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Child Custody Letter of Recommendation Templates

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									Summary of Title I Monitoring, Part A, FYs 2005 and 2006
See the key at the bottom for an explanation of the chart and its abbreviations.


Indicator           Indicator Description
 Number                                                                      Alaska
                                                                        May 15-19, 2006
                                                                             F=22
                                                                             R=6
Overarching
Requirement
   F=26
   R=5




                                                           F: Inadequate Monitoring: McKinney
                  The SEA conducts monitoring of its
                                                           Homeless (8)
                   subgrantees sufficient to ensure
                                                           The SEA conducted no McKinney-
                compliance with program requirements
                                                           specific reviews of the sampled LEAs.
               under the Part A school district program,
                                                           There are a few references to homeless
                 Even Start, the Part D Neglected and
                                                           kids in the Title I consolidated review, but
                 Delinquent Program (N&D), and the
                                                           not enough to ensure McKinney
                 McKinney-Vento Homeless program.
                                                           compliance.




Indicator 1.1
                SEA has approved academic content
     F=2
              standards for all required subjects or has                       MR
    R=0       an approved timeline for developing them.
Indicator 1.2
     F=9
    R=3



                   The SEA has approved academic
                  achievement standards and alternate
                  academic achievement standards in         MR
                required subject areas and grades or an
                    approved timeline to create them.




Indicator 1.3
    F=11
    R=4



                The SEA has approved assessments and
                   alternate assessments in required
                                                            MR
                  subject areas and grades or has an
                    approved timeline to create them.




Indicator 1.4
     F=3
    R=3


                    Assessments should be used for
                 purposes for which such assessments
                are valid and reliable, and be consistent
                  with relevant, nationally recognized
                                                            MR
                 professional and technical standards.
                   Adequate yearly progress shall be
                defined by the state in a manner that is
                      statistically valid and reliable.
Indicator 1.5
     F=4
    R=2




                 The SEA has implemented all required
                    components as identified in its                             MR
                       accountability workbook.




Indicator 1.6
    F=10
    R=0       The SEA has published an annual report
                card as required and an Annual Report to                        MR
                              the Secretary.



Indicator 1.7
    F=12
                                                             F: Data Elements Missing, Local (12)
    R=3
                                                             One district report card did not include
                                                             data on the percentage of low-poverty
                 The SEA has ensured that LEAs have          classes taught by highly qualified
                   published annual report cards as          teachers and the most recent two-year
                               required.                     trend in student achievement. Another
                                                             district omitted three different data
                                                             elements, and a third had no report card
                                                             at all.


Indicator 1.8
               The SEA indicates how funds received
     F=0
              under Grants for State Assessments and
    R=0       related activities (§6111) will be or have                        MR
                been used to meet the 2005-06 and 2007-
                 08 assessment requirements of NCLB.

Indicator 1.9     The SEA ensures that LEAs meet all
     F=0            requirements for identifying and
    R=0             assessing the English language                              MR
                 proficiency of limited English proficient
                                  students.


Indicator                    Description
 Number                                                                       Alaska
                                                                         May 15-19, 2006
Indicator 2.1
     F=6
    R=2


                                                           R: Plan for Paraprofessional Support (2)
                   The SEA designs and implements          The state should prepare a plan to assist
                 procedures that ensure the hiring and     paraprofessionals who have not met the
                retention of qualified paraprofessionals   highly qualified requirements, including
                and ensure that parents are informed of    strategies to maintain and/or transfer
                    educator credentials as required.      paraprofessionals, as appropriate, prior
                                                           to the 2006-07 school year.




Indicator 2.2
     F=5
    R=3




                 The SEA has established a statewide
                  system of support that provides, or
                  provides for, technical assistance to
                     LEAs and schools as required.                            MR
                 See critical element 2.4 for additional
                   technical assistance requirements.
Indicator 2.3
    F=17
    R=9




                                                          F: Parental Involvement Policy (12)
                                                          Two separate findings relating to parental
                                                          involvement policies: The state did not
                                                          ensure that all schools had policies, and
                                                          one district policy did not contain all
                  The SEA ensures that the LEA and
                                                          required components.
                  schools meet parental involvement
                           requirements.
                                                          R: Involvement Policy Template
                                                          Although a regional resource center
                                                          provides policy templates, the state
                                                          should consider developing its own
                                                          template.




Indicator 2.4
    F=15
    R=5




                The SEA ensures that schools and LEAs
                 identified for improvement, corrective
                                                                             MR
                  action, or restructuring have met the
                   requirements of being so identified.
Indicator 2.5
     F=9
    R=10




                                                        R: Collect/Analyze Participation Data (7)
                The SEA ensures that requirements for   The state should collect choice
                     public school choice are met.      participation data on an ongoing basis,
                                                        rather than at the end of the school year.




