CONSOLIDATED PROGRAM REVIEW (CPR) 2015-2016 Report

Below is this year’s report from OSPI’s Consolidated Program Review team. We have a total of 11 non-

compliance findings. A couple of positive things to keep in mind:

Many of the non-compliance findings seem to be easy fixes rather than more difficult structural fixes

Our previous full review (2013-14) had 25 findings

Out of several hundred items under review, 11 is a relatively small number

2/24/2016

TO: Larry L. Nyland, Superintendent Seattle Public Schools

FROM: Paula Moore, Director

Title I, Part A, Learning Assistance Program (LAP) & Consolidated Program Review (CPR)

RE: Consolidated Program Review (CPR) 2015-2016 Report On 2/23/2016–2/24/2016, a team from the Office of Superintendent of Public Instruction (OSPI) conducted a review of federal and state programs in which your district participates.

This report includes commendations, technical assistance, noncompliant items and actions required. Your district has 45 calendar days from the date of the exit review to follow up with any action that is required for noncompliant items. Your follow-up due date is 4/11/2016.

Commendations:

Program Commendation Note

3) Title

I, C

The district's Migrant Education Program appears to have

enhanced its efforts to develop a strong parent advisory

council and engage them in the planning, implementation, and

evaluation of the local program.

6) Title

II, A

We so appreciate Seattle Public Schools response to meeting

federal HQT compliance requirements, especially that of Amy

Valenti. Given the number of teachers employed by SPS and the

limited resources assigned to this task, the work done is just

that much more amazing. The seriousness with which the district

has addressed the NHQT issue to meet federal compliance

requirements, Amy Valenti's attention to detail, her methodical

approach, accurate documentation, easy access to records, and

the few number of teachers who are actually not HQ is a

testimony to district efforts and Amy's perseverance in what we

know has been a tedious and time consuming endeavor over the

past several years. We do commend the district and Amy for the

work that has been done.

7) Title

III-TBIP

7.1 and 7.5

I visited Orca K-8 and Bryant Elementary Schools, two schools

with new and growing ELL programs. Both buildings have invited

ELLs previously under a parent waiver into program and have

growing populations. The district has done an excellent job of

providing staffing to provide ELL services and training to ELL

students' classroom teachers. Four teachers at Bryant

Elementary have committed to 60 hours of intensive professional

development to support ELLs in their classrooms. Principals at

both buildings were able to articulately respond to questions

about their ELL program and are advocates for the ELLs in their

buildings. Evidence of support through Title III coaches was

provided. The district is to be commended for the quick ramp up

of ELL services in over 20 additional buildings and the level

of support and training provided. The district provided

evidence of staff training regarding supports to students under

parent waivers.

7.7

The district has a high completion rate (approx. 90%) for its

intensive, 60-hour MOOC training, with approximately 400

teachers trained. This is accomplished in part due to the high

quality of the training, the support for collaboration provided

by Title III coaches, and the stipend to teachers who

participate.

10)

Homeless

SPS transportation department should be commended for the

services they provide to homeless students and their

families. Staff are well trained, and the department as a

whole works well with McKinney-Vento program staff to ensure

timely and professional services.

11)

Highly

Capable

Item 11.5: Program Service Evaluation: The district and

Advanced Learning Department staff are commended for outreach

to students in Title I-served schools through screening

instrument. Your Program Evaluation indicates significantly

more students were referred and assessed based on screening

results. This is established best practice for identifying

students who may be overlooked through traditional referral

processes.

13)

Private

Schools

The district does a very good job of ensuring information on

all eligible programs is provided to the private schools to

assist them in determining the services to be accessed for

students and staff.

Technical Assistance:

Program Technical Assistance Note

3) Title I,

C

It is recommended MEP staff complete Identification and

Recruitment activities to complete a Certificate of

Eligibility and enroll migrant students on a more timely

basis. The recommended guidance is to complete recruitment

activities within three-months of student and family

enrolling in school programs.

4) Title I,

D

Items of evidence seem to be targeting Interagency Intake

Center grant 209 activities, but Detention Center grant 208

is missing too many items to be compliant. Advise grantee to

review previous year's CPR documentations that were in

compliance for examples.

