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— PGCPS Great By Chatce May 4, 2016 MEMORANDUM, To: Gwendolyn J. Mason, Bd D,, Associate Superintendent Student Services Adrian B. Talloy, Ed, D., Executive Direotor Student Services ‘From: Michele Winston, CPA, Directo aS Jnteimal Audit Re: Assessment of Student Records for the Period July 1, 2013 through Jume 30, 2015 ‘An audit of student records for Office of Student Records, Transfers, and Archival Services (OSRTAS) ‘was completed for the period July 1, 2013 through June 30, 2015, ‘The audit report indicates that the programs” business processes and internal controls require improvement. ‘The office must streamline and document its processes to ensure efficient administration of students’ records, Implementation of recommendations will be useful in achioving this objective. Additionally, management's dedication to oversight will ensure that its’ mission is realized. ‘The exceptions noted are included in the attached report. Please provide an action plan within 30 days of receipt of this report, indicating steps that will be taken to ensure compliance with the recommendations. Please note that you are required fo provide your action plan using the attached Microsoft word template and any other correspondence to the Intemal Audit Office, Attention: Derrick Martin, Business Analyst, email address: destick mertin@pgeps.org. Enolosure co, Segun Eubanks, Ed. D., Board Chair Kevin Maxwoll, Ph. D,, Chief Executive Officer of Schools Monique Whittington Davis, Ed. D., Deputy Superintendent Brica Berry, Bsq., Executive Director, Board of Education Boverly Anderson, Ph. D., Board Member Gayle Huggins, Supervisor, OSRTAS ‘Wesley Wats, Jr, Chief Information Officer, Information Technology ‘Shawn Joseph, Hd. D., Deputy Superintendent, Teaching and Learning Prince George's County Pubic Scool | Internal Audt Department [Michele Winston, CPA W701 SCHOOL LANE, UPPER MARLBORO, MD 20772 Phone: 301-780-6888 Website: sei.PGCHS ong Internal Audit Report Assessment of Student Records Operational Audit For the Period Ended June 30, 2015 Assessment of Student Records Operational Audit For the Period Ended June 30, 2015 BACKGROUND ‘Student Engagement and’School Support, of which the Office of Student Records, Transfers and Archival Services (OSRTAS) is an integral part, provides direction, monitoring and tracking of school administrators and staff to ensure compliance with local, state and federal mandates in the areas of Records Compliance, Bullying Reporting, Alcohol, Tobacco and Other Drugs (ATOD) counseling completion and 504 Office of Civil Rights Compliance, Their goal is maintenance of accurate student records which are compliant with regulations and procedural standards that achieve the following outcomes: * All student records are available for review with a school employee present, unless court restricted access has been issued. ‘* Student records are made available for review in a school within 3 days of receipt of @ request. © Copies of student records are made available to parents or eligible students at a cost determined by the Board of Education. Currently, that cost is 25 cents per page/per copy. * When a student transfers to another Prince George's County Public School (PGCPS), all student records are sent to that school. Student records requiring transfer to another Maryland public school are made available with parental permission. The only exception to this requirement is compliance with a court order, subpoena, or state statute. The OSRTAS is under the direction of the Supervisor, Student Records and Transfers. The FY 2016 budget for OSRTAS is approximately $1 million with 15 FTEs. SUMMARY Internal Audit (IA) conducted an operational audit of selected student records of PGCPS for the period July 1, 2013 through June 30, 2015. The audit was conducted as part of Internal Audit’s FY 2016 annual audit plan. ‘The audit included a review of a total of 28 schools and 200 student records, for compliance with PGCPS?’ policies and procedures which provides guidance for the administration of student records approved by the BOE and the Maryland State Department of Education (MSDE). The audit results include the following findings: 1, Management Oversight — Opportunities for Strengthening Management's Current Internal Control Environment; uel CONFIDENTIAL Page 2 Assessment of Student Records Operational Audit For the Period Ended June 30,2015 * MSDE Maryland Student Record System Manual © The Student Enrollment Guide © Administrative Procedure 5010, Homeless Children and Youth-School Access and Services © Administrative Procedure 5111, Registration and Withdrawal of Students © Administrative Procedure 5118.1, Informal Care Arrangements and the Enrollment Non- Resident Students © Administrative Procedure 5125, Individual Student School Based Records © Administrative Procedure 5161, Immunizations FINDINGS AND RECOMMENDATIONS ‘The results of the test work revealed the following findings and recommendations: Finding 2016.01 