Finding 45765 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-17

AI Summary

  • Core Issue: The Organization is not maintaining proper documentation for students removed from the graduation rate cohort, leading to non-compliance with federal regulations.
  • Impacted Requirements: Documentation must support legitimate reasons for student removal, including transfers, death, or emigration, as outlined in 34 CFR section 200.19(b).
  • Recommended Follow-Up: Establish clear procedures to ensure all necessary documentation is collected and retained for cohort removals, in line with Louisiana Administrative Code requirements.

Finding Text

2022-002: Graduation Rate Cohort Documentation 84.010 - Title I - Grants to Local Education Agencies Criteria: The Organization must report graduation rate data for all public high schools at the school level using the 4-year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i)-(iv)). Only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating the 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school must confirm, in writing, that the student transferred out, emigrated to another country, or is deceased. Lycee is responsible for assigning exit codes to any student who leaves the Organization. Only specific exit codes are deemed legitimate reasons for leaving the Organization and will cause the leaver to not be included in the cohort?s graduation index calculations. These codes relate to death, transfers out of the state or country, transfers to non-public schools, transfers to home study/in-school private schooling, and transfers to Early College Admissions Programs. Specific documentation must be maintained in order for students to be considered legitimate leavers from the cohort. The Organization is also responsible for developing a system of internal controls to ensure the proper documentation is retained for all leavers of the cohort. Condition: While testing compliance and internal controls with respect to 34 CFR ?200.19(b), 2 of 5 leavers had exceptions to the required documentation set forth by the Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, ?611. The Organization does not have procedures in place to ensure adequate documentation is maintained to support the removal of students from a cohort. Universe/Population Size: The sample of cohort removals should be selected from a universe thatincludes all student that left the Organization due transferring to a diploma awarding school or program, death, or emigration to another country. Based on these requirements, the total universe is 21 students who are considered leavers of the cohort during the year ended June 30, 2022. This is also considered the population size. Sample Size: Based on sampling guidance for audits performed under the Uniform Guidance, a non-statistical sample of 5 leavers was selected for testing. Cause: The Organization has experienced turnover, which has resulted in inconsistency in the execution of the control and ensuring documentation is adequately maintained. Effect: The Organization is non-compliant with maintaining proper graduation rate cohort documentation. In addition, without proper internal controls over the graduation rate cohort process, appropriate levels of review may not occur, and therefore the Organization may not be complying with all of its responsibilities over Title I. Recommendation: The Organization should establish procedures at the program administration level to ensure appropriate documentation is obtained related to removal of students from a cohort in accordance with Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, ?611. Repeat Finding: No. View of Responsible Official: Management agrees and is concurrently making updates to our policies, procedures, and related control processes.

Corrective Action Plan

Lycee Francais de la Nouvelle-Orleans' (a nonprofit organization) (Lycee) respectively submits the following corrective action plan for the year ended June 30, 2022. RESPONSES TO FINDINGS: 2022-002: Graduation Rate Cohort Documentation U.S. Department of Education Response: We agree with the auditors' comments. We are concurrently making updates to our policies, procedures, and related control processes as well.

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 622207 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $602,891
84.425 Education Stabilization Fund - Esser II Formula - Covid $300,186
84.425 Education Stabilization Fund - Esser Iiieb Interventions - Covid $279,029
84.027 Special Education_grants to States $163,176
84.425 Education Stabilization Fund - Esser III Formula - Covid $153,827
32.009 Emergency Connectivity Fund Program $139,436
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $43,500
84.367 Improving Teacher Quality State Grants $37,093
84.010 Title I Grants to Local Educational Agencies $8,570
84.173 Special Education_preschool Grants $4,455
84.365 English Language Acquisition State Grants $4,129