Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Title I Grants to Local Educational Agencies
Assistance Listing Number: 84.010
Federal Award Identification Number and Year: S010A210020 S010A220020
S010A230020 S010A220020
S010A210020 S010A220020
S010A230020
Pass-Through Agency: Maryland Department of Education (MSDE)
Pass-Through Number(s): 221499-01 231095-01
241282-01 231255-01
232028-01 231992-01
241671-01
Award Period: 7/1/2021–9/30/2023 7/1/2022–9/30/2024
7/1/2023–9/30/2024 7/1/2022–9/30/2024
3/1/2023–9/30/2023 3/1/2023–9/30/2024
7/1/2023–9/30/2024
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 the 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/Context:
For six out of eighteen samples tested, the Board did not maintain documentation to support the students’ withdrawal and/or evidence of the school’s review and approval of the student’s withdrawal that was reported to Maryland State Department of Education (MSDE). MSDE requires the Board to provide data for students that no longer attend a school in the district. The data is used to determine if the Board's graduation rate is affected because of the student’s departure.
Questioned costs: Undeterminable.
Cause:
The Board did not retain documentation supporting student withdrawal codes as required by the grant.
Effect:
The Board's graduation rate may be improperly calculated if the data provided to the State is inaccurate.
Repeat Finding: Yes, refer to prior year finding 2023-004.
Recommendation:
We recommend that the Board continue with established policies and procedures implemented in October 2023 to ensure that it obtains documentation to support student withdrawals and that this documentation is available for audit purposes.
Views of responsible officials:
There is no disagreement with the audit finding.