the following table presents a summary of the property and

2009 State FTE Audit Advisory

To be presented to the:

Audit Committee On February 10, 2011

School Board of Broward County, Florida On March 1, 2011

The Nation’s Sixth-Largest School District

The School Board of Broward County, Florida Benjamin J. Williams, Chair

Ann Murray, Vice Chair

Robin Bartleman Maureen S. Dinnen

Patricia Good Jennifer Leonard Gottlieb

Laurie Rich Levinson Nora Rupert

David Thomas, NBCT

James F. Notter Superintendent of Schools

The School Board of Broward County, Florida, prohibits any policy or procedure, which results in discrimination on the basis of age, color, disability,

gender, national origin, marital status, race, religion or sexual orientation. Individuals who wish to file a discrimination and/or harassment complaint may call the Executive Director, Benefits & EEO Compliance at 754-321-2150 or

Teletype Machine (TTY) 754-321-2158.

Individuals with disabilities requesting accommodations under the Americans with Disabilities Act (ADA) may call Equal Educational Opportunities (EEO) at

754-321-2150 or Teletype Machine (TTY) 754-321-2158.

www.browardschools.com

The School Board of Broward County, Florida Office of the Chief Auditor

2009 State FTE Audit Advisory

Table of Contents

Page Observations and Recommendations…………………………………………………..………..1-6 Table 1. Summary of number of exceptions by category……………………..………..……...…7 Table 2. Summary of weighted FTE adjustments by category……………………….....…..……7 Table 3. Summary of exceptions grouped by ESE, ELL, and OJT…………………...…..…...…8 Table 4. Summary of student documentation & teacher certification exceptions…….……….....9 Table 5. Summary of ESE student documentation exceptions……………………………….....10 Table 6. Summary of ELL student documentation exceptions……………….…………..…..…10 Table 7. Summary of ESOL teacher certification exceptions……………………………...……11 Exhibit A. Abbreviations……………………….………………………………………...……..11 Exhibit B. How an FTE adjustment is calculated………………………………………...……..12 Exhibit C. Florida Auditor General Website…………….………………………………..…….12 Corrective Action Responses………………………..…………………………………….….13-20 Florida Auditor General 2009 FTE Audit Final Report available at:

http://www.myflorida.com/audgen/pages/pdf_files/2011-005.pdf


The School Board of Broward County, Florida

Office of the Chief Auditor

Audit Advisory

Pertaining to the State of Florida Auditor General

Florida Education Finance Program (FEFP) Full-Time Equivalent (FTE) Students and Student Transportation

Audit of Fiscal Year 2009 The State of Florida Auditor General, Florida Education Finance Program (FEFP) Audits Section, recently audited fiscal year 2009 Full-Time Equivalent (FTE) student documentation and teacher certification at 46 Broward schools, centers, and agencies. The audit also included a review of Pupil Transportation ridership reporting for fiscal year 2009. The Florida Auditor General issued a draft audit report June 18, 2010, allowing the statutory 30 days for our response, and released the final report, Number 2011-005, on August 9, 2010. Teacher certification and student documentation findings in the final audit report resulted in negative adjustments totaling (1,470.7387) weighted FTE. The revised base student allocation of $3,886.14 for FY 2009 multiplied by the Broward District Cost Differential of 1.0279 yields a value of $3,994.56 per weighted FTE. This results in a potential financial loss to the District of roughly $5.87 million for teacher certification and student documentation findings. There is no reliable way to predict the financial impact of Student Transportation findings. The Florida Auditor General has historically audited FTE reporting in Broward County Public Schools every three years, in a predictable fashion. In June 2010, the Auditor General announced a change from a three-year fixed cycle of audits of the Florida Education Finance Program and Student Transportation, to scheduling examinations based on auditor judgment. Although it is most probable that one year out of every three will be audited, we are no longer assured that any particular year will be targeted. Therefore, we must be aware that failure to comply with FDOE documentation rules and teacher certification requirements in any school year could result in funding losses.

Office of the Chief Auditor 2009 State FTE Audit Advisory 1

Contracted Agency Source Attendance Documents

• The most costly finding was caused by failure to produce source attendance documents acceptable to the Auditor General’s office. An audit adjustment of (992.1840) weighted FTE was issued for 100% of the students reported for FTE by Alternatives Unlimited, Inc. (Drop Back In), a contracted dropout prevention agency, for a potential financial penalty of approximately $3.96 million.