Indicator 2.6
     F=6
    R=16




                                                        R: Collect/Analyze Participation Data (9)
                The SEA ensures that requirements for
                                                        The state should collect SES
                    the provision of supplementary
                                                        participation data on an ongoing basis,
                 educational services (SES) are met.
                                                        rather than at the end of the school year.
Indicator 2.7
     F=7
    R=18




                The SEA ensures that LEAs and schools
                  develop schoolwide programs that use
                 the flexibility provided to them by law to                     MR
                improve the academic achievement of all
                           students in the school.




Indicator 2.8
     F=2                                                      F: Identify At-Risk Students
    R=1                                                       One targeted assistance school provides
                                                              services to all students rather than
                                                              targeting students at risk of failing.
                  The SEA ensures that LEA targeted
                    assistance programs meet all
                                                              F: Proper Expenses
                            requirements.
                                                              The same school spent money on
                                                              inappropriate expenses such as food,
                                                              caps and gowns, yearbook support and
                                                              photography.



Indicator                    Description
 Number                                                                       Alaska
                                                                          May 15-19, 2006
Indicator 3.1
     F=6
    R=3
                 Within State Allocations, Reallocations,
                and Carryover. The SEA complies with—
                    • The procedures for adjusting ED-
                    determined allocations outlined in
                   §§200.70 – 200.75 of the regulations.
                 • The procedures for reserving funds for
                        school improvement, State
                                                            MR
                  administration, and (where applicable)
                the State Academic Achievement Awards
                                  program.
                     • The reallocation and carryover
                provisions in section 1126(c) and 1127 of
                               Title I statute.




Indicator 3.2
     F=1
    R=3
                  LEA Plan. The SEA ensures that its
                   LEAs comply with the provision for
                 submitting an annual application to the
                                                            MR
                    SEA and revising LEA plans as
                necessary to reflect substantial changes
                    in the direction of their program.
Indicator 3.3
    F=40
    R=6

                                                             F: Rank Order Procedures (4)
                                                             One school received less Title I funding
                                                             than schools with higher poverty levels;
                                                             the state must ensure districts comply
                                                             with rank order procedures.

                                                            F: Parental Involvement (8)
                                                            The state did not ensure districts allocate
                   Within District Allocation Procedures.   95 percent of their parental involvement
                   LEA complies with the requirements in set-aside to schools; one district did not
                 sections 1113, 1116, & 1118 of the Title I allocate any of its reservation to schools,
                  Statute and §§200.77 and 200.78 of the but instead required each school to
                 regulations with regard to: (1) Reserving reserve 1 percent of its allocation.
                   funds for the various set-asides either
                  required or allowed under the statute, & R: Augment Instructions
                    (2) Allocating funds to eligible school The state should clarify in its
                     attendance areas or schools in rank    consolidated application the order of
                 order of poverty based on the number of priority districts should employ when
                   children from low-income families who using their 5 percent "highly qualified"
                    reside in an eligible attendance area.  reservation to assist teachers in targeted
                                                            assistance schools.

                                                             R: Transportation
                                                             With respect to public school choice, the
                                                             state should ensure that Title I only funds
                                                             the difference between what the district's
                                                             normal transportation budget and the
                                                             additional costs related to Title I choice.




Indicator 3.4*     Fiscal Requirements: Maintenance of
     F=0            Effort. The SEA complies with the
     R=0         maintenance of effort (MOE) provisions                          MR
                 of Title I. Sections1120A (a) and 9021 of
                                   the ESEA.
Indicator 3.4*
     F=5
     R=2


                 Fiscal Requirements: Comparability. The
                 SEA ensures that the LEA complies with
                                                                                 MR
                  the comparability provisions of Title I.
                      Section 1120A(c) of the ESEA
Indicator 3.4*
     F=5
     R=0

                   Fiscal Requirements: Supplement not
                  Supplant. The SEA ensures that Title I
                   funds are used only to supplement or
                  increase non-Federal sources used for                          MR
                   the education of participating children
                    and do not supplant funds from non-
                             Federal sources.




