MT. DIABLO UNIFIED SCHOOL DISTRICT

Criteria: 34 CFR, section 200.19(b) states, in part: High schools – (1) Graduation rate. Consistent with paragraphs (b)(4) and (b)(5) of this section regarding reporting and determining AYP, respectively, each State must calculate a graduation rate, defined as follows, for all public high schools in the State: (i) (A) A State must calculate a “four year adjusted cohort graduation rate,” defined as the number of students who graduate in four years with a regular high school diploma divided by the number of students who form the adjusted cohort for that graduating class. (B) For those high schools that start after grade nine, the cohort must be calculated based on the earliest high school grade. (ii) The term “adjusted cohort” means the students who enter grade 9 (or the earliest high school grade) and any students who transfer into the cohort in grades 9 through 12 minus any students removed from the cohort. (A) The term “students who transfer into the cohort” means the students who enroll after the beginning of the entering cohort's first year in high school, up to and including in grade 12. (B) To remove a student from the cohort, a school or LEA must confirm in writing that the student transferred out, immigrated to another country, or is deceased. (1) To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. (2) A student who is retained in grade, enrolls in a General Educational Development (GED) program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort.Condition: During our review of the District’s Title I program, we noted that the District did not maintain written documentation supporting that a student had enrolled in another school or in an education program that culminates in the awarding of a regular high school diploma. The District is required to maintain official written documentation supporting that a student has enrolled in another school or in an educational program that culminates in the awarding of a regular high school diploma. A student who is retained in-grade or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rates and must remain in the adjusted cohort. Cause: The District did not maintain adequate documentation to support the removal of a student from the regulatory adjusted cohort.Effect: We were unable to determine whether the District implemented policies and procedures for documenting the removal of students from the regulatory adjusted cohort. Questioned Costs: NoneContext: The CDE uses the student-level data maintained in CALPADS to calculate the four-year adjusted cohort graduation rate for all LEAs in the state. We selected nine students who were identified in CALPADS as transfer students who withdrew from the District. The District was unable to provide any written documentation to confirm that one of these students transferred out of the District and emigrated to another county or enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Recommendation: We recommend that the District implement appropriate controls necessary for documenting the removal of students from the regulatory adjusted cohort, and ensure that the supporting documentation is maintained. Views of Responsible Officials: The District agrees with the auditor’s recommendation as stated above. The District acknowledges that it can be challenging to obtain documentation for students who leave the District without notification or formally withdrawing.

Finding 2024-003: Time and Effort Requirements (50000) Repeat Finding? No Assistance Listing No. 84.425 – Education Stabilization Funds (ESSER) U.S. Department of Treasury Passed through California Department of Education Criteria: To support salaries and wages for employees that work on federal programs, local educational agencies (LEAs) are required to maintain time and effort records that accurately reflect the work performed. These time and effort records must: (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (2) be incorporated into the official records of the LEA; (3) reasonably reflect the total activity for which the employee is compensated by the LEA, not exceeding 100% of compensated activities; (4) encompass both federally assisted and all other activities compensated by the LEA on an integrated basis, but may include the use of subsidiary records as defined in the LEA’s written policy; (5) comply with the established accounting policies and practices of the LEA; and (6) support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Budget estimates or percentages determined before the services are performed alone do not qualify as support for charges to Federal awards. Condition: Three employees out of a sample of 25 total had exceptions related to proper time accounting documentation. One employee was missing time accounting documentation for the months of August and September 2023. The employee was terminated during the year; however, there was no time accounting done for August or September while the employee was active. Two other employees' time accounting documentation was not signed until after the close of the fiscal year in which they were accounted for. Cause: The exceptions appear to be isolated situations and not a systemic problem. The District did not have sufficient time and effort procedures to ensure that their records were supported by appropriate documentation. Effect: The District could be required to reimburse ESSER III funds using an unrestricted funding source. Questioned Costs: The District did not provide documentation for $22,155 charged to ESSER programs. Specifically, the District failed to provide sufficient documentation to support salaries charged to ESSER III – Resource 3213. Context: Three employees out of a sample of 25 total had exceptions related to proper time accounting documentation. Recommendation: The District must update its time and effort records and policies and procedures to ensure that all salaries and wages charged to federal programs are properly supported by a system on internal controls. Specifically, the time and effort records must accurately reflect the work performed and encompass all activities of the employee, both federal and non-federal, and be signed in a timely manner. Views of Responsible Officials: The District agrees with the auditor’s recommendation as stated above.

GSA_MIGRATION