7) Title

III-TBIP

7.3

Title III cannot fully fund high school credit retrieval or

high school credit retrieval summer school for Title III

eligible Native American students, but it can provide

additional support for eligible students within credit

retrieval programs.

10)

Homeless

The district needs to address current systemic challenges

related to the immediate enrollment (defined as enrolling and

participating fully in all school activities) and provision

of service for eligible homeless students according to the

federal McKinney-Vento Act.

SPS policies and procedures - particularly regarding

enrollment - should be reviewed and revised in a manner to

effectively remove barriers to the immediate enrollment and

participation of homeless students.

The McKinney-Vento dispute process should be implemented in a

manner that is consistent with district policy federal

law/state policy.

Any systems developed or revised by the district should

support the Liaison's responsibilities as defined by federal

law.

Training for district administrative staff is strongly

encouraged, as well as continued technical assistance through

OSPI and NCHE as appropriate.

12)

Perkins/CTE

12.4.The Special populations document shows that the Health

and Human Services courses have higher enrollments then other

pathways. The district may wish to disaggregate the data to

be sure programs are not impacted disproportionally.

12.4 Though the district has added ELL and IA supports in

class rooms teachers report the need for PD and coordination

to make these models more effective.

12.8 Health and Human services shows strong leadership but it

could be strengthened in other pathways especially with the

Instructors' that are coming out of business and industry.

14) Civil

Rights

14.1 - Staff Training: In its upcoming discrimination complaint procedure training, the district should make it clear to building principals that the district's formal complaint procedure is required for all written complaints alleging potential discrimination.

14.6 - Pregnant and Parenting Students: The district should ensure it is protecting its pregnant and parenting students from discriminatory harassment. This could include additional training or notification to students, families, and staff that harassing a student based on their status as pregnant or as a parent is discriminatory harassment and will be treated as such under district policies and procedures. More information about protections for pregnant and parenting students is available at: http://www.k12.wa.us/Equity/Trainings.aspx .

14.10 - Course and Program Enrollment: While it appears that the district reviews enrollment data for Advanced Learning programs and CTE—with additional reviews being conducted by individual buildings—it does not appear the district has a comprehensive system in place to make sure that disaggregated course and program enrollment data is reviewed annually to identify and address disparities. Please take steps to make sure this review takes place each year and includes honors and AP courses, CTE programs, highly capable programs, and online or ALE programs.

16) OSSS OSSS issued a CPR desk review. The district team has

uploaded a current DIP into Indistar and has maintained

ongoing "limited" development of required objectives.

By May 30th submission all 14 assessed district level

indicators will have goals and tasks that reflect the current

DIP. Please contact district OSSS leadership coach or myself

for technical assistance in merging current DIP in

Indistar. Paul Wieneke

Noncompliant Items:

Program Number Description Actions Required

Title I,

A

1.16 Title I Set-Asides Parent Involvement: Per iGrants form

package 201, the district was

required to set aside $99,078 for

parent involvement activities. The

district only set-aside $84,644.

Please submit an action plan

describing how the district will

ensure that set-aside requirements

are met and are in alignment with

their approved application. In

addition to the action plan, ensure

that the proper amount is set-aside

for Parent Involvement activities in

the current year. Professional

Development: The district could not

provide evidence that unspent

professional development set-asides

were carried forward into the 15-16

year, as required. Please submit an

action plan describing how the

district will ensure that set-aside

requirements are met. In addition to

the action plan, please provide

evidence that the district has

revised their 15-16 budget to include

unspent PD from 14-15.

Title

II, A

6.1 Highly Qualified

Teachers

All teachers, under contract with the

district for 2015-16 between the

first day of school and December 9,

2015, assigned to Title I school-wide

or targeted assistance programs are

required to be highly qualified at

time of placement or risk recovery of

federal funds by the state auditor.