Indicator 3.5
    F=19
    R=0


                                                            F: Corrective Action Plans (9)
                                                            The state did not ensure that districts
                                                            were provided with guidance for the
                 Audit. The SEA ensures that its LEAs are
                                                            preparation of corrective action plans.
                  audited annually in accordance with the
                  Single Audit Act, and that all corrective
                                                            F: Timely Corrective Action (8)
                 actions required through this process are
                                                            The state did not ensure that a district
                             fully implemented.
                                                            prepared a corrective action plan to
                                                            address the auditor's internal control
                                                            letter in the A-133 single audit reports.
Indicator 3.6
    F=33
    R=2




                    Services to Eligible Private School
                       Children. LEA complies with
                requirements in sections 1120 and 9306
                   of the Title I Statute, Section 443 of
                 GEPA, and § 200.62 – 200.67, 200.77
                and 200.78 of the regulations with regard      MR
                   to services to eligible private school
                children, their teachers and their families.
                   (See also, indicator 3.3, for findings
                 relating to district set-asides for private
                              school services.)




Indicator 3.7
     F=8
    R=0

                 Complaint Procedures. The SEA has a
                  system for ensuring fair and prompt          MR
                       resolution of complaints.




Indicator 3.8
    F=10
    R=1          Committee of Practitioners (COP). The
                    SEA establishes a Committee of
                  Practitioners (COP) and involves the         MR
                    committee in decision making as
                                 required.
Indicator 3.9
    F=73
    R=3




                                                            F: Locating Inventory Items (9)
                                                            One district did not accurately record
                                                            equipment and could not locate items
                                                            selected for testing.
                Equipment and Real Property. The SEA
                                                            F: Log-Out Procedures (5)
                and component LEAs establish controls
                                                            One district did not observe a procedure
                    over the procurement, recording,
                                                            to account for or document equipment
                  custody, use and disposition of Title I
                                                            used offsite.
                    equipment in accordance with the
                     provisions of State policies and
                                                            F: Physical Inventory (9)
                procedures, the No Child Left Behind Act
                                                            The state did not ensure that districts
                  (NCLB), the Improper Payments Act,
                                                            maintained a system to conduct accurate
                  standards of internal control, and any
                                                            physical inventories of equipment
                  other relevant standards, circulars, or
                                                            purchased with Title I funds.
                           legislative mandates.
                                                            R: Random Annual Inventories
                                                            Districts might conduct annual physical
                                                            inventories of Title I equipment at
                                                            selected schools at a random basis.
Indicator 3.10
     F=61
     R=4
                                                                 F: Inadequate Invoices (13)
                                                                 Three separate findings regarding
                                                                 invoices: One district did not review and
                                                                 approve vendor invoices prior to issuing
                                                                 payments; one district did not require
                                                                 contractors to provide details of services
                                                                 and dates on invoices; and in one district
                                                                 vendor invoices did not provide a clear
                                                                 basis to determine the accuracy of
                                                                 charges.
                 Procurement and Disbursement Controls.
                         SEA and LEAs comply with                F: Insufficient Documentation (14)
                  requirements regarding procurement of          Three separate findings regarding
                         goods and services and the              documentation: In one district a purchase
                       disbursement of Title I funds in          order was issued after receipt of services
                     accordance with state policies and          and an invoice had no documentation;
                      procedures, NCLB, the Improper             one transaction had no documentation
                 Payments Information Act, and any other         supporting the allocation of Title I funds;
                 relative standards, circulars, or legislative   and another district approved contracts
                                 mandates.                       with service providers that did not identify
                                                                 required deliverables.

                                                                 F: Purchase Orders (12)
                                                                 Two separate findings regarding
                                                                 purchase orders: One district did not
                                                                 approve purchase orders prior to the
                                                                 order and delivery of goods and services;
                                                                 in addition, in another district, a service
                                                                 was inappropriately charged to the Title I
                                                                 program.



Other Fiscal
Management                                                       F: Timely Drawdown (2)
   Issues                                                        The state did not ensure the timely
     F=7           Special focus on fiscal compliance by         drawdown of Title I funds; this resulted in
    R=0               Office of Chief Financial Officer          excessive carryover of Title I funds and
                                                                 the application of funds to different
                                                                 school years.




   States        Under each state is the date of the visit, and the total number of findings (F) and recommendations (R) from all three monito
 Indicators      Under each indicator is the total number of findings (F) and recommendations (R) from all available state data fo
 Frequency       If a specific finding or recommendation for an indicator is found in more than one state, the total number of occu
   Colors        Findings are listed in red and recommendations in black
                 MR=Met Requirements
  Abbrev-
                 F=Finding
  iations
                 R=Recommendation
Notes
        * Indicator 3.4 includes three different categories of findings, separated into three rows for the purpose of this ch
s 2005 and 2006


                    Arkansas                     Delaware
                March 27-31, 2006               Oct. 3-7, 2005
                      F=34                           F=24
                      R=13                           R=2




      F: Inadequate Monitoring: N&D (9),
      McKinney (8)
      State had no protocol for reviewing the        MR
      state agency N&D program, and had only
      two questions relating to McKinney




                        MR                           MR
F: LEP Student Standards
The state must set geometry academic
achievement standards for the LEP
alternate (portfolio) assessment.
                                         MR
F: Science Achievement Standards (3)
Arkansas is developing but has not
completed academic achievement
descriptors in science for the 10-12
grade span.