Management Oversight - Opportunities for Strengthening Management’s Current Internal Control Environment 1) IA noted key control weaknesses posing vulnerability or immediate threats to achieving optimal service delivery for administration of PGCPS’s Student Records.” The following findings, if corrected, will provide opportunities for strengthening the internal control environment within The Office of Student Records, Transfers and Archival Services (OSRTAS): Bi-Annual Audits ~ Principals are not conducting bi-annual audits in compliance with AP# 5125, Individual School-Based Records, section b.1. Mandatory Training Training is not conducted consistently for new registrars; Principals do not receive training, Compliance Reviews/Reporting — Schools do not receive sufficient review and follow-up annually, Federal Compliance ~ Schools are not in compliance with Family Educational Rights and Privacy Act (FERPA) by notifying parents of their rights under the guidelines. Non-Resident Tuition ~ A tracking system is not in place to ensure that all tuition payments are .d by PGCPS. —_————_ CONFIDENTIAL Page 4 Assessment of Student Records Operational Audit For the Period Ended June 30, 2015 notification must include information regarding a parent's right to inspect and review his or her child's education records, the right to seek to amend the records, the right to consent to’ disclosure of personally identifiable information from the records (except in certain circumstances), and the right to file a complaint with the Office regarding an alleged failure by a school to comply with FERPA. The schoo! must also inform parents of its definitions of the terms "school official" and “legitimate educational interest”. The school may provide the annual notification by any means likely to inform parents of their rights.” 5) Administrative Procedure (AP) 5118.1, Informal Care Arrangements and the Enrollment Non-Resident Students states, "The Application for Enrollment of a Non-Resident Student (PA-26) and the payment of tuition unless explicitly waived must be submitted along with the normal proof of residence to complete the enrollment at a neighborhood school. Charter schools and dedicated program schools may not accept non-resident students without a letter of approval for the current school year from the Office of Pupil Accounting and School Boundaries, the Office of Appeals or the Board of Education.” The registrar should send the Application to Enroll Non-resident Tuition Student and the check for tuition to the Treasurer's Office with a copy to the Office of Pupil Accounting and Schoo! Boundaries ‘Management has not enforced sound internal controls by ensuring accountability throughout the Department and in respective schools. Additionally, there is an apparent disconnect between departments involved in the management of student records, Furthermore: * Compliance reviews periodically conducted by Student Records staff at the school level are ineffective. Schools do not receive timely feedback fom compliance reviews as evidenced by the current backlog of reports, Also, there is no school rotation amongst compliance specialist. ‘+ School staff responsible for maintenance of records have not received timely or adequate training to perform their responsibilities. ‘An inadequate control environment has impacted management's ability to provide optimal service to its stakeholders, This includes providing oversight and governance necessary to achieve an acceptable level of performance for effective and efficient operations regarding the student records. Inadequate student records management could result in loss of funding by way of the assessment of fines from MSDE. ——_—$<— CONFIDENTIAL, Page 6 Assessment of Student Records Operational Audit For the Period Ended June 30, 2015 Management must also ensure that: 1 ‘Training on records management is periodically assessed through development of intemal performance metrics with the ‘Training Coordinator and respective Supervisors. Items assessed or measured may include: 1.) Total number of trainings administered; 2.) Statistics on training types per year, and what positions require mandatory attendance; 3.) ‘Total number of staff not availing themselves to training; 4.) Supervisor feedback for any noted efficiencies gained with delivery of staff training, A process is implemented to streamline the compliance and reporting processes. The compliance review and reporting process must be formally evaluated to ensure that suitable time is allotted for reaching more schools. A compliance checklist, (i.e. “Exceeds/Meeis/Does Not Meet Management's Expectations”, “Improvement Needed”, “Unacceptable”, etc.) should be considered and left with the Principal and Registrar with a determined deadline for follow up. Ifno significant improvement has been made, then a formal report should be sent, Quarterly, summarized performance reports can be sent to Instructional Directors. This should be done to promote uniformity and consistency with delivering the best possible service, while allowing time for other duties 2016.02 Student Records Not Properly Maintained ‘The following 72 instances of non-compliance with OSRTAS records management were noted at several schools, There were: 9 schools with unsecured files. Record rooms or record cabinets were unlocked throughout the school day. 9 schools where the files were disorganized. Files were found in piles on the floor or on top of the record cabinets, 5 instances where student records, requested in the audit sample, could not be locate. 