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Meeting of the Board of Regents | April 2009

Wednesday, April 8, 2009 - 11:00pm

sed seal                                                                                                 

 

 

THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234

 

TO:

Subcommittee on Audits

 

FROM:

Theresa E. Savo 

 

SUBJECT:

Board of Regents Oversight – Financial Accountability

 

DATE:

April 8, 2009

 

STRATEGIC GOAL:

Goal 5

 

AUTHORIZATION(S):

 

 

SUMMARY

 

Issues for Discussion

 

              Two items are presented for discussion with the Members of the Subcommittee on Audits including:

 

  • Analysis of School District Financial Statements (Attachment II)
  • Completed Audits – Including a Summary of the Department’s Internal Audit Workgroup (Attachment III) and a status report on the Wyandanch and Roosevelt Union Free School Districts

 

Reason(s) for Consideration

 

              Update on Activities

 

Proposed Handling

 

              Discussion and Guidance

 

Procedural History

 

The information is provided to assist the Subcommittee in carrying out its oversight responsibilities related to audits of financial and reporting practices; performance audits or reviews; ethical conduct issues arising from audits; internal controls; and compliance with laws, regulations, and policies.

 

Background Information 

 

1.           Analysis of School District Financial Statements

The Office of Audit Services reviews the annual independent audits of all school districts in the State.  Information will be presented on the results of the review of the July 1, 2007 to June 30, 2008 financial statements. (Attachment II)

 

 2.           Completed Audits

              The Subcommittee is being presented with 9 audits this month.  The audits have been reviewed by the Department’s Internal Audit Workgroup.  Their report is attached.  (Attachment III)

 

              Audits are provided as follows:

 

Office of the State Comptroller

 

              Bayport-Blue Point Union Free School District

Broome-Tioga BOCES

Cold Spring Harbor Central School District

Eastern Suffolk BOCES

Garrison Union Free School District

Nassau BOCES

Ogdensburg City School District

Pearl River Union Free School District

State Education Department Accuracy of Graduation and Dropout

   Data in Annual Report Cards for Selected High Schools

 

Status Report on the Wyandanch and Roosevelt Union Free School Districts

The Subcommittee will be updated on the fiscal status of the two school districts.

             

Recommendation

 

For item one (Analysis of School District Financial Statements), and item two (Completed Audits and Status Report), no further action is recommended. 

 

Timetable for Implementation

 

              N/A

 

The following materials are attached:

  • Roadmap
  • Minutes of the March Meeting (Attachment I)
  • Analysis of School District Financial Statements (Attachment II)
  • Review of Audits Presented – Department’s Internal Audit Workgroup (Attachment III)
  • Summary of Audit Findings (Attachment IV)
  • Audit Report Abstracts (Attachment V)


 

REGENTS SUBCOMMITTEE ON AUDITS

MEETING ROADMAP

 

Date:  April 2009

Time:  TBD

Location:  TBD

TOPIC

OUTCOME

WHO

MINUTES

Opening Remarks

 

Chair

3

Review Agenda/Minutes (Attachment I)

Approval

Conway

7

Analysis of School District Financial Statements (Attachment II)

Information

Conway

10

Completed Audits – Including a Summary of the Department’s Internal Audit Workgroup (Attachment III), Summary of Audit Findings (Attachment IV), and Audit Report Abstracts (Attachment V)  and a status report on the Wyandanch and Roosevelt Union Free School Districts

Questions answered

Department Audit Staff and Szuberla

25


 

Your Subcommittee on Audits held its scheduled meeting on March 16, 2009.

 

Subcommittee Members in Attendance:

 

Regent Geraldine Chapey, Chair

Regent Arnold Gardner

Regent Milton Cofield

Regent Joseph Bowman Jr.

 

Other Members of the Board of Regents in Attendance:

 

Regent Roger Tilles

Regent Lester Young Jr.

 

Discussion Items

 

  • Regent Chapey recognized Regent Gardner, who is leaving the Board of Regents, for his valuable contribution to the Subcommittee and thanked him for his many years of service.

 

  • Regent Chapey commented that in these challenging economic times, BOCES and school districts are striving to contain costs and are aided by the audit reports presented to the Subcommittee.

 

  • Staff reported on some follow-up items from the February 2009 meeting:

 

  • Staff reported on a pamphlet being developed to provide summary information on audit trends arising from school district and BOCES audit findings.  It should be ready by next month’s meeting.

