Finding Text
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 a educational program that culminates in the award of a regular high school diploma.
Context: Exceptions were identified in two of the sixteen students sampled.
Questioned Costs: None.
Cause: The District did not maintain adequate documentation to support the removal of a student from the
regulatory adjusted 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 other cohort codes. Subsequently the District should assist school sites
in developing the record retention process to ensure documentation is available upon request.
Views of Responsible Officials: The district will develop a process for properly accounting for and documenting
when a student is taken from the regulatory-adjusted cohort. In addition, formal training will be provided to both
Counselors and site Guidance Technicians on the manner in which to implement the developed process in order to
ensure that documentation is available upon request. This will be provided prior to May of 2024.