Review and impact Of new Required Dropout Audit

1. Review and impact Of new Required Dropout Audit A presentation by TASBO and LISD Finance Dept.

2. Introduction Barbara Speer and Donna Scarbrough from SBM Inc., TASBO, and Region One

3. Why is there a new Dropout requirement HB 1144 approved by Legislature Reasons behind the bill Concerns about accuracy and completeness of reporting Lost students – over 100,000 state wide In 2000, a Drop Report Study was made. Discussed Definition, calculation and data quality For complete report - www.tea.state.tx.us/research/dropout/rider71study

4. What are the Requirements of HB 1144 • HB 1144 requires an audit of dropout records from all school districts and charter schools serving grades 7-12 • February 1, 2002 – TEA to make guidelines and training materials available to CPAs –Not FINAL at this time. • Schools are to award a contract to certified public accountants that completed training • First data to be audited – data for SY 2001-2002 • April 2003 – Due date for filing first cycle of audit reports

5. New requirements of the Accountability Rating System • Academic Excellence Indicator System (AEIS) • District Ratings – exemplary (1% or less), recognized (3% or less), academically acceptable (5.5% or less) or academically unacceptable (>5.5%) • Campus Ratings – exemplary, recognized, acceptable or low performing

6. What does TEA look at? TEA compares the fall enrollment and leaver records with the enrollment and attendance records submitted the previous year. Students are matched by student ID, last name, first name and date of birth. • Students for who enrollment or leaver records are expected and are received • Underreported students for whom records are expected but not received • Overreported students for whom records are received but not expected.

7. How to calculate the Annual Dropout Rate? Number of students who dropped out during the school year divided by Number of students in attendance at any time during the school year

8. When is the Audit? Timelines for full implementation of the Annual Audit of Dropouts beginning with the 2001-2002 year for audit • September 2002 - Make training available to auditors throughout the state • October-November 2002 - Schools contract with independent auditors for the annual audit of dropouts for school year 2001-2002

9. When is the audit? continued • November-December 2002 - Independent auditor performs internal control procedures • March 2003 - Independent auditor to begin sampling procedures • April 2003 - The annual audit of dropout records of the 2001-2002 school year due not later than the 90th day after the last day permissible for resubmission to be submitted to TEA in accordance with the Texas Education Code §39.055

10. What has changed in Reporting Requirements? • Before 1997-98 schools reported only students in Grades 7-12 who graduated or dropped out. • Since 1997-98 schools have been required to report the status of all students enrollment or in attendance in Grades 7-12.

11. What are the audit requirements? Dropout records shall be audited by a PA or CPA who: • Is certified or registered as appropriate • Is licensed under Chapter 901 • Has successfully completed training provided by TEA in auditing school dropout records • Is not an employee of the school district/charter school

12. Cover Page Table of Contents Executive Summary Agreed-Upon Procedures Report Findings and Recommendations Current Year Corrective Action Plan Status of Prior Years Findings Appendix Engagement Letter Auditor’s Statement of Completion Certificate of Board School Representation Letter Example Audit– Anywhere ISD

13. LISD Must reports the following to TEA: • Annual Audit of Dropout Report approved by the Board or • Annual audit of Dropout Report not approved by the Board and reasons for non approval • By the 90th day after last day permissible for PEIMS data FINAL Fall submission

14. TEA will conduct Desk Audits and Follow-up • TEA must review all reports submitted by the school district and charter schools • Audit reports are public records • If penal law is violated TEA will notify authorities • If federal program funds are involved TEA will notify the appropriate federal agency • TEA may request additional information

15. TEA MAY conduct On-site Investigations If district’s PEIMS data submission indicates that the accuracy of data is seriously compromised TEA will investigate and can take sanctions • Informal monitoring • Recommended training • Recommended assistance • Financial penalties • Accreditation actions

16. What is PEIMS? • PEIMS data includes personnel, financial and organizational information and student demographic information. • PEIMS includes two categories of data: • Data collected electronically using established data standards; • Other data collection/analysis (e.g. state assessment, federal funding, Foundation School Program data). • PEIMS standards are updated annually. Auditors must apply the definitions and documentation requirements for the year being audited. PEIMS Data standards are found at: http://www.tea.state.tx.us/peims/standards/index.html

17. What is the PEIMS Terminology • Data Standards: instructions, codes, formats and procedures to be used to submit PEIMS data. • Code Table: definitions of codes used to report data (Code table C162 provides “leaver” codes). • Record Type: used to submit information. Pertinent record types include: • 203: School Leaver Data-Student; • 100: Student Data Identification; • 101: Student Data Demographic; and • 110: Student Data Enrollment. • EDIT+: TEA software used to validate/edit PEIMS data. • Person Identification Database (PID): TEA system to manage and store information on individuals reported through PEIMS.