 

  • Counsel briefed the Subcommittee on a follow-up action at the Ardsley Union Free School District which led to members of a school board coming into compliance with mandatory board training regulations. 

 

  • Regent Cofield moved that the minutes of the February meeting be accepted, Regent Gardner seconded.

 

  • Auditor staff from Toski, Schaefer and Co. presented the results of the single audit of the Department’s administration of federal grant funds. For the 2007-08 state fiscal year, the auditors identified four findings. One involved the Child Nutrition Program, two involved VESID and one involved the Reading First program.  The auditors described the findings and the Department’s corrective actions taken as a result. The prior year there were five findings and three were resolved and two repeated this year.

 

  • Office of Audit Services (OAS) staff reported on the audits being presented to the Subcommittee this month.  Upon districts’ submission of corrective action plans, OAS staff will review to ensure all recommendations have been addressed.

 

  • A presentation on one of the 5 audits highlighted by the Department’s Internal Audit Workgroup, State Education Department Criminal History Background Checks for School Employees, was made by staff from the Office of the State Comptroller.

 

  • State Education Department Criminal History Background Checks for School Employees

 

The audit found the Department was not fully monitoring the status of ongoing background checks and that a small number of applications for background checks could not be processed because of data transmission failures or blurred images.  Staff from the Office of Higher Education described changes that the Department has made to correct the deficiencies, including the routine production of reports that clearly identify applications that are taking too long and that may require intervention.

 

  • Staff from the Office of Education P–16, reported on the fiscal condition of the Hempstead Union Free School District. The District has made some progress in controlling spending but is faced with a multi-million dollar deficit in the School Lunch Fund. The district has been identified as being in fiscal stress and has submitted a plan to improve its fiscal condition.

 

  • Completed audits presented this month:

 

Office of the State Comptroller

 

              Copiague Union Free School District

              Greenburgh Central 7 School District

              Irvington Union Free School District

              Ithaca City School District

              Madison-Oneida BOCES

              Menands Union Free School District

              Monroe 1 BOCES

              Mount Pleasant Cottage Union Free School District

              North Collins Central School District

              Putnam-Northern Westchester BOCES

              Roosevelt Union Free School District

              Sayville Union Free School District

              Southwestern Central School District

              State Education Department – Criminal History Background Checks for School

                  Employees

              Wayne-Finger Lakes BOCES


          Attachment II

 

Regents Subcommittee on Audits

April 2009

Analysis of School District Financial Statements

 

School districts and BOCES are required to submit independently audited financial statements and, where applicable, audits required by the federal Single Audit Act (OMB Circular A-133) are also submitted to the Department. The Office of Audit Services (OAS) receives, processes, and reviews over 700 financial statements annually and a similar number of single audits.

 

Financial Statements

 

Each report is reviewed by staff in OAS to assess the following:

  • financial condition of the institution;
  • quality, accuracy, and completeness of the audit reports;
  • significance of any reported management control weaknesses; and
  • accuracy of key ST-3 data used for State aid and reporting purposes for districts.

 

In addition, the financial statements are evaluated to assess compliance with Government Auditing Standards and the Department’s reference manual.  Districts with indicators of fiscal stress and fiscal concern are identified and notified by a letter, along with graphical illustration of the trend of its fund balance, revenue, and expenditures, etc.  These at-risk districts are monitored.  In some cases, they are asked to prepare a plan to address their financial condition.

 

Based on the review of the 2007-08 financial statements, we have identified 8 school districts as being in fiscal stress and 13 as having indicators of fiscal concern.

 

If significant issues are identified in review of a district’s independently audited financial statement, OAS will send a letter to a district requesting additional information.

 

Single Audit (OMB Circular A-133)

 

As a pass-through entity for federal awards, the Department is required to issue a management decision on single audit findings identified by the districts’ independent public accountant through the single audit.  A management decision issued by the Department is required for each single audit finding and states whether it sustains the finding or not, reasons for the decision and identifies any expected action by the auditee.  It is anticipated that OAS will issue management decisions to more than 100 school districts and BOCES for the 2007-08 financial statements.

 

Where appropriate, compliance with the requirements of OMB Circular A-133 and the adequacy of management's action related to any single audit findings are also reviewed.  This often results in further communication with the district and the independent auditor.


