Finding 386907 (2023-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The School District failed to keep proper documentation for 8 out of 10 student transfers, risking inaccurate graduation rate reporting.
  • Impacted Requirements: Compliance with OMB’s Uniform Guidance and PDE regulations requires written proof of student transfers to ensure accurate cohort data.
  • Recommended Follow-Up: Implement stronger policies for maintaining documentation, including reminders and audits, to ensure compliance by the end of the 2024 school year.

Finding Text

2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE– SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Condition: In our testing for compliance with Special Tests and Provisions - Annual Report Card, High School Graduation Rate, we noted that School District personnel did not maintain appropriate written documentation to support the transfers of 8 out of 10 sampled students from the adjusted 2019-2020 cohort. Funding for this program is from the Pennsylvania Department of Education (PDE). Criteria: Per the OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B), to remove a student from the cohort, the local educational agency (LEA) must confirm in writing that the student transferred out, emigrated to another country, or is deceased. The 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. According to the PDE’s guide for reporting the Graduation, Dropout and Cohort Data Set, an LEA may not consider a student a transfer unless it knows with certainty that the student has enrolled in another secondary educational institution that offers a regular high school diploma. Effect: Failure to maintain appropriate written documentation to support the removal of students from the 2019-2020 cohort may cause an inaccurate reporting of the 2022-2023 graduation rate and noncompliance with federal and state regulations. Cause: School District personnel stated that they either did not maintain documentation because several years had passed since the students left or they only received verbal confirmation of the students’ transfers. Recommendation: School District management should develop written policies and procedures which require that personnel maintain the appropriate written documentation to support student transfers in accordance with the above criteria to ensure an accurate cohort graduation rate. Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024. Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092

Corrective Action Plan

Corrective Action Plan Finding number 2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Contact Person - Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092 Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from the school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024.

Categories

Reporting Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 386908 2023-001
    Significant Deficiency Repeat
  • 963349 2023-002
    Significant Deficiency
  • 963350 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Arpa Esser III $175.12M
84.010 Title I Grants to Local Educational Agencies $161.94M
84.425 Crrsa Esser II $63.74M
84.425 Arpa Esser 7% $62.65M
93.600 Head Start $48.91M
84.027 Special Education_grants to States $47.31M
10.553 School Breakfast Program $16.97M
84.425 Geer II Iu26 $12.67M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $10.55M
84.367 Supporting Effective Instruction State Grants $9.12M
84.425 Arpa Esser Set Aside Iu 025 $7.27M
84.048 Career and Technical Education -- Basic Grants to States $6.05M
10.558 Child and Adult Care Food Program $5.69M
93.558 Temporary Assistance for Needy Families $3.76M
10.555 National School Lunch Program $2.91M
84.365 English Language Acquisition State Grants $2.80M
84.425 Education Stabilization Fund $2.51M
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $1.85M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1.63M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.11M
84.425 Arp Homeless Children Youth II $1.09M
84.425 Eans II Non Public Assistance Program $1.07M
84.215 Fund for the Improvement of Education $858,492
12.002 Procurement Technical Assistance for Business Firms $848,732
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $599,113
84.425 Arpa Esser 2.5% $589,639
84.196 Education for Homeless Children and Youth $526,413
84.184 Safe and Drug-Free Schools and Communities_national Programs $453,730
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $394,278
84.013 Title I State Agency Program for Neglected and Delinquent Children and Youth $318,337
84.425 Geer Continuity of Education and Equity Grant $244,339
84.041 Impact Aid $224,563
84.425 Geer II Cte $214,013
84.425 Arp Homeless Children Youth I $124,098
10.582 Fresh Fruit and Vegetable Program $109,386
84.411 Investing in Innovation (i3) Fund $92,876
84.173 Special Education_preschool Grants $81,540
16.839 Stop School Violence $76,222
93.079 Pash Cares $66,558
16.710 Public Safety Partnership and Community Policing Grants $19,600
10.649 Pandemic Ebt Administrative Costs $5,950
84.425 Geer Atsi Sd $2,020
84.377 School Improvement Grants $0
84.424 Student Support and Academic Enrichment Program $0
84.425 Geer Special Ed Covid 19 $0
84.425 Continuity of Education and Equity Grant $0
84.425 Cares Pccd Health Safety $0
84.425 Statewide System of Support Iu 26 $0
21.019 Coronavirus Relief Fund $0
93.137 Community Programs to Improve Minority Health Grant Program $0
66.039 National Clean Diesel Emissions Reduction Program $0
84.366 Mathematics and Science Partnerships $0