East Baton Rouge Parish School SystemLocal Government

Graduation Rate Cohort Documentation 84.010 Title I Basic Grant #28-23-T1-17 Questioned Costs: None. Criteria: The School System must report graduation rate data for all public high schools at the school level using the 4-year adjusted cohort rate under ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25)). Only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating the 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. 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. A student who is retained in grade, enrolls in a 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. The East Baton Rouge Parish School System is responsible for assigning exit codes to any student who leaves the School System. Only specific exit codes are deemed legitimate reasons for leaving the School System and will cause the leaver to not be included in the cohort’s graduation index calculations. Specific documentation must be maintained in order for students to be considered legitimate leavers from the cohort. The School System is also responsible for developing a system of internal controls to ensure the proper documentation is retained for all leavers of the cohort. Universe/ Population Size: The sample of cohort removals was selected from a universe that includes all high school students that left the School System based on exit codes. Based on these requirements, the total universe is 344 students who are considered leavers of the cohort. This is also considered the population size. Sample Size: Based on sampling guidance for audits performed under the Uniform Guidance, a non-statistical sample of 40 leavers was selected for testing. Condition(s): In testing internal controls with respect to 34 CFR §200.19(b), 7 of 40 leavers had exceptions to the required documentation set forth by the compliance guidance. This rate of exception indicates that the School System does not have adequate internal control procedures in place to ensure that all documentation is maintained contemporaneously with the removal of the student to support the removal from a cohort. While the School System does have a process of obtaining monthly drop-out reports to monitor leavers from the cohorts at the program level, testing revealed that these listings were not complete with all exit codes and potential leavers. This created a deficiency in the internal control process in place, as there was lack of oversight over the documentation obtained for certain leavers. Cause: Individual high schools are responsible for maintaining documentation related to the removal of students. Monthly monitoring reviews of documentation was conducted to ensure adequately removal of the students from the cohort; however, some high schools did not report the students in the district data reporting system. Effect: Without the proper school reporting data process over the graduation rate cohort, documentation may not be properly retained, and therefore the School System may be noncompliant with the Graduation Rate Cohort component of the Title I program. Recommendation: The School System should establish procedures at the School and program administration levels to ensure appropriate documentation is obtained related to removal of students from a cohort in a timely manner. The School System should develop an internal control procedure which includes the periodic review of a complete listing of cohort removals at the program administration level. The School System should also emphasize the importance of appropriate documentation retention at the School level in a timely manner with the departure of students. We recommend that the documentation for leavers also be maintained and monitored at the program administration level to provide a level of accountability to the schools. View of Responsible Official: The finding will be resolved on January 31, 2024. Sandra Bethley, Ph.D., Executive Director of Federal Programs will be responsible for the resolution of the finding. Effective January 4, 2024, the leadership team of the Office of Federal Programs will supervise the Graduation Rate Cohort initiative for the East Baton Rouge Parish School System. A Graduation Rate Cohort team will be established. The Graduation Rate Cohort team will develop written procedures for identified school personnel and principals to follow. A contact person from each high school will be identified. A meeting will be conducted with identified school personnel to explain the criteria and procedures for maintaining documentation for students departing from the high schools. Failure to comply with the procedures will result in immobilizing schoolwide Title I funds.

CFDA #84.165A Magnet Schools Assistance Program Questioned Costs: None. Criteria: The Uniform Guidance federal regulations were fully effective as of December 26, 2017 and therefore, the School System, as a recipient of federal awards, was required to implement and comply with the Uniform Guidance for the year ended June 30, 2019. The federal regulations at 2 CFR Subpart D, ?200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor, and may only be used when one or more of the following circumstances apply: 1.) The item is available only from a single source; 2.) The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; 3.) The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or 4.) After solicitation of a number of sources, competition is determined inadequate. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning, must be documented. Universe/ Population Size: The total universe was considered to be all vendors of the Magnet School Assistance Program (MSAP) whose transactions for the year ended June 30, 2019 exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the universe. Based on these requirements, the total universe is 26 vendors totaling $919,820. This is also considered the population size. Sample Size: Based on sampling guidance for audits performed under the Uniform Guidance, a non-statistical sample of 5 vendors was selected for testing. Condition(s): In testing internal controls with respect to 2 CFR Subpart D, ?200.320(f), the 5 vendors selected for testing were deemed to be sole source vendors by the School System; however, there was no documentation maintained to support the decision-making process in awarding three of these vendors. In two instances, sole source letters were obtained from the vendors, which outlined the uniqueness of the goods and services to be provided. However, the letters were dated after-the-fact or included no date as evidence that the documentation was obtained contemporaneously with the decision to award the sole source vendor. The documentation also lacked consideration of similar type products that could potentially satisfy the needs of the program. Cause: While the School System has adopted a procurement policy to address procurement to sole source vendors and an informal review of these criteria did take place prior to awarding each sole source vendor tested, a centralized control and periodic review did not exist to ensure documentation is adequately maintained contemporaneously with the decision to award the sole source vendor. Effect: Without proper internal controls over procurement to sole source vendors, documentation may not be properly retained, and therefore the School System may be noncompliant with the requirements of the MSAP program and Uniform Guidance. Recommendation: The School System should establish procedures at the School System and program administration levels to ensure appropriate consideration to competitors are given and documentation is obtained related to procurement of sole source products in accordance with the Uniform Guidance 2 CFR Subpart D, ?200.320(f). This documentation should be approved by the program director, as well as the central office purchasing director, and retained as evidence of the internal controls over procurement. Repeat Finding: No.

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