Attachment III

 

Regents Subcommittee on Audits

April 2009

Review of Audits Presented

Department’s Internal Audit Workgroup

 

 

Newly Presented Audits

 

We reviewed nine audits that are being presented to the Subcommittee this month.  One audit was of a Department function, five were of school districts and three were of BOCES; all were issued by the Office of the State Comptroller (OSC).  The findings were in the areas of procurement, information technology, financial reporting, claims processing, cash, payroll, extraclassroom activity fund, and other, such as payments for facility rentals, purchases of recycled paper, and reporting high school graduation and dropout rates.  Two of the BOCES audits which assessed the reliability of controls at Regional Information Centers did not result in any recommendation.

 

The Department has issued letters to the auditees, reminding them of the requirement to submit corrective action plans to the Department and OSC within 90 days of their receipt of the audit report.

 

The Department’s Internal Audit Workgroup did not identify any of the audits for further review and follow-up.

 

 


Audit

Procurement

Claims Processing

Payroll

Cash

Financial Reporting

Information Technology

Extraclassroom Activity Fund

Other

 

Office of the State Comptroller

 

 

 

 

 

 

 

 

Bayport-Blue Point Union Free School District

 

 

 

 

* Broome-Tioga BOCES (footnote 2)

 

 

 

 

 

 

 

 √

Cold Spring Harbor Central School District

 

 

 

 

 

 

**Eastern Suffolk BOCES

 

 

 

 

 

 

 

 

Garrison Union Free School District

 

 

 

√ 

 

 

**Nassau BOCES

 

 

 

 

 

 

 

 

* Ogdensburg City School District (footnote 1)

 

 

 

 

√ 

Pearl River Union Free School District

 

 

 

 

 

 

 

* New York State Education Department (footnote 3)

 

 

 

 

 

 

 

√ 

 

 

 

 

 

 

 

 

 

April 2009 Total

4

1

1

1

2

3

1

3

 

* Other:

1

Billing for Facility Rentals

2

Recycled Copy Paper Purchases

3

Reporting High School Graduation and Dropout Rates

 

 

**

No Recommendations


 

Summary of Current and Prior Audit Findings

 

 

May 2007 - April 2008

May 2008

June 2008

September 2008

October 2008

November 2008

December 2008

January 2009

February 2009

March 2009

April 2009

Running Total

Procurement

97

9

2

35

6

6

8

13

16

7

4

203

Capital Assets

18

0

0

1

0

0

0

0

0

0

0

19

Claims Processing

108

9

3

16

3

7

5

3

8

2

1

165

Payroll

107

13

2

24

5

7

10

12

11

1

1

193

Cash

80

13

3

21

4

4

5

5

13

2

1

151

Financial Reporting

64

5

1

15

3

8

5

8

11

5

2

127

Information Technology

100

8

1

25

6

11

11

10

12

6

3

193

Capital Construction

5

0

0

0

0

0

0

0

0

0

0

5

Extraclassroom Activity Fund

7

0

0

6

1

1

1

1

0

0

1

18

Segregation of Duties

47

4

3

6

2

2

1

1

2

1

0

69

Budgeting

9

1

6

1

1

0

1

1

0

1

0

21

Conflict of Interest

10

2

0

4

1

1

3

1

3

0

0

25

Fingerprinting

0

5

1

0

1

1

1

2

0

2

0

13

Other

7

2

5

19

4

17

1

23

5

1

3

87

Total

659

71

27

173

37

65

52

80

81

28

16

1,289

 


Definitions of Categories

 

Procurement – includes findings related to lack of a contract, failure to competitively bid, failure to use purchase orders, lack of segregation of duties, no approval of the purchase and a lack of documentation.

 

Capital Assets – includes failure to have a manager responsible, lack of policy, and inappropriate disposal.

 

Claims Processing – includes claims being paid without adequate documentation, failure to audit the claim, an untrained claims auditor, and a claims auditor that lacks independence.

 

Payroll – includes a lack of segregation of duties in the payroll process; no policy and procedures and inappropriate payments to district administrators including leave accruals and health benefits; improper classification of employees; insufficient policies and procedures for the employee retirement system; improper contractual benefit payments; and improper longevity payments to the former superintendent.

 

Cash – includes poor control of cash, failure to prepare bank reconciliations, and weaknesses in the treasurer’s duties.