ESE Student Documentation

• ESE documentation for 92 students in program 254 or 255 did not contain evidence that the funding matrix had been reviewed or updated at the time the relevant IEP was prepared. This problem caused audit adjustments totaling (213.4720) weighted FTE, with a potential financial impact of approximately $850,000.

Hospital and Homebound Classification of Students at Residential and Day Treatment Facilities

• A separate finding appeared in the audit report stating the position of the Auditor General on the Hospital and Homebound classification of students placed in residential and day treatment facilities. The Auditor General asserts that these students should be reported in Dropout Prevention rather than ESE programs. No audit adjustment was attached to this finding, for this audit year.

Teacher Certification

• One teacher of ESE Pre-K students at Bauhuin School, a contracted agency, did not meet the General Knowledge requirements within a year after hire, resulting in an audit adjustment of (24.6360) weighted FTE, with a potential funding penalty of approximately $98,410.

• The remaining teacher certification adjustments amounted to (21.4126) weighted FTE (exclusive of teacher certification findings related to Drop Back In.) This is a marked improvement in SBBC teacher certification findings when compared to the previous audit.

o When choosing course numbers and assigning teachers to classes, school

staff must compare each teacher’s certifications to certifications allowed by the course code directory for each particular course number, with attention to the program classifications of students enrolled in the course section.


o Parents must be notified by schools of out-of-field teachers in writing prior to the FTE survey week. The letter must be dated, and the out-of-field teaching areas for each teacher must be listed. Electronic notification of parents (website or email) is not acceptable. This was a particularly troublesome area, causing audit adjustments when the other steps in the out-of-field waiver process had been properly completed.

o Schools must also track the progress of their out-of-field teachers with regard to their required coursework timelines.

ESOL Teacher Certification

• A common audit exception occurs when teachers complete 300 points ESOL inservice training, then fail to apply to the Florida Department of Education to have the ESOL endorsement added to their teaching certificates. Category 1 teachers are not in-field in ESOL until the FDOE adds the ESOL endorsement to their teaching certificates.

• Teachers of category 2 courses such as mathematics, science, social studies, and

computer literacy are required to achieve 60 points in ESOL inservice coursework within two years of beginning to teach their first ELL student. Since category 2 teachers are not required to obtain a Department of Education endorsement in ESOL, nor be formally Board approved out-of-field in ESOL if they lack the required coursework, it is easy for their out-of-compliance status to be overlooked.

ELL Student Records

• Instructions from the FDOE indicate that student ELL plans must be reviewed and updated at the beginning of each school year. Schools were cited for failure to document the timely review and update of over 500 ELL plans.


• Premature 4th, 5th, or 6th year assessments of a total of 87 ELL students were noted in the audit findings. The appropriate assessment tool is required to be administered immediately prior to the student’s 4th, 5th, or 6th year program entry anniversary.

• An annual review at the beginning of the school year is required, as well as a complete re-evaluation just before the student’s program entry anniversary for continued placement in the 4th, 5th, or 6th year in the ELL program. Any time a 4th, 5th, or 6th year ELL student scores at C1 level on an English language assessment test, but there is good reason to place or retain the student in the ELL program, an LEP committee must document the validity of the ELL placement by assessing and documenting the presence of two of five criteria outlined in the LULAC settlement. Many of the 4th, 5th, and 6th year ELL students who tested Fluently English Speaking might have been properly coded Program 130 if the correct supporting documentation had been present in the students’ files.

• Six years is the maximum that a student can be funded in the ELL program.

Every ELL student in 6th grade and beyond should be checked to see if they are still eligible for program 130 funding. This should be done immediately before each FTE survey, because eligibility is based on each student’s original program entry date.

Vocational/OJT Timecards

• On-the-Job-Training Timecards are required to support a student’s work schedule, and are the source attendance document for OJT courses. FTE audit adjustments for missing timecards reduce funding to zero for the student in the OJT course.

• The teacher and the employment supervisor must sign each time card promptly

after the end of the period covered by the time card.

• Timecards for all OJT students must be kept on file with FTE records. Requiring vocational teachers to turn in student timecards after each FTE survey week and at the end of the year would help maintain these records for audit purposes.

General Comments

• Many schools apparently do not review student documentation when new students and their records arrive at the school. In many cases, FTE audit adjustments were made for documents which should have been in a student’s records, but were missing when the records arrived from the sending school. These problems should be identified at the time student records are received, and corrected immediately. This is a prevalent problem when students move from elementary to middle school, or middle to high school, and schools receive many incoming student records at the same time. Schools should review for deficiencies in student records when the records first arrive.