Based on the information provided and

the current district data reported in

the HQT Tool (SY15-16), the following

teachers are NHQT and assigned to a

Title I building: Jana Gueck, EC,

John Muir Elem; Katie Beavers, math

and science, Rainier Beach HS; Leenar

Fong, math, Seattle World School;

Tamara Kelley, EC, South Shore; Title

I building principals should not sign

the Principals Attestation when not

all teachers meet HQT (Item 1.17)

Within the 45 day window, provide a

status report on NHQT teachers

assigned to Title I buildings;

include whether or not they have met

the HQT requirements. In the event

the district is audited, having NHQT

in Title I buildings may be a

finding, even if the teacher is on an

Individual Teacher Plan for Achieving

Highly Qualified Status.

Title

III-TBIP

7.1 Identification The district has made tremendous

progress towards identifying eligible

English language learners. However,

there continue to be students with a

reported language other than English

who have not been placement tested,

including 29 students who enrolled in

2016. Submit an action plan for: -

verifying home language surveys for

students with a reported primary

language other than English who have

not taken a placement test and

administering a placement test when

necessary. - ensuring that, when a

parent indicates at the school level

that the student's primary language

is not English, this is documented on

a home language survey and the

student is tested for ELL

eligibility.

Homeless 10.2 Dispute Resolution Dispute process and forms were

updated to meet compliance; however,

not all staff are familiar with the

dispute process requirements -

particularly the requirement for

immediate enrollment. Provide

evidence that all district personnel

are following district procedures

regarding immediate enrollment during

McKinney-Vento disputes.

Homeless 10.5 Identification of

Students

McKinney-Vento requires that all

district staff receive McKinney-Vento

training to support their efforts to

actively identify homeless students.

Please provide an action plan to

systemically integrate McKinney-Vento

training into the SPS professional

development. Training cohorts should

include central office personnel

(enrollment, nutrition services,

transportation, etc.)as well as

building staff.

Homeless 10.6 Enrollment, Intake,

Access and Parent

Information

Please provide an action plan to

systemically address issues with the

immediate enrollment of homeless

students regardless of whether or not

those students lack records. Include

documentation that immediate

enrollment is being provided to

McKinney-Vento eligible students.

Provide evidence that

residency/address are not required

for enrollment/ services. Provide

evidence that the district liaison is

making the final determinations

regarding identification, enrollment,

provision of service, etc. for

homeless students, per federal law.

Civil

Rights

14.2 Nondiscrimination

Statement

Please submit an action plan

describing how the district will

ensure the complete, current

nondiscrimination statement is

included in all major district and

building publications (including

newsletters and building handbooks)

that are widely disseminated to

students, parents, or employees.

Civil

Rights

14.5 Section 504 Please submit a revised Section 504

procedure (2162P) with an updated

grievance procedure that aligns with

the discrimination complaint process

in WAC 392-190-060 through -070.

Civil

Rights

14.14 Accommodating

Student Interests

and Abilities

Please submit evidence that each

building that offers an athletic

program equally accommodates the

interests and abilities of male and

female students. If the district

cannot show compliance, please submit

an action plan that describes how

each building will effectively

accommodate the interests and

abilities of the underrepresented

sex.

Civil

Rights

14.15 Annual Athletic

Evaluation

Please submit (1) an action plan

describing how the district will

annually evaluate girls' and boys'

interscholastic, club, or intramural

athletic programs at middle schools

to ensure that the overall benefits

and treatments of the boys' and

girls' programs are comparable and

(2) a description of the process the

district uses to ensure that athletic

fundraising, donations, and booster

clubs do not result in disparities

that favor one sex over another.

Fiscal 15.1 Fiscal Cross-

Cutting

Time and Effort - The PARS for two

employees (one employee was coded to

Title IC and General Fund, and the

other employee was coded to Title III

and General Fund) were completed

based on budget instead of actual

time. Provide a corrective action

plan to ensure that employees

properly complete PARS by recording

actual time spend on each cost

objective. Time and Effort - Several

semi-annual certifications were not

dated and stated "invalid signature".

