kids count every day 2015 oaep conference presented by: marnie a. carlisle, assistant chief deputy...
TRANSCRIPT
Kids Count Every Day
2015 OAEP Conference
Presented by:
Marnie A. Carlisle, Assistant Chief Deputy Auditor
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AgendaImportance of Data Quality
Results of Statewide Attendance Review
Common Errors
Statewide Recommendations
Community School Student Head Count
Tips for the Future
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Importance of Data Quality
• It is extremely important that ODE and schools have systematic and uniform data collection guidelines and an infrastructure to collect, produce, and report data that are accurate, reliable, and high quality.
• State and local EMIS personnel are critical to complying with this objective!
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Importance of Data Quality
• USDE’s Education Department General Administrative Regulations (EDGAR), codified in 34 CFR Part 76, require States to establish procedures for ensuring local schools comply with all compliance requirements.
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Importance of Data Quality
• The Ohio Consolidated Application to USDE requires that Ohio’s accountability system produce reliable and valid decisions.
• ODE has adopted various business rules to comply with this mandate.
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Role of the AOS
• Ohio Rev. Code § 117.11 requires AOS to audit State and all local governments.
• Per AICPA - audits are designed to determine whether financial statements are free of material misstatement.– Auditing more and/or searching for fraud
quickly becomes costly/inefficient.
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Role of the AOS
• The focus of an audit is on the accuracy of financial statement amounts, including the compliance with laws directly and indirectly affecting financial statement amounts.
• Though some statutory provisions require a deeper look at certain, non-financial compliance matters.
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Reporting Noncompliance: The dreaded Finding for
Recovery (FFR)• Ohio Rev. Code Section 117.28 authorizes the Auditor of State
to report a finding for recovery in audit reports when legal action may be appropriate to recover public money or property.
• Ohio Rev. Code Section 117.01 (C) defines public money as "any money received, collected by, or due a public official under color of office, as well as any money collected by any individual on behalf of a public office or as a purported representative or agent of a public office."
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Findings for Recovery• Under Ohio Rev. Code Sections 9.24(H)(3) and
117.28, a finding for recovery may exist when:
1. Public money has been illegally expended;
2. Public money that has been collected has not been accounted for;
3. Public money that is due has not been collected; or when
4. Public property has been converted or misappropriated
--- Here is how much you misspent. Pay it back!!!
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FFR – What did they do wrong?
• Did not maintain supporting documentation.
• Records support more was collected than was deposited in bank.
• Check written not for a proper public purpose.
• Pay raises implemented before effective date.
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Results of the 2013 AOS Statewide Review
The purpose of the review was to:
(1) Identify systemic, and possible duplicate, student attendance and enrollment practices among Ohio schools;
(2) Provide recommendations to the Ohio Department of Education (ODE) and Ohio General Assembly for making future policy and legislative improvements to Ohio’s accountability system; and
(3) Determine whether schools were scrubbing enrollment data.
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Results of the Statewide Review
• The final statewide report included findings related to school year 2010-11 student attendance and enrollment practices for select Ohio schools.
• AOS referred the schools with evidence of scrubbing to ODE for further investigation and recalculation of the school report cards and to the USDE IG’s Office.
• ODE investigated and reperformed testing for the scrubbing schools which led to further investigations by the Office of Professional Conduct and others.
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Results of the Statewide Review
Total Schools Tested
Total Districts Tested
Phase One (Interim Report dated October 4, 2012) 100 75
Phase Two (Interim Report dated October 23, 2012) 81 47
Phase Three (Final Report dated February 11, 2013) 102 no newCommunity Schools (Final Report dated February 11, 2013) 5 5Phase Three Other Schools (i.e., Tips) (Final Report dated February 11, 2013) 43 10
331 137
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Common Errors• Lack of up-to-date, written attendance
policies and due process– AOS identified systemic concerns regarding the
withdrawal of students due to truancy without court adjudication.
– Policies were incomplete, lacked clearly defined procedures for withdrawal, or contravened the clearly stated statutory due process proceedings for truant students.
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Common Errors• Maintaining Official Student Attendance
Records and AYP – The majority of schools maintain some supporting
documentation for breaks in enrollment.
– However, certain schools had a systemic lack of appropriate supporting documentation, causing concerns about school- or district-wide AYP determinations.
• AOS referred these schools to ODE and USDE IG.
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Common Errors• Old IRN’s no longer being used for the
originally approved purpose.
• Students transferred to local conversion school without parental or guardian consent.
• Lack of audit log documentation for e-SIS activity.
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Common Errors• No disciplinary/expulsion reports or
notices to support students withdrawn under the Expulsion code.
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Less Common,But Serious Errors
• Data manipulation:– Unsupported withdraw / re-enrollment– Unsupported grade changes “D ‘em up”– Unsupported retroactively-erased
absences– Zombie 12th graders– Unsupported changes to unexcused
absences during count week
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Statewide Recommendations
• Kids Count Every Day
– Base state funding on year-long attendance (i.e., the money follows the student in approximate real time).