18. 2002-03 Submission Timeline Submission 1: Fall (prior/current year data) include: • Snapshot data reflecting district’s status on October 25, 2002; • Leaver data on graduates, dropouts and other school leavers identified in 2001-02. 10/25: Snapshot Date 8/9: Last Date-editorial changes to Data Standards 9/9: Last Date-updates to static PID 12/12: Data due at TEA 1/23: Last Date- resubmitting fall data (all schools) 10/31: TEA ready to process data 9/26: EDIT+ ready to process data, state-wide distribution of static PID 3/3: Data available to customers

19. PEIMS PEIMS Student Leaver Codes • Reported in fall PEIMS submission; • Includes all grade 7-12 students enrolled in previous year, but who did not re-enroll in current year for various reasons including: • Graduated or received GED; • Moved; • Died; or • Dropped Out • TEA determines if “leaver” records can be excluded. Records are excluded if student: • Enrolled elsewhere; • Received GED; • Is not ADA eligible or case of duplicate reporting; • Graduated from any other district; or • Was previously identified as a dropout.

20. What happens now? 10/25: Snapshot Date 12/12: Data due at TEA 1/23: Last Date- resubmitting fall data (all schools) 3/3: Data available to customers PEIMS data available for auditor to develop and submit report to district. Report due to TEA in April. Student enrolled in 2001-02 does not re-enroll in 2002-03 school year. Student coded as “leaver” using 2002-03 data standards and submitted per fall PEIMS submittal dates.

21. PEIMS Student Leaver Codes • PEIMS Code Table C162 (2002-03) provides leaver code definitions in seven categories: • Leavers reported by this code are not included in dropout rate calculations • NOTE: Codes may change each year - use the correct codes for reporting and in auditing the reporting

22. PEIMS Student Leaver Codes Compulsory Attendance exceptions (2002-03) for leaver reporting: Exception #1: Student who is at least 17, attends a HSEP and meets one of the following conditions: • Student has parental permission to attend program; • Student required by court order to attend program; • Student has separate residence from parents; or • Student is homeless. Exception #2: Student who is at least 16, attends a HSEP and meets one of the following conditions: • Student recommended to take course by agency with custody or supervision by court order; or • Student is attending a Job Corps program.

23. Leaver Code Documentation

24. Leaver Code Documentation Leaver Codes LeaverCodes + + Moved to Other Educational Settings Codes Moved to Other Educational Settings Codes 80, 06, 21 21 22 22 72 72 60 60 24 24 Documentation Documentation 81, 82 73,74 * P * * * * Withdrawal form (signed and dated by appropriate Withdrawal form (signed and dated by appropriate P P P P parties) documenting intent to enroll elsewhere parties) documenting intent to enroll elsewhere * * * * Signed letter by parent/guardian or written Signed letter by parent/guardian or written P P P P * P documentation of oral statement by parent/ documentation of oral statement by parent/ guardian stating intent to enroll elsewhere. guardian stating intent to enroll elsewhere. * * * * Records request from new school. Records request from new school. P P P P Signed letter from receiving school or written. * * * * * * P P P P P P documentation of oral statement by receiving documentation of oral statement School that student is enrolled. ACC ACC - - 041BR01 signed by both districts 041BR01 signed by both districts P P Copy of court order Copy of court order P P Documentation that student is enrolled full time in Documentation that student is enrolled full time in P P college academic program. college academic program. + Code 22: Make sure compulsory attendance requirements are met. *: Indicates more than one form of documentation is acceptable.

