Finding 963349 (2023-002)

2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE– SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Condition: In our testing for compliance with Special Tests and Provisions - Annual Report Card, High School Graduation Rate, we noted that School District personnel did not maintain appropriate written documentation to support the transfers of 8 out of 10 sampled students from the adjusted 2019-2020 cohort. Funding for this program is from the Pennsylvania Department of Education (PDE). Criteria: Per the OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B), to remove a student from the cohort, the local educational agency (LEA) must confirm in writing that the student transferred out, emigrated to another country, or is deceased. The 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. According to the PDE’s guide for reporting the Graduation, Dropout and Cohort Data Set, an LEA may not consider a student a transfer unless it knows with certainty that the student has enrolled in another secondary educational institution that offers a regular high school diploma. Effect: Failure to maintain appropriate written documentation to support the removal of students from the 2019-2020 cohort may cause an inaccurate reporting of the 2022-2023 graduation rate and noncompliance with federal and state regulations. Cause: School District personnel stated that they either did not maintain documentation because several years had passed since the students left or they only received verbal confirmation of the students’ transfers. Recommendation: School District management should develop written policies and procedures which require that personnel maintain the appropriate written documentation to support student transfers in accordance with the above criteria to ensure an accurate cohort graduation rate. Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024. Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092