 

Financial Reporting – includes inaccurate accounting statements, such as, an overstated fund balance, fund balance exceeding the legal limit, general fund transfers without voter approval, and improper use of accrued liability reserve funds.

 

Information Technology – includes lack of a disaster recovery plan, failure to back up information, inappropriate or undocumented user rights, inappropriate or missing password protection, and no policy and procedures.

 

Capital Construction – includes a lack of detailed accounting records related to a capital project, undocumented expenses, inappropriate and unapproved change orders.

 

Extraclassroom Activity Fund – includes poor accounting over funds and no documentation of expenses.

 

Segregation of Duties – includes weakness in control caused by individuals having responsibility for incompatible functions.

 

Budgeting – includes budget reviews required for school districts that have received approval for deficit financing, poor revenue projections and use of fund balance.

 

Conflict of Interest – includes personal conflicts of board members, district officials, and district employees where they have an interest in a contract, where they have the power, or may appoint someone who has the power to negotiate, authorize, approve, prepare, and make payment or audit bills or claims of the contract.

 

Fingerprinting – includes failure to fully comply with fingerprinting requirements.

 

 


Office of the State Comptroller

Audit

Major Finding(s)

Recommendation/Response

Bayport-Blue Point Union Free School District

Internal Controls Over Selected Financial Operations

2008M-247

10th Judicial District

 

 

The District’s accounting records were not up-to-date because journal entries were recorded as late as six months after the transaction took place. Wire transfers (totaling $492,211) were made without proper authorization. The treasurer also did not maintain adequate control over her facsimile signature.

 

The claims auditor does not report directly, or submit periodic reports to the board. Contrary to Education Law, the board also appointed a District secretary and the District accountant to serve as deputy claims auditors from July 2006 until the appointments were rescinded in September 2007. One hundred eight claims (totaling $897,645) were reviewed, and it was found that nine claims (totaling $66,647) were paid prior to audit. The claims auditor also approved claims by a speech therapist even though the invoices indicated that services (totaling $2,880) were provided to students on days when school was closed. Certain invoices were dated as early as 18 months prior to the claim.

 

Payments that were made to five professional service providers (totaling $398,490) were reviewed and it was found that all five professionals were hired without the benefit of competition.

 

The District also had not restricted physical access to IT assets, nor had the District adequately protected these assets from fire or water damage. Backup tapes are also located on site with the server, and audit logs are not reviewed.

14 recommendations

 

The report’s recommendations focused primarily on strengthening the policies and procedures regarding business office operations, claims audit, professional service providers, and information technology.

 

District officials disagreed with the findings and recommendations in the report. They disagreed with the recommendations specifically pertaining to accounting records and supporting documentation, bank reconciliations, wire transfers, check signatures, claims audit communication with the board, the claims audit process, and the use of professional service providers.

 

The District asks that if specific findings are proven to be incorrect, that they be removed from the report.

 

Broome-Tioga BOCES  Recycled Copy Paper Purchases

P4-8-05

6th Judicial District

 

 

Broome-Tioga BOCES, as well as six other local governments in Broome County, did not purchase 100 percent recycled paper, but instead purchased 9,305 cases (235 tones) of non-recycled white copy paper, and 4,620 cases (116 tons) of 30 percent recycled colored copy paper. 

 

When officials from the Broome-Tioga BOCES were asked why they had not purchased 100 percent recycled copy paper, they responded by saying they were concerned with the additional costs and that the paper would not work in the print shop machines.

 

If Broome-Tioga BOCES had purchased 100 percent recycled paper, they would have conserved wood, energy, greenhouse gases, waste water, and solid waste.

 

1 recommendation

 

The report specifically recommended that, although it is more costly to purchase 100 percent recycled paper, Broome-Tioga BOCES should explore using recycled paper to determine for themselves if the benefits of purchasing recycled paper outweigh the additional cost.

 

Broome-Tioga BOCES officials stated that they will continue to monitor the cost of recycled paper and consider moving to products that are friendlier to the environment. They also stated that they are working with their equipment manufacturers to ensure that there are no technical or warranty issues with using recycled paper. Broome-Tioga BOCES has already implemented a change to its purchasing practices to also include a request for recycled paper when possible.