However, this appeared to be an issue

with Excel, which is used for time

and effort reporting. Provide a

corrective action plan to follow up

on the cause(s)of this issue and

correct it. Time and Effort - There

were instances where the semi-annual

certifications were not completed

until the end of the year for the

first half of the year. Also, a

couple PARS were completed late (for

example, a PAR for March was not

signed until October 1). Provide a

corrective action plan to ensure time

and effort forms are completed in a

timely manner. Non-Payroll

Transactions: The following issues

were noted followed by action plan

required: 1) Title I, A: Meals with

meetings/professional development:

Noted agenda indicated working lunch

and per diem amounts were reasonable,

but need to provide additional

documentation supporting why meal

purchases were necessary and what

benefit it provided to the program.

2) Title I, A: Year End Journal

Vouchers transferring funds into

federal programs. Several transfers

of funds from state/local to federal

programs were reviewed and based on

discussions with staff, documentation

was electronic budget reports and

were not printed for backup

documentation, so cannot determine

allowability without going to the

original transaction. We recommend

retaining documentation to support

JVs moving forward. 3)School

Improvement (SIG): It was noted that

a vendor was paid for taking 60

students to the Family Fun Center in

Tukwila for $949.37 for a celebration

of Summer Freedom Schools.

Entertainment is not an allowable

cost with federal funds.

Additionally, reviewed the contract

for this purchase, and noted this was

not included in the activities to be

performed. This particular program

has decentralized budget authority at

the building level, which increases

the risk of unallowable expenditures

being charged to federal programs. We

recommend that Michael Stone review

and approve all

expenditures/contracts for approval

prior to payment. 4)Procurement

Procedures: The procedures regarding

Supplies, Material and Equipment

provided to us was were dated 2012,

and do not contain purchasing

thresholds compliant with federal

regulations. Provide a more current

revision that includes the required

thresholds. 5)Title III: We noted

unallowable transactions for a credit

retrieval program (PASS program with

Sunnyside SD, fingerprint fees

(corrected for current year) and

World Language Testing for credit by

proficiency. Provide an action plan

that ensures only allowable

activities are charged to Title III.

6)There are 3 outstanding requests

for supporting documentation to

review the initial request and

approval to determine compliance for

allowability. Title I, C – Office

Depot $317.75, Title I, D – Apple

Computer (ipad airs) - $24,198.58,

Perkins - Harbor Freight Tools -

$2,317.94. Provide requested

documentation.

If you have any questions or concerns about the information provided in this report or if you need

further technical assistance, please use the contact information below. The agency TTY number is (360)

664-3631.

Program Monitor Phone

Number

Consolidated Program

Review

(360) 725-

6100

0 General N/A (360) 725-

6100

1 Title I, A Larry Fazzari, Penelope Mena (360) 725-

6100

2 LAP Larry Fazzari, Penelope Mena (360) 725-

6100

3 Title I, C Sylvia Reyna (360) 725-

6147

4 Title I, D Kathleen Sande (360) 725-

6046

5 Title I, G Barbara Dittrich (360) 725-

6097

6 Title II, A Deborah Parriott (360) 725-

6340

7 Title III-TBIP Alyssa Westall (360) 725-

6147

8 Gun-Free Mike Donlin (360) 725-

6044

9 Rural Education N/A (360) 725-

6234

10 Homeless Melinda Dyer , Jess Lewis (360) 725-

6050

11 Highly Capable Jody Hess (360) 725-

6171

12 Perkins/CTE Mary Nagel (360) 725-

6245

13 Private Schools Anne Renschler, Sylvia Reyna (360) 725-

6229

14 Civil Rights Sarah Albertson (360) 725-

6162

15 Fiscal Debra Crawford, Jamey Schoeneberg, Toni

Bernethy, Jennifer Carrougher

(360) 725-

6104

16 OSSS PAUL WIENEKE (360) 725-

6424

17 Fiscal Follow-Up N/A (360) 725-

6280

PM:ar/tm

cc:

Min Yee, CPR Contact, Seattle Public Schools

Kenny Ching, Grants Accounting Supervisor, Seattle Public Schools

Sylvia Reyna, CPR Team Lead, Office of Superintendent of Public Instruction