Finding Text
Finding 2024-006: Annual Report Card, High School Graduation Rate (50000)
Repeat Finding? This is a repeat of Finding 2023-008.
Program Identification:
Federal Agency: U.S. Department of Education
Pass‐through Entity: California Department of Education
Program Names: Title I, Part A Grants:
Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010)
Criteria: ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)))
require a local educational agency to have official written documentation that a student enrolled in another school or
in an educational program that culminates in the award of a regular high school diploma in order to remove a student
from the graduation cohort. A student who is retained in grade, enrolled in a GED program, or leaves school for any
other reason may not be counted has having transferred out for the purpose of calculating graduation rate and must
remain in the adjusted cohort.
Condition: During our testing of compliance and controls over the graduation cohort, we identified two instances in
which the District was unable to provide supporting documentation to demonstrate that the students enrolled in another
school or in an educational program that culminates in the award of a regular high school diploma.
Context: Exceptions were identified for two of the four students sampled.
Questioned Costs: None.
Cause: Lack of review process to ensure that when a student is removed from the graduation cohort proper
documentation is obtained and maintained to support the student’s removal from the graduation cohort.
Effect: School site’s graduation rate will be overstated on the school site’s annual report card.
Recommendation: We recommend the District train school site staff on allowable documentation to remove students
from a graduation cohort as well as regarding other cohort codes. Subsequently the District should assist school sites
in developing the record retention process to ensure documentation is available upon request. Lastly, the District
should conduct an audit over pupils who have been historically removed from the graduation cohort and ensure that
proper documentation is on file to support their removal. If documentation does not exist, then those pupils codes
should be revised accordingly.
Views of Responsible Officials: The District acknowledges the finding and is committed to strengthening controls
over graduation cohort documentation. To address this, we will provide targeted training for school site staff on proper
cohort coding, allowable documentation, and compliance requirements. Additionally, we will implement a
standardized review process to ensure that all student cohort removals have appropriate supporting records and are
retained in a centralized system for audit purposes.
To further enhance compliance, the District will conduct periodic internal audits to verify the accuracy of past and
future cohort removals, updating records as necessary. Clear procedural guidelines will be established, and a
designated compliance team will oversee adherence to these protocols. These corrective actions will ensure accurate
graduation reporting and prevent recurrence of this issue