Finding Text
2023-001 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: GT--0141
Known Questioned Cost Amount: $0
Prior Year Audit Finding: Yes, Finding 2022-002
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 the 2022-2023 school year, the District spent $2,103,331 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 for ensuring it complied with assessment system security requirements. Specifically, the District did not have the required written Test Security and Building Plans in place for all 29 schools we reviewed that administered the following standardized tests: Washington Access to Instruction and Measurement (WA-AIM), Smarter Balanced Assessments (SBA), World-Class Instructional Design and Assessment (WIDA), and Washington Comprehensive Assessment of Science (WCAS). We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
During the 2021-2022 school year audit, District staff did not fully understand OSPI’s requirement to document written Test Security and Building Plans. Staff thought that their process of training test coordinators and communicating the testing requirements to them was sufficient to comply with the requirement. Based on when the District received the prior year finding, the District did not have time to adjust its process for the 2022-2023 school year.
Effect of Condition
Without documented Test Security and Building Plans, the District cannot demonstrate it implemented and complied with OSPI’s assessment system security requirements for any of the four standardized tests it administered in the 2022-2023 school year.
Recommendation
We recommend the District improve its internal controls and establish policies and procedures to comply with OSPI’s assessment system security requirements. Specifically, the District should establish written Test Security and Building Plans for all standardized tests it will administer.
District’s Response
The Bellevue School District concurs with this finding. The District did not have a written Test Security and Building Plan (OSPI TSBP) for each school. For our corrective action, the District will create a SharePoint site to retain each school’s annual OSPI TSBP for all standardized state tests starting with the 2023-2024 school year. The District Manager of Data, Testing & Research will provide instructions, professional development, and guidance for each school. Each school’s OSPI TBSP will be retained on the SharePoint site. The District Manager of Data, Testing & Research will verify that each school complies. The Bellevue School District would like to highlight that upon receiving the final audit report for 2021-2022 school year in November 2023, the corrective actions were promptly initiated, with the necessary changes implemented by January 1, 2024.
Auditor’s Remarks
We thank the District for its cooperation throughout the audit and the steps it is taking to address these concerns. We will review the status of the District’s corrective action 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 34 CFR, Part 200, Title I – Improving the Academic Achievement of the Disadvantaged, Section 78 – Allocation of funds to school attendance areas and schools.
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.