• In particular, the ESE and ELL student folders should be reviewed for completeness and correctness of documentation just before the October and February FTE surveys. New, currently dated documentation should be prepared immediately if any documentation or forms are missing or deficient. Doing this just prior to the FTE surveys would mean the paperwork would be valid, correct and up to date during the FTE survey week, which is the time period targeted by the FTE auditors.

Pinnacle

• The auditors noted that teachers could and often did mark all students present in Pinnacle a week in advance.

• They also observed that Pinnacle passwords were not automatically required to be changed on a regular basis.

Transportation

• Transportation should only transport ESE students after they have received a valid IEP that states in detail the reason for the need for transportation services and the extent of the services and equipment needed for the student.

• The Florida Department of Education considers seat belts, harnesses, and safety vests standard equipment, so in order to claim weighted funding for the use of these devices, the student’s IEP must document what exactly about the particular student’s unique medical condition makes it necessary to use the harness or safety vest.

• 4,256 students were incorrectly reported programmatically for 15 days-in-term in

survey 1 in July 2008. ETS corrected this data processing error when the auditors reported it, so that days-in-term errors occurred only on a limited basis during survey 4 in June 2009.

• 110 students were incorrectly reported as Center-to-Center riders for intersession transportation between Hallandale Elementary and Gulfstream Middle. There is no category designated for reporting inter-campus transportation of students who are enrolled in only one school.

• Thorough documentation, including the student’s signature, date, Bus Pass number and the signature of the issuing school administrator, is required when Bus Passes are issued to students using public transportation to travel to school. This documentation requirement applies to all Bus Passes, including those issued to students by charter schools and contracted agencies.


Conclusion FTE adjustments are becoming more severe with each successive audit. Negative weighted FTE adjustments were (199.4531) for the FY 2000 audit, (263.8189) for FY 2003, (357.3491) for the FY 2006 audit, and (1,470.7387) for the current FY 2009 FTE audit. Of the (1,470.7387) weighted FTE adjustment, (992.1840) were attributable to missing Drop Back In student sign-in sheets, while (24.6360) were precipitated by a contracted agency’s teacher’s failure to promptly fulfill FDOE General Knowledge requirements. Weighted FTE adjustments attributable to BCPS teacher certification deficiencies totaled (21.4126). The remaining (432.5061) total weighted FTE adjustments stem from deficiencies in student records. Even without the losses generated by contracted agencies, the adjustments for the FY 2009 audit are in excess of the FY 2006 audit adjustments, continuing the trend of escalating audit adjustments and funding penalties. There will be an opportunity to appeal to the Department of Education for reversal or amelioration of the audit findings and the associated financial adjustments at a future date. The Department of Education arranges the informal conference and determines when it will occur. The funding penalties will not be calculated and applied by the Florida Department of Education Office of Funding and Financial Reporting until after this informal appeals conference has taken place. Of particular concern at this time is the Department of Education’s requirement that each ESE student’s Matrix of Services form be reviewed and updated (or a new Matrix prepared) every time a new IEP is prepared. The Matrix of Services is the form for assessment and documentation of program funding level. Easy IEP, the automated document creation and storage system, may not facilitate recording the review of an existing Matrix. It is in our best interests as a District to pay attention to FTE reporting requirements, student documentation, teacher certification, and Transportation records in order to avoid being financially penalized for FTE audit findings every three years. Most of these audit findings are the result of deficiencies in documentation of services that were actually properly provided to eligible students. The next anticipated State FTE audit will likely cover the 2011-2012 school year, which begins in July 2011, less than one year from now.


Table 1. Number of Exceptions Area of examination Sample

size Number of exceptions

Percent of sample with exceptions

Teacher Certification 775 136 18%

ELL student records 2,786 808 29%

ESE Program 254 and 255 student records 885 194 22%

OJT student records 338 58 17%

Basic student not in membership or attendance 489 15 3%

Individual bus rider records 748 194 26%

Non-sampled bus riders reported improperly 171

District-Wide ESOL-Ineligible Course 1 course / 1 student Table 2. Summary by Total of Exceptions in Category


Type of Exception Weighted FTE Adjustment Potential Dollar Impact

Attendance Records Missing (992.1840) $ (3,963,339)

ESE Student Documentation (336.1365) $ (1,342,717)

