Delaware Community School Corporation

FINDING 2020-001 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A150014, S010A180014, S010A190014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Assessment System Security Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. The School Corporation did not retain Testing and Security Agreements for individuals at two schools who administered, handled, or had access to secure test materials. In addition, the School Corporation did not retain training materials or communications that documented that staff had been trained on ethical and appropriate practices, contained in the Code of Ethical Testing Practices and Procedures, as well as any additional local standards or training on how test administration, test security standards, and procedures would be monitored by school administrators. The lack of internal controls and noncompliance were systemic issues that occurred throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.207(a) states in part: "The Federal awarding agency or pass-through entity may impose additional specific award conditions as needed. . . ." 2 CFR 200.333 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Federal awarding agencies and pass-through entities must not impose any other record retention requirements upon non-Federal entities. The only exceptions are the following: (a) If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken. . . ." 511 IAC 5-5-5(b) states: "Any individual who administers, handles, or has access to secure test materials at the school or school corporation shall complete assessment training and sign a testing security and integrity agreement to remain on file in the appropriate building-level office each year." Indiana Assessment Program Manual, Section 9, Part D states in part: ". . . Locally developed written test security policies must include, but not be limited to, the following descriptions regarding how the corporation will: 1. Ensure that all appropriate staff have knowledge of the Code of Ethical Practices and Procedures and understand how to secure, administer, and handle the assessments while in their possession. 2. Ensure all appropriate staff receive test administration and test security training prior to testing. 3. Ensure all staff receive Test Security and Integrity Training prior to testing. 4. Ensure staff members who will provide students with testing accommodations are familiar with each student's individual accommodation needs as per the student's IEP, ILP, Section 504 Plan, CSEP, and/or Service Plan prior to testing. 5. Ensure staff members who will provide students with testing accommodations receive focused training on providing such accommodations prior to testing. 6. Define and clearly communicate at least once annually for all appropriate staff how staff implementation of test administration and test security standards and procedures will be monitored by school administrators. 7. Define and clearly communicate at least once annually for all appropriate staff all security procedures established for each assessment. 8. Provide any other information and professional development necessary to ensure that all appropriate staff have the knowledge and skills necessary to make ethical decisions related to preparing students for an assessment, administering the assessment, and interpreting the results from assessment. 9. Establish a testing schedule. At a minimum, the schedule should include the assessment name, testing dates and times, applicable grade levels, content areas, and testing room locations. 10. Establish an access policy for assessment materials that allows only appropriate staff to have access to test administration manuals prior to the administration of the test, but prohibits the reviewing of any secure test questions before, during, or after the assessment administration. 11. Establish a process that ensures all student assessments are secure when they are not being administered. 12. Annual review school materials and practices related to preparing students for assessments. The description must include an explanation regarding how the school corporation will ensure test preparation materials used by school staff are appropriate and do not violate test security protocols. 13. Monitor testing to ensure staff are administering assessments with fidelity in terms of test administration and test security protocols/procedures and that staff are appropriately providing students with accommodations included in their IEPs, ILPs, Section 504 Plans, CSEPs, or Service Plans. 14. Provide channels of communication that allow teachers, administrators, students, parents/guardians, and other community members to voice their concerns about testing practices they consider inappropriate (see the Testing Concerns and Security Violations Report form in Appendix C). 15. Establish procedures for investigating any complaint, allegation, or concern about inappropriate testing practices, and ensuring protection of both the rights of individuals and of the integrity of the assessment. 16. Investigate any complaint of inappropriate testing practices or testing irregularities according to the Protocol for Reporting and Investigating Alleged Breaches as established and published pursuant to 511 IAC 5-5-4 (see Appendix A)." Cause Management had not developed a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance with the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Special Tests and Provisions - Assessment System Security compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

CORRECTIVE ACTION PLAN FINDING 2020-001 Contact Person Responsible for Corrective Action: Greg Kile Contact Phone Number: 765-284-5074 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Effective System of Internal Controls to Related to Assessment System Security Compliance: ? Delaware Community School Corporation Administrators will continue to provide test security training to all applicable employees throughout the school corporation following all protocols specified by the Indiana Department of Education. The Corporation Test Coordinator, or CTC, will be responsible to ensuring that this training continues to occur as it has each year. ? Additionally, the CTC will train building principals in regard to retaining records of test security training meeting agendas, test security training materials, test security training meeting sign-in sheets, and individual employee?s signed test security and integrity agreement forms. These records will be collected and maintained at each school building throughout the fall and winter of each school year. Each spring, prior to the end of the school year, the CTC will request a copy of these records be send to him or her and stored centrally for the entirety of the school corporation. This documentation will be retained by the CTC for a minimum of three years or until those years are audited, whichever occurs last. ? After three years or those years have been audited, whichever occurs last, the CTC will dispose of assessment system security compliance records in accordance with the Indiana Records Retention Schedule?s guidance for disposal of records. Anticipated Completion Date: August, 2021