Finding Text
2023-002 Special Tests: Graduation Cohort
Federal Agency: U.S. Department of Education
Federal Program Name: Title I
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: A010A200020 and fiscal years 2019-2022
Pass-Through Agency: Maryland State Department of Education
Pass-Through Number(s): 200091, 211083, 221498, 231248, 201469, 211311, 221770, 231256,
201704, 211289, 221674, 231035
Award Period (s): Fiscal years 2019-2022
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
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 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: City Schools did not obtain and/or maintain documentation to support students’ the withdrawal code reported to Maryland State Department of Education (MSDE). MSDE requires City Schools to provide data for students that no longer attend a school in the district. The data is used to determine if City Schools’s graduation rate is affected because of the student’s departure.
We identified 3 students whose withdrawal code was not supported by documentation for more than a year after the student’s departure from the district. 2 of the 3 students, 2 students attended other schools and 1 student no longer lived in the United States. In all 3 errors, the student was identified as reported as attending a school within the district without adequate documentation
Questioned costs: None
Context: For 2 out of 40 students tested, City Schools did not obtain documentation to support the student’s transfer to another school prior to the auditor’s inquiry. The school reported that student as attending another school without documentation the transfer.
For 1 out of 40 students tested, the student no longer lived in the United States and did not attend school for school years 2019-2020 and 2020-2021. The school reported the student as attending school for both school years before learning that the student was no longer in the country.
Cause: City Schools did not consistently follow the established procedures related to student withdrawal codes.
Effect: MSDE data was not correct and City Schools’ graduation rate may be incorrect.
Repeat Finding: No
Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained to support compliance with grantor’s requirements.
Views of responsible officials: There is no disagreement with the audit finding.