Finding 400213 (2023-002)

Sedro-Woolley School District No. 101 September 1, 2022 through August 31, 2023 2023-002       The District’s internal controls were inadequate for ensuring compliance with federal Title I grant requirements for assessment system security. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: FPG--2035/0270366 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and reside in areas with high concentrations of children from low-income families. During fiscal year 2023, the District spent $1,142,212 in Title I program funds. Federal regulations require recipients to establish and maintain internal controls to ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. States, in consultation with school districts, must establish and maintain an assessment system that is valid, reliable and consistent with relevant professional and technical standards. States must have formal, well-documented policies and procedures to maintain test security and ensure that districts implement them for all standardized tests. The Office of Superintendent of Public Instruction (OSPI) provides templates for all districts to document their test security and building plans for each assessment they administer. OSPI also provides detailed guidance and manuals on test security. Description of Condition The District did not have adequate controls in place to ensure it complied with assessment system security requirements. Specifically, the District did not retain adequate records showing teachers attended required training or followed required security procedures before and after administering assessments to students. We consider this internal control deficiency to be a material weakness. Cause of Condition The District does not have a centralized or consistent process for collecting and retaining assessment security documents. Some buildings provide their documents to the Administration Coordinator to retain, while some buildings retain their own documents. In addition, the District has experienced turnover in the Administration Coordinator role that is responsible for overseeing assessment procedures. Due to this turnover, the Administration Coordinator did not adequately monitor each building during the audit period to ensure the District retained the required records. Additionally, the District experienced turnover in its special education department, which normally provides training for the Washington Access to Instruction and Measurement (WA-AIM) assessment. Effect of Condition The District could not demonstrate it followed assessment security requirements in accordance with its security plan and OSPI’s policies and procedures. Of the seven assessments we tested, the District lacked two training logs and the pre-assessment and post-assessment assurance forms for the WA-AIM assessment. Recommendation We recommend the District improve internal controls and follow established policies and procedures to comply with OSPI’s assessment system security requirements. Specifically, the District should retain the required forms to demonstrate it has complied with assessment security measures. District’s Response There was not clarity on who was in charge of organizing the training, Training Log and tracking of assessment security Pre/Post testing forms for the Wa-Aim, WIDA, Smarter Balanced Assessment, and WCAS. Moving Forward the following duties will be implemented: Special Education Director:  Responsible for organizing the training, and collecting the Training Log and Pre/post test security forms for any staff proctoring the Wa-AIM. MLL  Director:  Responsible for organizing the training at the beginning of each year, and collecting the Training Log and Pre/post test security forms for any staff proctoring the WIDA. District Assessment Coordinator with/ support of building principals:  Responsible for organizing the training, and collecting the Training Log and Pre/post test security forms for any staff proctoring the SBA and WCAS. Auditor’s Remarks We thank the District for its commitment to resolving this issue. We will follow up on the status of this finding during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 20 U.S. Code section 6311(b)(2)(B)(iii) requires state and local education agencies to establish and maintain valid and reliable assessment systems, consistent with relevant professional and technical standards.