To address this issue, the District will continue to provide guidance and training to school site staff regarding proper cohort coding practices, allowable supporting records, and documentation standards. In addition, the District will strengthen its review and retention processes to ensure that cohort adjustment documentation is consistently collected, properly reviewed, and maintained in an organized manner for audit purposes. The District will also conduct periodic internal reviews of cohort records to verify the accuracy of both historical and future student removals. Clear procedural expectations and oversight responsibilities will be established to support compliance, improve reporting accuracy, and reduce the risk of recurrence.