FAC Explorer

Finding 614005 (2022-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 32371
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Boston Public Schools failed to provide required documentation for 9 out of 60 students removed from graduation cohorts, risking inaccurate graduation rate reporting.
  • Impacted Requirements: Compliance with federal regulations on reporting graduation rates and maintaining effective internal controls over student data.
  • Recommended Follow-Up: BPS management should reinforce documentation requirements and monitor processes for student withdrawals to ensure compliance and accuracy.

Finding Text

Finding number: 2022 003 Federal agency: U.S. Department of Education Pass through agency: Massachusetts Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control and Compliance over Annual Report Card, High School Graduation Rate Prior Year Finding: Yes 2021 002 Type of Finding: Material Weakness Criteria Beginning with annual report cards providing assessment results for the 2010?2011 school year, a State educational agency (SEA) and its local education agencies (LEAs) must report graduation rate data for all public high schools at the school, LEA, and State levels using the 4 year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i) (iv)). Additionally, SEAs and LEAs must include the 4 year adjusted cohort graduation rate (which may be combined with an extended year adjusted cohort graduation rate or rates) in adequate yearly progress (AYP) determinations beginning with determinations based on assessments administered in the 2011?2012 school year. Graduation rate data must be reported both in the aggregate and disaggregated by each subgroup described in 34 CFR section 200.13(b)(7)(ii) using a 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, 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. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards 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. Condition For 9 of 60 students removed from their respective cohorts in the Student Information Management System (SIMS) selected for testing, the City of Boston Public Schools (BPS) could not provide any official written documentation that the student emigrated to another country, is deceased, or is enrolled in another school or in an education program that culminates in the award of a regular high school diploma. Cause This appears to be due to insufficient review of supporting documentation before removal of students from the adjusted cohort graduation rate. Effect BPS is potentially misstating the number of students in the adjusted cohorts used by the Commonwealth of Massachusetts to determine the 4 year adjusted cohort graduation rate. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should re familiarize and re enforce the requirements with staff related to the removal of students from the adjusted cohorts used to determine the 4 year adjusted cohort graduation rate and the policies and procedures to obtain and monitor official written documentation of student transfers required to remove students from their respective cohort. View of Responsible Officials from the Auditee Between April and June 2022, the district contracted with Ernst and Young to complete a review of withdrawal processes and make recommendations to improve monitoring and internal audit processes. In August 2022, the district formed a student withdrawal working group, which created a process memo to support the appropriate withdrawal process for students in grades 9 12. At the August Management and Operations Institute, the student withdrawal working group was able to communicate and train school leaders and their administration on the appropriate withdrawal processes for students. Throughout the fall and winter, the student withdrawal working group has been monitoring the number of students withdrawn from the district; reviewing associated documentation of the withdrawal; and working with school leaders and school administration both at the central office level as well as through the liaisons and leaders within the regional structure to upload appropriate withdrawal documentation or update withdrawal codes to reflect the evidence associated with each student?s withdrawal case.