ELL Student Documentation (45.7320) $ (182,679)

Membership and Attendance (45.3403) $ (181,114)

Teacher Certification GK (24.6360) $ (98,410)

ESOL Teacher Certification (9.4348) $ (37,688)

Vocational Teacher Certification (5.5823) $ (22,299)

ESE teachers needed reading endorsement (5.2747) $ (21,070)

OJT Students (4.9947) $ (19,952)

No valid FDOE Certification (0.9217) $ (3,682)

ESE Teacher Certification (0.1959) $ (783)

Reading endorsement needed (non-ESE) (0.1931) $ (771)

Subject Area Teacher Certification (0.1101) $ (440)

District-Wide ESOL-Ineligible Courses (0.0026) $ (10)

Total (1,470.7387) $ (5,874,954)

Table 3. Subtotal of Exceptions Grouped by ESE, ELL, and OJT

Type of Exception Weighted FTE Adjustment

Potential Dollar Impact

Potential DollarImpact

Attendance Records Missing(Drop Back In) (992.1840) $ (3,963,339) $ (3,963,339)

ESE ESE Student Documentation (336.1365) $ (1,342,717)

ESE Teachers needed Reading Endorsement (5.2747) (21,070)

ESE Teacher Certification (0.1959) (783) $ (1,364,570)

ELL ELL Student Documentation (45.7320) $ (182,679)

ESOL Teacher Certification (9.4348) (37,688) $ (220,367)

Student not in Membership or Attendance (45.3403) $ (181,114) $ (181,114) Teacher certification GK PK ESE agency (24.6360) $ (98,410) $ (98,410) OJT and Vocational OJT Students (4.9947) $ (19,952)

Vocational Teacher Certification (5.5823) (22,299) $ (42,251)

No valid FDOE Certification (0.9217) $ (3,682)

Subject Area Teacher Certification (0.1101) (440)

Reading Endorsement needed (non-ESE) (0.1931) (771) $ (4,893) District-Wide ESOL-Ineligible Courses (.0026) $ (10 ) $ (10)

Total (1,470.7387) $ (5,874,954)


Table 4. Student Documentation and Teacher Certification Summaries

Type of Exception Weighted

FTE Adjustment



Teacher Certification

Teacher certification GK PK ESE agency (24.6360) $ (98,410)

ESOL Teacher Certification (9.4348) (37,688)

Vocational Teacher Certification (5.5823) (22,299)

ESE Teacher Certification (5.4706) (21,853)

No valid FDOE Certification (0.9217) (3,682)

Reading endorsement needed (non-ESE) (0.1931) (771)

Subject Area Teacher Certification (0.1101) (440) $ (185,143)

Student Documentation ESE Student Documentation (336.1365) $ (1,342,717)

ELL Student Documentation (45.7320) (182,679)

OJT Student Timecards (4.9947) (19,952) $ (1,545,348)

Attendance Records Missing (992.1840) $ (3,963,339) $ (3,963,339)

Student not in Membership or Attendance during survey (45.3403) $ (181,114) $ (181,114)

District-Wide ESOL-Ineligible Courses (0.0026) $ (10) $ (10)

Total (1,470.7387) $ (5,874,954)


Table 5. 2009 State FTE Audit ESE Student Documentation Exceptions

Type of exception Weighted

FTE adjustment

Percent of ESE student

adjustments Matrix not reviewed and updated with each IEP (213.4720) 64%

Student program not reported in accordance with Matrix (68.1774) 20%

Students in outside facilities claimed as 255 when Matrix supported 254 (24.6810) 7%

IEP and/or Matrix either missing or not valid for survey (14.8880) 5%

Incorrectly added 3 special consideration points to Matrix (11.2680) 4%

IEP committee composition incomplete (1.9590) Less than 1% Student’s schedule not reported with correct minutes of instruction in proper ESE program (1.6911) Less than 1%

Gifted EP not valid for survey 0 0

Total ESE student weighted FTE adjustments (336.1365) Table 6. 2009 State FTE Audit ELL Student Documentation Exceptions


FTE adjustment

Percent of ELL student findings

Student’s ELL plan not reviewed and updated at beginning of school year (26.5894) 58%

Incorrect number of instructional minutes claimed in program (7.2027) 16%

Students tested FES and were placed in ELL program without committee approval (3.7032) 8%

Inadequate parent notice (2.8921) 6% Test to justify 4th, 5th, or 6th year in ELL program was not administered within an acceptable window of the student’s program entry anniversary (2.4272) 5%