26 records were found without logs of review to monitor access to students” records. 17 cumulative folders without “LAF Available”, indicating that Limited Access Folders were also available for those students. 6 cases where sensitive information was found in the cumulative folder. Page 8 Assessment of Student Records . Operational Audit For the Period Ended June 30, 2015 A solution for enabling SchoolMax to tally graduation credits should be determined. (See Finding 2016.04). © OSRTAS should determine a schedule dedicated to resolving the microfilming backlog. * OSRTAS should also continue to identify schools with disorganized and incomplete records. Efforts should be made to provide solutions to incomplete records prior to student transfers. 2016.03: Noncompliance with Registration Documentation ‘The following 213 instances of noncompliance with PGCPS registration documentation requirements were noted based on review of 200 students’ files. There were: * 69 instances where a PA-14 Student Registration Forms were incomplete or unsigned. © 33 instances where a PA-15 Affidavit of Disclosure Forms were not found in the students’ records, In 39 other instances, the PA-15s were incomplete. © 2 instances where no proof of birth was found in the students’ records. In 4 other instances, the proof of birth was insufficient. #18 nstances where proof of birth did not match SchoolMax information. * 7 instances where proof of residency was not found in the students” records, In 18 other instances, the proof of residency was insufficient. © 12 instances where shared housing affidavits were not current. © 11 instances where Homeless Student Services Forms were not properly sent to the Homeless Education Coordinator for review. AP SILI, Registration and Withdrawal of Students, reflects MSDE enrollment regulations and describes the procedures for student registration with PGCPS: * The parent/guardian must complete the Student Registration Form, PAl4 when registering a student, The parent/guardian must also complete the A‘fidavit of Disclosure, PAIS when registering a student for the first time. School personnel (copistrar/secretary) must review and sign the PA14 and PALS to ensure that all items of information are completed and proof of residence verified. —_—_—_—]—— ————— CONFIDENTIAL Page 10 ‘Assessment of Student Records Operational Audit For the Period Ended June 30, 2015 Recommendations - Pupil Accounting & Schoo! Boundaries and OSRTAS management should collaborate with Instructional Directors and Principals to ensure that all schools are represented at mandatory student records and registration trainings. In addition, OSTRAS should conduct semi-annual surveys to identify new members of student record teams for core training. The Executive Director of the Department of Student Services should consider requesting budgetary allocations supporting 12 month positions for all registrars and records secretaries to censure consistency in the registration process. 2016.04 BOE Non-Compliance with State Mandates and Graduation Summary Completion ‘There is.no standard operating procedure to ensure full compliance with State of Maryland mandate regarding student records, The school Counseling Department and the OSRTAS have not documented a process to prevent or respond to instances of errors resulting from improper or ely completion of the Graduation Standard Credit Summary. As a result, the following tions were identified by Internal Audit: unti exc 1. Untimely Completion of Graduation Standard Credit Summary: «The Graduation Standard Credit Summaries used by guidance counselors to determine whether MSDE graduation requirements have been met were not completed for all students prior to graduation. This process requires counselors to manually tally credits for each potential graduate which has resulted in errors. 