25. Leaver Code Documentation

26. Leaver Code Documentation

27. Leaver Code Documentation *: Indicates more than one form of documentation is acceptable.

28. Leaver Code Documentation

29. Leaver Codes Leaver Codes 03 03 10 10 16 16 30 30 61 61 99 99 Other Codes Documentation Other Codes Documentation Copy of death certificate or obituary. Copy of death certificate or obituary. P P Written documentation (including documentation of Written documentation (including documentation of P P oral statements by parent/guardian) that student oral statements by parent/guardian) that student left because of alcohol or drug abuse problems. left because of alcohol or drug abuse problems. Copy of Transfer Document for Copy of Transfer Document for Binational Migrant P P or student student written documentation (including written documentation (including documentation of oral statements by parent/ documentation of oral statements by parent/ guardian) that student is leaving country. guardian) that student is leaving country. Written documentation (including documentation of Written documentation (including documentation of P P oral statements by parent/guardian) stating that oral statements by parent/guardian) stating that student intends to or is enrolled in a health student intends to or is enrolled in a health care facility. facility. Documentation from facility where student is Documentation from facility where student is P P incarcerated or written documentation (including incarcerated or written documentation (including documentation of oral statements) identifying documentation of oral statements) identifying facility where student is incarcerated. facility where student is incarcerated. No documentation identified No documentation identified P P Leaver Code Documentation

30. Enrolled Enrolled Enrolled Enrolled Enrolled Enrolled Did not Did not Graduated Graduated Enrolled Enrolled All All Current Current Current Current Current Current Enroll Enroll in prior in prior Other Other Reports Reports As of As of Year Year Year Year Last Last Year Year in in School School BEFORE BEFORE AFTER AFTER Leaver Leaver Required Required Status Status School School Current Current ON ON as as Year Year as of as of as of as of Codes Codes Year* Year* Year Year of date of date date date date date No No Yes Yes **100, **101 **100, **101 2 2 **100,**101, **100,**101, No No Yes Yes 1 1 110 110 No No Yes Yes **100, **101 **100, **101 2 2 Yes Yes Yes Yes 100, 101 100, 101 2 2 Yes Yes Yes Yes 100, 101, 110 100, 101, 110 1 1 Yes Yes Yes Yes 100, 101 100, 101 2 2 100, 101, 100, 101, Yes Yes Yes Yes 0 0 203 (gr. 7 203 (gr. 7 - - 12) 12) 100, 101, 100, 101, Yes Yes Yes Yes 0 0 203 (gr. 7 203 (gr. 7 - - 12) 12) Yes Yes 100, 101, 100, 101, Yes Yes 0 0 203 (gr. 7 203 (gr. 7 - - 12) 12) Reporting Decision Table * Note: 100,101,110 and 203 records are submitted when student graduates in prior year, but returns for more education in current year. **Reporting of these records is optional for prior year grade 7-12 students.

31. 203 Special Rules - Graduates • Required for all students who graduated during prior year (including summer) – must meet 19 TAC § 74, Subchapter B or 19 TAC, § 89.1070 (special education); • Students who complete GED are NOT reported as graduates; • Students who completed graduation requirements in one year and exit level TAAS in another are reported as graduates in the year TAAS was passed; • Students reported as graduates (code 01) must have DATE-OF-GRADUATION, GRADUATION-TYPE-CODE and COLLEGE-ENTRY-INDICATOR-CODE completed.

32. PEIMS 203 Examples District # 999999, Campus #021. • Example 1: Student S12345678, 20 years old, left to pursue a job. • Example 2: Student S22222222 transferred to school in neighboring district via form ACC-041BR01.

33. What kind of Leaver Documentation will the audit review? General Acceptable Documentation: • Transcript; • Records request from another school in which student is enrolled; • Signed withdrawal form; • Written, signed statement by parent or guardian; • Written, signed statement by student (if married, living away from parents or at least 18 years of age); or • Verification by superintendent or authorized representative of child’s status (e.g. enrolled in another school).

34. Other Leaver Documentation Regs… • Documentation signed and dated by authorized representative of district. Representative designated by written policy. • Withdrawal forms completed and signed by parent/ guardian or adult student and district representative. Original signature not required when form received via fax or e-mail. • Written documentation of verbal statements made by parents or adult student (in person, by telephone) is acceptable in some situations if signed and dated by the district representative. (Use this sparingly!) • Documentation must exist in district at the time leaver data submitted. • Documentation required for dropout and leaver codes.