– In response, the GA passed HB 59 requiring three count weeks during the school year (i.e., the last day of October, March and June).
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Statewide Recommendations
• Increase Oversight of Schools– Historically, ODE has relied heavily on the honor-
system for reporting.
– The legislature should reform the system by introducing independent oversight, expanding cross-checks and data monitoring throughout the school year.
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Statewide Recommendations
• Monitor Programs for At-Risk Students
– ODE should regularly monitor assigned IRNs to ensure schools are still using their approved IRN’s for the originally-intended purpose.
– ODE should also monitor transfers of at-risk students to alternative school programs to ensure transfers were made for legally valid reasons.
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Statewide Recommendations
• Increase EMIS Training– The General Assembly should develop minimum
continuing professional education requirements for school personnel using EMIS.
– Federal Accountability (i.e., report card) rules differ vastly from State Foundation Formula funding rules, which creates complexities.
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Statewide Recommendations
• State Monitoring of Student Withdrawals
– ODE should generate statewide school reports by student name and SSID number for key enrollment and withdraw codes.
– ODE should use these reports to perform analyses and cross-check the timing of student withdrawals and subsequent enrollments against EMIS data for completeness and accuracy.
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Statewide Recommendations
• Statewide Student Identifier (SSID) System
– The General Assembly should change existing law to allow ODE to have access to names of students and other personal information with necessary privacy protections consistent with Federal law.
– The statutory constraints impose significant costs on both ODE and users of the SSID system without additional privacy protections.
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Statewide Recommendations
• Document Student Withdrawals
– ODE should clarify its EMIS Manual and administrative rules to require (and not merely suggest) what types of evidentiary documentation must be maintained for each of the EMIS withdraw codes.
• Refer to chart in Section 2.1.1: Student Enrollment Overview in the 2014 EMIS Manual.
COMMUNITY SCHOOL STUDENT COUNT
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Community School Student Head Count
• AOS conducted a surprise count of 30 site-based brick and mortar schools on October 1, 2014.
• “Report on Community School Attendance Counts” available on AOS website under Audit Search.
• Not intended to be a financial or performance audit.
• 7 schools found to have unusually high variances – all DORPs.
• Provided policy recommendations to ODE, the legislature, and sponsors.
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Community School Student Head Count
• Recommended ODE update their manuals - AOS noted ODE’s EMIS and SOES Manuals had not been updated for the consolidation of these systems or the changes to EMIS-R.
• Recommended ODE and sponsors require accurate reporting of monthly FTE estimates to prevent overstatement of FTEs and prevent risk of loss of State Foundation dollars due to a community school’s closure.
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Community SchoolStudent Head Count
• Recommended ODE immediately fix the SOES flagging system which was not operational until November of 2014 and carefully review the errors identified to identify possible adjustments to earlier Foundation settlements.
• Recommended ODE and sponsors develop minimum standards for documentation and provide best practice tools to use as a guide in developing and monitoring blending learning curriculum.
– The Educational Plan in sponsor contracts should specifically describe these requirements – no boilerplate language.
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Community SchoolStudent Head Count
• Recommended sponsors actively review, especially near the beginning of the school year but also periodically throughout the year, community school enrollment and student attendance information.
• Sponsors should consider conducting unannounced, onsite FTE reviews and verify enrollment and attendance information against original source documents contained in the community school’s student files.
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Community SchoolStudent Head Count
• Temporary Assistance for Needy Families (TANF) – As part of maintaining certain benefits under the Federal TANF program and in lieu of working, students must remain enrolled in school.
• During our interviews of the Category 1 community schools, management explained students will frequently attend the bare minimum number of required hours to remain enrolled in school but fail to actively participate.
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Community SchoolStudent Head Count
• AOS used the results of the community school student head count to inform the legislative discussion about community school reform.
• AOS is supporting a number of legislative proposals enhancing accountability and transparency and preventing conflicts of interest.
• AOS also supports legislative proposals for fiduciary duty - right of action powers for sponsors and changes to truancy rules - aligning them more closely to the rules applicable to traditional schools.
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Tips for the Future
• Documentation is the key!
• Ensure policies are robust and current!
• Maintain a strong system of internal controls over EMIS collection and reporting, including e-SIS documentation!
• Trust but verify!
https://ohioauditor.gov/fraud/default.html
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Tips for the Future• Be prepared for your audit and plan ahead for SDC
closures:– Student Files
– Enrollment Reports
– Student count week records/reports
– Auditor access to E-SIS
– Federal Maintenance of Effort Reports
– High School Graduation Cohort Reports (including assignment of students to 9th Grade cohorts and any changes to existing cohorts)
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Questions
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Kids Count Every Day
Marnie A. Carlisle, Asst. Chief Deputy Auditor88 East Broad Street
Columbus, Ohio 43215
Presenter Phone: (800) 282-0370E-mail: [email protected]
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88 E. Broad St.Columbus, Ohio 43215
Phone: (800) 282-0370 Fax: (614) 466-4490E-mail: [email protected]
www.OhioAuditor.gov