Finding 585417 (2023-001)

Graduation Rate Cohort Documentation 84.010 Title I Basic Grant #28-23-T1-17 Questioned Costs: None. Criteria: The School System must report graduation rate data for all public high schools at the school level using the 4-year adjusted cohort rate under ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)). 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 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. The East Baton Rouge Parish School System is responsible for assigning exit codes to any student who leaves the School System. Only specific exit codes are deemed legitimate reasons for leaving the School System and will cause the leaver to not be included in the cohort’s graduation index calculations. Specific documentation must be maintained in order for students to be considered legitimate leavers from the cohort. The School System is also responsible for developing a system of internal controls to ensure the proper documentation is retained for all leavers of the cohort. Universe/ Population Size: The sample of cohort removals was selected from a universe that includes all high school students that left the School System based on exit codes. Based on these requirements, the total universe is 344 students who are considered leavers of the cohort. 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 40 leavers was selected for testing. Condition(s): In testing internal controls with respect to 34 CFR §200.19(b), 7 of 40 leavers had exceptions to the required documentation set forth by the compliance guidance. This rate of exception indicates that the School System does not have adequate internal control procedures in place to ensure that all documentation is maintained contemporaneously with the removal of the student to support the removal from a cohort. While the School System does have a process of obtaining monthly drop-out reports to monitor leavers from the cohorts at the program level, testing revealed that these listings were not complete with all exit codes and potential leavers. This created a deficiency in the internal control process in place, as there was lack of oversight over the documentation obtained for certain leavers. Cause: Individual high schools are responsible for maintaining documentation related to the removal of students. Monthly monitoring reviews of documentation was conducted to ensure adequately removal of the students from the cohort; however, some high schools did not report the students in the district data reporting system. Effect: Without the proper school reporting data process over the graduation rate cohort, documentation may not be properly retained, and therefore the School System may be noncompliant with the Graduation Rate Cohort component of the Title I program. Recommendation: The School System should establish procedures at the School and program administration levels to ensure appropriate documentation is obtained related to removal of students from a cohort in a timely manner. The School System should develop an internal control procedure which includes the periodic review of a complete listing of cohort removals at the program administration level. The School System should also emphasize the importance of appropriate documentation retention at the School level in a timely manner with the departure of students. We recommend that the documentation for leavers also be maintained and monitored at the program administration level to provide a level of accountability to the schools. View of Responsible Official: The finding will be resolved on January 31, 2024. Sandra Bethley, Ph.D., Executive Director of Federal Programs will be responsible for the resolution of the finding. Effective January 4, 2024, the leadership team of the Office of Federal Programs will supervise the Graduation Rate Cohort initiative for the East Baton Rouge Parish School System. A Graduation Rate Cohort team will be established. The Graduation Rate Cohort team will develop written procedures for identified school personnel and principals to follow. A contact person from each high school will be identified. A meeting will be conducted with identified school personnel to explain the criteria and procedures for maintaining documentation for students departing from the high schools. Failure to comply with the procedures will result in immobilizing schoolwide Title I funds.