Finding Text
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 three 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 six 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: Education and Support Services has adopted a written policy for
Adjusted Cohort Graduation Rate procedures to ensure all supporting documentation for
students removed from the cohort is effort includes personnel in State and Federal Programs,
Technology Information
Systems (TIS), Student Records, and School Site personnel.