Student’s ELL file missing (1.6056) 4%

Student exited from ELL program before FTE survey (0.4485) 1%

Student beyond 6th year in ELL program (0.2915) Less than 1%

ELL committee met but did not document 2 criteria for placing student in program (0.1843) Less than 1%

Miscellaneous other (0.3875) Less than 1%

Total ELL student documentation weighted FTE adjustments (45.7320)


Table 7. 2009 State FTE Audit ESOL Teacher Certification Exceptions


FTE adjustment

Percent of ESOL teacher

certification findings

Category 1 teacher out-of-field in ESOL without proper OOF process (7.8552) 83%

Out-of-field in ESOL plus Reading without proper OOF process (0.3107) 3% Category 2 teacher beyond 2 years without 60 points in ESOL coursework (1.2689) 14%

Total ESOL teacher certification weighted FTE adjustments (9.4348)

Exhibit A. Abbreviations

BCPS -- Broward County Public Schools C1 -- test score indicates English proficiency ELL -- English Language Learner EP -- Educational Plan (Gifted) ESE -- Exceptional Student Education ESOL -- English for Speakers of Other Languages ETS -- Education Technology Services (SBBC department) FEFP -- Florida Education Finance Program FES -- Fluent English Speaker FDOE -- Florida Department of Education FTE -- Full-Time Equivalent (Students) FY -- Fiscal Year GK -- General Knowledge (FDOE teacher certification testing requirement) IEP -- Individualized Education Program LEP -- Limited English Proficiency or Limited-English-Proficient LULAC -- League of United Latin American Citizens OJT -- On-the-Job Training OOF -- Out-of-Field PK -- Pre-Kindergarten SBBC -- School Board of Broward County



Exhibit B. How an FTE adjustment is calculated Revised base allocation for 2008-2009 $3,886.14 Times Broward County cost differential for 2008-2009 X 1.0279 Equals Funding per weighted FTE in Broward 2008-2009 $3,994.56

Example: Finding #251—Matrix not reviewed and updated timely for 11 ESE students

Program number Unweighted FTE Cost Factor Weighted FTE

Adjustment Potential

Funding Loss 111 7.5000 X 1.066 = 7.9950 112 2.0000 X 1.000 = 2.0000 254 (6.5000) X 3.570 = (23.2050) 255 (3.0000) X 4.970 = (14.9100)

Total 0 (28.1200) (28.1200) X $3,994.56 ($112,327.03)

Exhibit C. Florida Auditor General Website

Florida Auditor General home page:

http://www.myflorida.com/audgen/

Report No. 2011-005 Broward County District School Board

Florida Education Finance Program (FEFP) Full-Time Equivalent (FTE) Students and Student Transportation

For the Fiscal Year Ended June 30, 2009


http://www.myflorida.com/audgen/


THE SCHOOL BOARD OF BROWARD COUNTY, FLORIDA

EDUCATION TECHNOLOGY SERVICES Jeff Stanley, Director School Applications

Telephone: (754) 321-0329 Fax: (754) 321-0905 Date: 12/10/2010 TO: Ann Conway Office of the Chief Auditor FROM: Jeff Stanley, Director School Applications SUBJECT: 2009 FTE AUDIT ADVISORY This memo is a response to 3 issues of concern identified in the 2009 Auditor General’s FTE audit report. Pinnacle

• The auditors noted that teachers could and often did mark all students present in Pinnacle a week in advance.

Allowing schools to enter attendance in the future allows them to record absences in advance in the case of vacations or suspensions. This is seen as a time-saving function for the schools. Unfortunately, having this function also permits teachers to misuse it by marking students present. We will re-emphasize the proper use of this feature during training.

• They also observed that Pinnacle passwords were not automatically required to be changed on a regular

basis.

The Pinnacle system will allow teachers to change the password at any time, however they do not expire. The software vendor does not offer this feature based on the experience of its customers that teachers will forget the password if they are required to change it often, necessitating the need to re-set passwords.

Transportation • 4,256 students were incorrectly reported programmatically for 15 days-in-term in survey 1 in July 2008.

ETS corrected this data processing error when the auditors reported it, so that days-in-term errors occurred only on a limited basis during survey 4 in June 2009.

ETS has corrected the programming error that caused this miscalculation of days-in-term.

If you have any questions, please call me at 754-321-0329.

JS:tbm

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