Categories

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 37561 2022-001
    Material Weakness
  • 37562 2022-002
    Significant Deficiency
  • 37563 2022-003
    Material Weakness Repeat
  • 37564 2022-004
    Material Weakness
  • 37565 2022-005
    Significant Deficiency
  • 37566 2022-006
    Significant Deficiency
  • 37567 2022-005
    Significant Deficiency
  • 37568 2022-006
    Significant Deficiency
  • 37569 2022-005
    Significant Deficiency
  • 37570 2022-006
    Significant Deficiency
  • 37571 2022-005
    Significant Deficiency
  • 37572 2022-006
    Significant Deficiency
  • 37573 2022-005
    Significant Deficiency
  • 37574 2022-006
    Significant Deficiency
  • 37575 2022-007
    Significant Deficiency
  • 614003 2022-001
    Material Weakness
  • 614004 2022-002
    Significant Deficiency
  • 614006 2022-004
    Material Weakness
  • 614007 2022-005
    Significant Deficiency
  • 614008 2022-006
    Significant Deficiency
  • 614009 2022-005
    Significant Deficiency
  • 614010 2022-006
    Significant Deficiency
  • 614011 2022-005
    Significant Deficiency
  • 614012 2022-006
    Significant Deficiency
  • 614013 2022-005
    Significant Deficiency
  • 614014 2022-006
    Significant Deficiency
  • 614015 2022-005
    Significant Deficiency
  • 614016 2022-006
    Significant Deficiency
  • 614017 2022-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $141.16M
21.027 Coronavirus State and Local Fiscal Recovery Funds $90.35M
84.425 Education Stabilization Fund $52.13M
21.019 Coronavirus Relief Fund $37.76M
84.010 Title I Grants to Local Educational Agencies $32.74M
10.555 National School Lunch Program $29.43M
14.267 Continuum of Care Program $29.00M
21.023 Emergency Rental Assistance Program $23.84M
84.027 Special Education_grants to States $19.37M
14.231 Emergency Solutions Grant Program $15.08M
97.067 Homeland Security Grant Program $10.22M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4.43M
14.218 Community Development Block Grants/entitlement Grants $3.44M
84.367 Improving Teacher Quality State Grants $3.14M
14.889 Choice Neighborhoods Implementation Grants $2.50M
32.009 Emergency Connectivity Fund Program $2.42M
84.365 English Language Acquisition State Grants $2.15M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $2.14M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.91M
84.424 Student Support and Academic Enrichment Program $1.53M
93.053 Nutrition Services Incentive Program $1.46M
84.048 Career and Technical Education -- Basic Grants to States $1.29M
10.559 Summer Food Service Program for Children $1.15M
14.905 Lead Hazard Reduction Demonstration Grant Program $875,418
84.287 Twenty-First Century Community Learning Centers $798,800
84.173 Special Education_preschool Grants $705,763
10.582 Fresh Fruit and Vegetable Program $589,666
84.002 Adult Education - Basic Grants to States $493,394
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $461,145
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $434,221
16.034 Coronavirus Emergency Supplemental Funding Program $387,065
20.616 National Priority Safety Programs $330,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $327,657
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $327,115
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $230,558
16.741 Dna Backlog Reduction Program $228,189
14.241 Housing Opportunities for Persons with Aids $198,525
94.016 Senior Companion Program $180,387
14.401 Fair Housing Assistance Program_state and Local $179,360
47.076 Education and Human Resources $178,788
14.248 Community Development Block Grants_section 108 Loan Guarantees $151,694
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $139,975
97.042 Emergency Management Performance Grants $136,689
94.002 Retired and Senior Volunteer Program $134,065
84.196 Education for Homeless Children and Youth $133,025
93.052 National Family Caregiver Support, Title Iii, Part E $128,466
97.106 Securing the Cities Program $117,605
16.588 Violence Against Women Formula Grants $116,980
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $115,958
16.838 Comprehensive Opioid Abuse Site-Based Program $99,654
10.649 Pandemic Ebt Administrative Costs $82,855
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $77,511
97.047 Pre-Disaster Mitigation $75,000
45.149 Promotion of the Humanities_division of Preservation and Access $64,064
12.900 Language Grant Program $62,353
45.301 Museums for America $58,423
16.817 Byrne Criminal Justice Innovation Program $54,978
97.044 Assistance to Firefighters Grant $31,952
97.039 Hazard Mitigation Grant $29,550
14.261 Homeless Management Information Systems Technical Assistance $25,333
45.024 Promotion of the Arts_grants to Organizations and Individuals $22,500
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $22,337
10.331 Food Insecurity Nutrition Incentive Grants Program $18,005
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $17,540
16.015 Missing Alzheimer's Disease Patient Assistance Program $12,177
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $9,776
16.833 National Sexual Assault Kit Initiative $9,758
14.U00 Brownsfields Economic Development Initiative $7,379
20.600 State and Community Highway Safety $5,364
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $2,777
84.411 Investing in Innovation (i3) Fund $1,836
20.205 Highway Planning and Construction $1,634
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,529