35. PEIMS Leaver Record Types

36. PIDS and PIDS Errors • PID is used by TEA to manage and store student data. • PID allows linking data across data collections. • PID error rate policy is being phased in over 6 years, starting in 2000-01. • Data sent in 2005-06 must have <10 records with PID errors or a PID error rate ≤ 1%.

37. Three types of Documentation to be reviewed Quality Manual Tier 1 Tier 2 Campus Procedures Work (desk) Instructions Tier 3

38. Documentation Requirements: the Data Quality Manual • Structure defined in policies • Tier 1 – Quality Manual • Policies • Responsibilities • Requirements • Written commitment to quality • List of Tier 2 quality documents

39. Documentation Requirements: the Data Quality Manual (continued) • Tier 2 – Department (campus) and functional procedures • Campus procedures • Responsibilities • Campus chart • Describes the input interface • Describes the output interface • List of Tier 3 procedures

40. Documentation Requirements: the Data Quality Manual (continued) • Tier 3 – Work instructions and standard operating procedures (desk procedures) • Step-by-step instructions on how a task is done • Not every task requires a work instruction • Two questions can determine if needed • If done incorrectly, will it affect the quality of the data? • Is it self- evident to a new employee?

41. Auditing the Data Quality Manual – three questions • Does it cover the data quality system? • Is it controlled? • Can people get it when they need it?

42. Auditing Data Quality Records • Difference between documents and records • Document exists before the fact – description of an activity • Record exists after the fact – data and information • Data quality records – defined in the data quality manual with owner and retention times • Storage – protect from abuse and deterioration • Ease of retrieval

43. Independent Auditor’s Role in Testing • Auditor’s responsibility – perform the agreed-upon procedures in accordance with SAS and report the findings • Auditor must prepare work papers on procedures followed, documents read and tests performed. • Work papers are subject to review by TEA, GAO, etc.

44. Audit Process RFP Engagement Letter ICQ Risk Assessment Sampling Report Development AP Report Findings and Recommendations Corrective Action

45. Internal Control Questionnaire (ICQ) • Tool used by auditor to gather information to assess risk. • ICQ is completed by central administration and each campus prior to fieldwork. Auditor requests completion by a certain date. • Two levels of ICQ: central administration and campus. • Types of information asked by ICQ: • Identification of key positions and duties in the process such as an internal auditor and PEIMS coordinator; • Identification of leaver process including policies, procedures, documentation and coding; • Role and support of Educational Service Centers in training and providing PEIMS assistance; • Safeguards to maintain data and data integrity; and • Technical assistance (student accounting software).

46. Sampling occurs in two populations: Student leaver population Underreported Student Population for grades 7-12 Auditor samples the populations according to sampling procedures identified in dropout module. Sampling is district level and is conducted for each population separately. Sampling

47. Tentative ->Sampling Process Edit+ School Leaver Roster (PRF8D002) State Auditor’s Office (SAO) Statistical Toolbox Compliance Sample Size and Random Number Generator Audit Sample Size to be examined = 29 Edit+ Statement of Presumed Under-Reported Students (PRF0B001)

48. Auditors will Examine Student Records • Form 5 is used to evaluate student leaver records and contains four questions: • Did student file contain enrollment form? • Is there authorized documentation to indicate student has withdrawn? • Was student assigned leaver code that explains student’s departure? • Does the documentation in the file support leaver code assigned to student? • Questions are marked as E (Exception), NE (No Exception) or NA (not applicable) • Number of exceptions per student file are tabulated and number of files with exceptions are totaled. • Student confidentiality must be maintained in examining and reporting results of these records as per Family Educational Rights and Privacy Act (FERPA).

49. Auditor will Examine Student Records • Form 6 is used to evaluate under-reported student records and contains three questions: • Other than enrollment form, is there evidence that student was in attendance for year studied? • Is there documentation that student should have been reported as a leaver? • Is there documentation to support a leaver code that can be assigned to the student? • Questions are marked as E (Exception), NE (No Exception) or NA (not applicable) • Number of exceptions per student file are tabulated and number of files with exceptions are totaled. • Student confidentiality must be maintained in examining and reporting results of these records per FERPA.

50. TEA has developed expected procedures to be followed in conduct of audit Auditor may perform additional procedures that are mutually agreed to by auditor and district. School, at its cost, employs public accountant or certified public accountant to apply agreed upon procedures. Audit is conducted consistent with AICPA standards. Agreed-Upon Procedures