2. Inadequately Maintained Maryland State Department of Education Student Record (SR) Cards © SR-I (Personal Data) - IA reviewed SR-I cards from the Oracle Application Express (APEX) system that omitted student personal information. > There were 101 instances where data elements such as evidence of students’ birth, residence history and the names, dates and titles of individuals who verified evidence of students’ birth were not provided. > Included in the 101 instances was 1 instance where a student could not be located in APEX via the student ID number since the “Primary Family or Legally Responsible Adult” was not entered on the SR-1. © SR-2 (Annual Early Childhood/Middle School Performance) - There were 15 instances where data maintained in SchoolMax were not displayed in APEX, Annual school performance information for students in grades (K through 8) required on the SR-2 could not be located in APEX. However, the students’ report cards printed from SchoolMax were aveilable in the cumulative files, Page 12 Assessment of Student Records . Operational Audit For the Period Ended June 30, 2015 ‘SR-2- Annual Early Childhood/Middle School Performance SR-3- Annual Secondary School Performance SR-4- State Mandated and Local Education Agency Testing sR SR Health Screening, Maryland Student Exit Record vvvvy «AP 5125 Section Al, Category 1 Data, provides guidance on data that shall be maintained in the Cumulative Folder on the appropriate State SR cards for all students. © The Student Enrollment Guide details that the Cumulative Folder must contain the SR, in the following order: a, SR+l card - download a copy of the SchoolMax Student Enrollment History that includes the enrollment code and insert behind side 2 of the SR-1 card. A duplicate copy of the final report card should be inserted behind the SR-1 card to capture the year-end attendance. b. SR-2 card - download copy of the SchoolMax Student Transcript and insert behind the SR-2 card ©. SR-3 card - download a copy of the SchoolMax University Style Transcript and insert behind the SR-3 card d. SR-3B (HSA Test Card), SR-4 and SR-5 cards. The SR-5 card may be maintained in the Health Room instead of the Cumulative Folder © AP 5125 Section BA states Category I Data made on the PS-46 Permanent Records Card shall be dated by the recorder. All Category II material placed in the student's records shall be signed and dated by the person authorizing or placing the material in the records. «The Student Enrollment Guide states that the SR-1, SR-2, SR-3, SR-4, DHMH 896, the student enrollment history, the final report card, the student transcript and the university style transcript are maintained permanently on microfilm. ‘The Permanent Record Card (PS-46) is kept forever at the school. The Student Enrollment Guide details that the Transfer Record Card or SR-7, from the previous school the child attended should accompany a student transferring to a new school, AP 5111.1 Section D also states if the student is transferring from another PGCPS school, the parent/guardian should present the Maryland Student Withdrawal/Transfer Record Card (SR-7). ———_——_— CONFIDENTIAL, Page 14 Assessment of Student Records Operational Audit For the Period Ended June 30, 2015 ‘© High school guidance counselors must be required to tally the Graduation Standard Credit Summary for each student eligible for graduation prior to submitting the list of graduates for preparation of diplomas. This will ascertain that students meet the MSDE requirements for graduation, Principals should hold guidance counselors accountable for timely completion. * The Depariment of Academies should reorganize the SchoolMax course catalog in a ‘manner that ig more uniform where course names can be easily traced to the Graduation Standard Credit Summary. ‘The Division of Information Technology should assist in this process to provide a more efficient means for the data in SchoolMax to be used in computing graduation credits ‘© The OSRTAS, Division of Information Technology and other impacted departments should devise a plan for generating reports at predetermined intervals during the school ‘year, identifying data not entered in APEX during the student registration process. ‘© The 2016 Maryland Student Records Manual should be referenced by the Office of Student Records, Transfers & Archival Services, IT department and other impacted departments to ensure state SR-7 cards include the state ID number in compliance: with the State of Maryland guidelines OPINION, Based upon the results of the audit, it is our opinion that the Office of Student Records, Transfers, and Archival Services’ business processes and internal controls require significant improvement to be in compliance with BOE policies and MSDE requirements, Noncompliance with BOE and MSDE requirements can lead to citations if noted during MSDE’s biennial audit. The most recent MSDE Enrollment Audit that found attendance, immunization record, and proof of residency shortcomings for approximately 9 students resulted in citation of $537,353. In comparison, this audit noted 45 exceptions in those areas and a corresponding MSDE citation would likely be much higher. ‘The OSRTAS must streamline and document its processes to ensure efficient administration of student records, Implementation of recommendations will be useful in achieving this objective. Additionally, management's dedication to oversight will ensure that its’ mission is realized. ACKNOWLEDGEMENT We would like to thank the management and staff of the Department of Special Education and Student Services for their cooperation and assistance during the audit. 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