 

Cold Spring Harbor Central School District  Internal Controls Over Procurement and Information Technology

2008M-252

10th Judicial District

 

 

District officials did not publicly advertise for competitive bids for payments to four vendors (totaling $80,778) or for contracts awarded to three vendors (totaling $607,791) that have yet to be paid. Additionally, quotes were not obtained for payments to three vendors (totaling $6,147). The purchasing policy also did not require District officials to use competition while procuring professional services. Payments were made to 12 professionals (totaling $532,083), and the services of 10 out of the 12 (totaling $397,040) were procured without the use of competition.

 

Further, the District’s computer access policies and regulations do not effectively address remote access and server room security. District officials also have not ensured that remote access agreements are in place with external parties. Finally, audit logs are also not maintained, and procedures are not in place to restrict physical access to, and protect, the District’s IT system components and data.

 

5 recommendations

 

The report’s recommendations focused primarily on strengthening the policies and procedures regarding procurement and information technology.

 

The District specifically agreed with the recommendations regarding compliance with General Municipal Law, and the District’s purchasing policy with competitive bidding. Additionally, the District agreed with the recommendations pertaining to awarding professional service contracts, and access to the District’s IT system and data.

 

The District has indicated that they will implement corrective action as soon as possible to address the recommendations.

Eastern Suffolk BOCES  Regional Information Center

2009M-28

10th Judicial District

 

 

The State Comptroller is statutorily required to audit all school districts, BOCES, and charter schools in the State by March 31, 2010. The school district audits often require the contact of a BOCES Regional Information Center (RIC) to gather information about a school district’s information technology systems that are provided or serviced by the RIC.

 

Based on the inquiries made of RIC management, and the review of policies and procedures during the examination of technology services the RIC provided to component school districts, it was concluded that as of December 31, 2008 controls are adequately designed.

There are no recommendations.

 

Garrison Union Free School District

Internal Controls Over Selected Financial Activities and Information Technology

2008M-250

9th Judicial District

 

 

The District’s unreserved, unappropriated fund balance of $1 million on June 30, 2008, or 11.33 percent of the 2008-09 budget, exceeded the legal limit of four percent by $652,783.

 

The District’s purchasing policy needs to be improved as it does not require the use of competition or contain procedures to be used to procure professional services which are exempt from competitive bidding. The District contracted with four professional service providers who were paid a total of $79,686, without using competition, such as a Request for Proposal (RFP) process or obtaining quotes. The District did not select the lowest cost vendors and did not have any documentation to justify the selection. Sixteen purchases totaling $20,364 were made prior to the completion of purchase orders.

 

District officials have not implemented a procedure to delete inactive employees from the active directory and the accounting system on a timely basis. The former business official still had access rights, although she left the District over a year ago. The board also has not adopted a comprehensive disaster recovery plan to help prevent the loss of equipment or data in case of an emergency.

 

7 recommendations

 

The report’s recommendations focused primarily on strengthening the policies and procedures regarding fund balance, purchasing, and information technology.

 

The District agreed with the recommendations specifically pertaining to the fund balance, the policies and procedures regarding the procurement of goods and services, confirming purchase orders, access to the computer system and user accounts, and the adoption of a disaster recovery program.

 

The District has indicated that changes have already been made based on the recommendations, and that they are working on the additional recommendations for improvements to the District’s policies and procedures along with the board of education.

Nassau BOCES Regional Information Center

2009M-27

10th Judicial District

 

 

The State Comptroller is statutorily required to audit all school districts, BOCES, and charter schools in the State by March 31, 2010. The school district audits often require the contact of a BOCES Regional Information Center (RIC) to gather information about a school district’s information technology systems that are provided or serviced by the RIC.

 

Based on the inquiries made of RIC management, and the review of policies and procedures during the examination of technology services the RIC provided to component school districts, it was concluded that as of December 5, 2008 controls are adequately designed.

There are no recommendations.

 

Ogdensburg City School District

Internal Controls Over Selected Financial Activities

2008M-231

4th Judicial District

 

 

There were weaknesses in the District’s controls over non-payroll check disbursements, the treasurer did not directly supervise the signature process, and checks were not subject to independent review prior to distribution. District checks are also computer-generated with the treasurer’s signature imprinted on them by a BOCES accounts payable clerk.

 

In the extraclassroom activity fund, recordkeeping duties, including maintaining cash ledgers, which should have been performed by student treasurers, were not being performed, and records pertaining to sales/receipts or profit/loss statements were not filed with money remitted. Further, seven organizations within the extraclassroom activity fund do not appear to be student organizations.