F: Parental Notification (2)
Arkansas does not have a process to
inform parents that their child's
achievement will be based on alternate
achievement standards.

F: Exit Criteria for LEP Students
Arkansas must develop statewide exit     MR
criteria for LEP students.

R: LEP Student Testing (2)
Arkansas has an alternate assessment
for LEP students, and must show it is
aligned with academic content and
achievement standards.




                  MR                     MR
                   MR                                            MR




F: Data Elements Missing, State (10)        F: Data Elements Missing, State (10)
The state report does not include the       The state report does not include the
percentage of classes not taught by a       percentage of classes not taught by a
highly qualified teacher disaggregated by   highly qualified teacher disaggregated by
high and low poverty schools.               high and low poverty schools.




                                            F: Data Elements Missing, Local (12)
F: Data Elements Missing, Local (12)
                                            The state has not ensured that district
District report cards do not include the
                                            report cards include the percentage of
percentage of classes not taught by a
                                            classes not taught by a highly qualified
highly qualified teacher disaggregated by
                                            teacher disaggregated by high and low
high and low poverty schools.
                                            poverty schools.




                   MR                                            MR




                   MR                                            MR




               Arkansas                                      Delaware
           March 27-31, 2006                               Oct. 3-7, 2005
                   MR                        MR




F: Receive District Approval, Ensure Title
I Focus
The state is enhancing its statewide
system of improvement by paying a
vendor to develop a comprehensive
school improvement model for schools in
corrective action or restructuring.
However, it has not obtained permission
from school districts to use the 4 percent
set-aside for this purpose; normally, 95
                                             MR
percent of these funds must be allocated
to districts. Also, the state has not
verified that funding will be used only in
Title I schools.

R: Individualize Support
ED expresses concern that using a single
"one-fits-all" model will not properly
address the specific problems that led a
school to be identified for improvement.
(see also, 2.5)

R: Combine Involvement Plans
Schools should develop one combined
parental involvement policy embracing
both state and federal requirements.
                                              F: Parental Involvement Policy (12),
R: Annual Parent Meeting, Assistance on       Separate School Plans (4)
Evaluation                                    District parental involvement plans have
Schools should conduct an annual              none of the required elements. Title I
meeting to ensure parents have                schools have not developed their own
information on the meaning of AYP, SES        plans but simply use the district's plan as a
options, and how they can become              school plan.
involved in school improvement plans.
The state should provide districts and
schools technical assistance on the
required annual evaluation of the
effectiveness of parental involvement
activities.




R: Plan Integration
The state should continue to streamline
efforts to integrate federal schoolwide
and improvement plans with the own
state improvement plan.

R: Peer Review (2)
The state should give districts information
about the peer review process, including
                                                                (see 3.3)
samples of rubrics, tools to provide
feedback, and samples of letters to
inform schools of approval status.

R: Individualize Plans
The state should review improvement
plans to ensure they address individual
needs of a school, rather than simply hit
items on a checklist.
F: Notification Missing Elements (5)
Choice letters did not consistently include
all required components; the state should
provide sample letters that give
information on identification of and
information on schools to which a student
may transfer, transportation, and how
parents can be involved.
                                          F: Notification Missing Elements (5)
                                          District choice letters did not contain an
(above item was originally reported under
                                          explanation of how parents can be involved
2.3)
                                          in addressing the academic issues that led
                                          to the school being identified for
R: Consistent Choice Definitions
                                          improvement.
The state should provide guidance to
districts to ensure state and federal
choice definitions are in line.

R: Collect/Analyze Participation Data (7)
The state should analyze choice
participation rates and work to increase
rates when low.



R: Consistent SES Definitions
The state should provide guidance to
districts to ensure state and federal SES
definitions are in line.

