Finding Text
Finding Number: 2023-004
Prior Year Finding: No
Federal Agency: U.S. Department of Education
Federal Program: Title I, Part A
Assistance Listing: 84.010
Pass-Through Entity: Maryland State Department of Education
Pass-Through Award Number and Period: 201310-01 (7/1/19 – 9/30/21) 231095-01 (7/1/22 – 9/30/24)
211116-01 (7/1/20 – 9/30/22) 211303-01 (7/1/20 – 9/30/22)
221499-01 (7/1/21 – 9/30/23) 221769-01 (7/1/21 – 9/30/22)
Compliance Requirement: Special Test
Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance
Criteria or Specific Requirement
Compliance: Per ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))), in order 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. Control: Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context
For 26 out of 40 samples tested, the Board did not maintain documentation to support the students’ withdrawal and/or evidence of the school’s review and approval of the student’s withdrawal that was reported to Maryland State Department of Education (MSDE). MSDE requires the Board to provide data for students that no longer attend a school in the district. The data is used to determine if the Board's graduation rate is affected because of the student’s departure.
Questioned Costs
Undeterminable.
Cause
The Board did not retain documentation supporting student withdrawal codes as required by the grant.
Effect
The Board's graduation rate may be improperly calculated if the data provided to the State is inaccurate.
Recommendation
We recommend that the Board enhance its procedures and internal controls to ensure that it retains documentation to support student withdrawals and that this documentation is available for audit purposes.
Views of Responsible Officials
Management agrees with the finding.