Finding Text
Finding 2024‐001: Title I – Compliance Requirement for Cohort Graduation Rate Not Met (30000) (50000)
Assistance Listing #84.010—Title I, U.S. Department of Education, California Department of Education
Repeat Finding? No
Criteria: 34 CFR, section 200.19(b) states, in part:
High schools – (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regarding reporting
and determining AYP, respectively, each State must calculate a graduation rate, defined as follows, for all public high schools in the State:
(i) (A) A State must calculate a “four-year adjusted cohort graduation rate,” defined as the number of students who
graduate in four years with a regular high school diploma divided by the number of students who form the adjusted
cohort for that graduating class.
(B) For those high schools that start after grade nine, the cohort must be calculated based on the earliest high school
grade.
(ii) The term “adjusted cohort” means the students who enter grade 9 (or the earliest high school grade) and any
students who transfer into the cohort in grades 9 through 12 minus any students removed from the cohort.
(A) The term “students who transfer into the cohort” means the students who enroll after the beginning of the entering cohort's first year in high school, up to and including in grade 12.
(B) To remove a student from the cohort, a school or LEA must confirm in writing that the student transferred out,
immigrated to another country, or is deceased.
(1) 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.
(2) A student who is retained in grade, enrolls in a General Educational Development (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.
Condition: During our review of the District’s Title I program, we noted that the District did not maintain written
documentation supporting that a student has enrolled in another school or in an education program that culminates in the awarding of a regular high school diploma. The District is required to maintain official written documentation
supporting that a student has enrolled in another school or in an educational program that culminates in the awarding of a regular high school diploma. A student who is retained in-grade or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rates, and must remain in the adjusted cohort.
Context: The CDE uses the student-level data maintained in CALPADS to calculate the four-year adjusted cohort
graduation rate for all LEAs in the state. We selected eleven students who were identified in CALPADS as transfer
students who withdrew from the District. The District was unable to provide any written documentation to confirm
that two of these students transferred out of the District and emigrated to another county or enrolled in another school or in an educational program that culminates in the award of a regular high school diploma.
Effect/Questioned Costs: We were unable to determine whether the District implemented policies and procedures
for documenting the removal of students from the regulatory adjusted cohort. There are no questioned costs as a result of this finding.
Cause: The District did not maintain adequate documentation to support the removal of a student from the regulatory adjusted cohort.
Recommendation: We recommend that the District implement appropriate controls necessary for documenting the
removal of students from the regulatory adjusted cohort, and ensure that the supporting documentation is maintained.
Views of Responsible Officials: Dr. Ryan Gleason will work with the Educational Services Department to ensure
that we follow this procedure for all students moving forward. The student in question attended a residential treatment facility and was not tracked beyond that placement.