 

Additionally, the same business office clerk billed, collected, and recorded charges for facility rentals. Both the clerk and the superintendent made adjustments to certain billings based on past practices. The District is not complying with its policies pertaining to the schedule of rental rates, billing for the use of school facilities, and is waiving fees for certain organizations.

 

The District wrongly enrolled the District physician in the Employee Retirement System (ERS), however, after it was questioned, the District determined that the school physician was an independent contractor, and the physician’s previously reported employee service credit will be removed, and ERS will refund past employer contributions back to the District.

9 recommendations

 

The report’s recommendations focused primarily on strengthening the policies and procedures regarding non-payroll check disbursements, the extraclassroom activity fund, billing for facility rentals, and the classification of employees for the Employee Retirement System.

 

The District specifically agreed with the recommendations pertaining to the authorization to sign payroll checks, the signing of receipts and disbursements without proper student oversight, the segregation of duties involving billing and accounts receivable for facility rentals, and the classification and removal of the school physician.

 

The District has indicated that they will implement corrective action as soon as possible to address the findings.

 

Pearl River Union Free School District

Internal Controls Over the Procurement of Professional Services

2008M-257

9th Judicial District

 

 

The board has adopted a purchasing policy which states that alternate proposals, written or verbal quotations, or other forms of competition shall be used to secure professional services. However, District officials have not implemented the policy. Procurement procedures and contracts for 15 professional service providers, who received a total of $585,220, and services for all 15 were procured without the use of Requests for Proposals (RFP’s), or any other form of competition.

 

1 recommendation

 

The District specifically agreed with the finding pertaining to the implementation of the purchasing policy and the use of RFP’s, or other forms of competition when procuring professional services.

 

District officials stated that they recognize the need to follow the protocols of District policy and regulations, and they have revised their procurement regulation to clarify and further specify their process.

State Education Department

Accuracy of Graduation and Dropout Data In Annual Report Cards for Selected High Schools

2008-S-45

 

 

It is the New York State Education Department’s (Department)  responsibility to report high school graduation and dropout rates to the public. In order to do this, the Department publishes an annual report card for each public high school in the State.

 

The audit reviewed data for the school year 2005-06. The reported graduation and dropout rate information for 12 high schools and 3,667 student files were reviewed.  It was found that graduation rates on the report cards for 2 of the 12 schools tested were overstated by more than 5 percentage points. Corcoran High School was the largest difference, which reported their graduation rate at 50 percent, when in actuality was found to be only 41 percent.  Four of the 12 schools also understated the dropout rate by more than 5 percentage points. Rochester’s John Marshall High School reported its dropout rate as 24 percent, whereas it was found to be 44 percent.

 

The audit found that the Department is reponsible for implementing reasonable controls to ensure that schools accurately report the status of students. The audit stated “the Department does have some controls in place, but they need to be improved….”

 

The major errors found that seemed to be causing the discrepancies were that schools were removing students from the calculations because of undocumented transfers, and  classifying students as transfers to a GED program when there was no evidence the student was actually enrolled in such a program.

 

 

7 recommendations

 

The report’s recommendations focused primarily on strengthening controls to provide assurance that the schools accurately report the status of students prior to release of report cards.

 

The data reviewed were from 2005-06. Since that time, the Department has made several major improvements to upgrade the data system. The Department has created a new high school data repository and a unique ID for every student, implemented a variety of electronic checks to reduce the possibility of errors in the data submitted by school districts, and last year moved all high school data into the repository. The Department is in the midst of major advances in data collection and reporting, organizationally and technologically, all of which will foster timely and accurate data collection and reporting.  More checks will be implemented during this coming year.

 

The Department agreed specifically with the recommendations and stated that many of the Comptroller’s recommendations were being put in place as a result of the changes described above.

 

The Department agreed to follow-up with school districts to resolve discrepancies and to send out more reminders to schools about the need to retain documentation and to review data for their students prior to signing certification.

 

The Department also responded that it is implementing a system to analyze graduation rate data submitted by districts and identify false student transfers.

 

The Department partially agreed with the recommendation stating that it should be required for school districts to have all employees responsible for maintaining student files and determining the status of students trained in the manuals requirements.

 

The Department has indicated that it has already taken the necessary steps to address all findings.

 

More information concerning actions to improve the data system is in an Item for Discussion that is being presented to the Regents Committee on Elementary, Middle, Secondary and Continuing Education.