R: Collect/Analyze Participation Data (9)     F: Notification Missing Elements (4)
The state should analyze SES                  District SES letters did not contain an
participation rates and work to increase      explanation of how parents can be involved
rates when low.                               in addressing the academic issues that
                                              lead to the school being identified for
R: Learning Plan                              improvement.
Districts should create a learning plan
template as part of their agreement with
SES providers, to make a plan that will
be tailored to student needs but
consistent across providers.
R: Offer Guidance to Combine Plans (8),
Annual Update (4)
The state should give technical
assistance to districts to guide the
development of a single school plan for a
school in in improvement that is also
operating a schoolwide program, and
                                            F: Plans Missing Elements (7)
should provide support to schools that
                                            Although the state has a planning process
have operated schoolwide programs for a
                                            that integrates improvement plans with
significant period of time to ensure they
                                            schoolwide plans, the plans do not contain
update their plans annually.
                                            all 10 required schoolwide plan elements.
R: Parental Involvement (3)
Parents were not clear about the purpose
of schoolwide programs or how they
could be involved in the planning,
implementation, or evaluation of these
programs.




                   MR                       (see 3.4 -- Supplement Not Supplant)




               Arkansas                                     Delaware
           March 27-31, 2006                              Oct. 3-7, 2005
R: Carryover Waivers
The state should consider its policy of not
allowing waivers to the 15 percent
                                            F: School Improvement Reservation
limitation for Title I carryover; this may
                                            The required 4 percent was not reserved
inhibit districts that have reasonable
                                            for school improvement.
cause for going over the limit.

(see also, 3.3)




                   MR                                         MR
                                               F: Professional Development (5)
(following five items were originally          School improvement plans must set aside
reported under 3.1)                            10 percent of Title I funds for pro- fessional
F: Parental Involvement (8),                   development and specify how they will be
Professional Development (5), SES              used to remove the school from school
District set-asides for SES, family literacy   improvement status.
and parenting, and pro- fessional              (item above was first reported under 2.4)
development were incorrect.
                                               F: School Allocations-125 Percent Rule
F: Calculating Poverty Percentages (2)         The state should not require districts where
In calculating schools' poverty per-           all Title I schools have poverty 35 percent
centage, districts used inconsistent data.     or over to allocate funds using the "125
                                               percent" rule.
F: Per-Pupil Allocations (2)
Districts were improperly using multiple       F: Parental Involvement (8)
per-pupil amounts in determining school        Districts must allocate at least 95 per- cent
allocations.                                   of parental involvement reservations to
                                               schools for use according to the school's
F: Skipped Schools                             own need assessment. Funds cannot be
The state did not ensure that skipped          held for district-wide activities.
schools met the requirements to be
skipped.                                       F: Equitable Services -- Instructional Set-
                                               Aside (2)
F: Desegregation Waiver                        Districts must calculate an equitable
The state has not ensured that the             proportion of district-wide reservations for
desegregation waiver for certain school        children in non-public schools.
districts is current.
                                               R: Fund Allocation Formula in
(originally reported under 3.6):               Consolidated Application (2)
F: Equitable Services -- Families (5),         The consolidated application template
Teachers (6), Students (2)                     could include (a) the different formulas
Districts did not correctly reserve the        used to allocate funds to schools and the
equitable portion for private school           rationale for using one or the other; and (b)
children, teachers, and families.              the formula to be used for calculating the
                                               equitable proportion of funds for children in
                                               non-public schools.


                    MR                                              MR




                                               F: Performing Calculations (3)
F: Inadequate Guidance and
                                               The state did not require districts to
Documentation
                                               develop procedures for determining
Guidance to districts must include
                                               comparability. It required only written
information on how to document
                                               assurances, backed with no calculations,
instructional staff FTE and procedures to
                                               that districts had a uniform salary schedule
follow when comparability calculations
                                               and a policy of equivalence in distribution
determine that schools are not
                                               of curriculum materials and supplies.
comparable. Districts must perform their
                                               Districts must develop procedures and
calculations at the start of the year and
                                               maintain records based on computations
document them.
                                               for determining comparability.
                                              F: Targeted Assistance Programs, Eligible
                                              Children
                                              A Title I teacher in a targeted assistance
                                              school was the sole mathematics teacher
                                              for all students in grades 4-6, thereby
                    MR                        supplanting state and local resources.
                                              Moreover, Title I funds must be used to
                                              provide services only to children eligible to
                                              participate.

                                              (originally reported under 2.8)



F: Corrective Action Plans (9)
The state should provide guidance to
districts for the preparation of corrective
action plans and the timely completion of
corrective action.
                                              F: Corrective Action Plans (9)
F: Timely Corrective Action (8)
                                              The state did not provide guidance to the
Three findings relating to timely
                                              districts, in the form of documented
corrective action: The state did not
                                              procedures, for the preparation of
complete timely corrective actions for
                                              corrective action plans and the timely
audit findings; the 2004 state audit noted
                                              completion of corrective actions to address
that a district's bank account had not
                                              audit findings.
been properly reconciled for one month
and there was still no documentation of
correction; and the 2003 audit noted that
a district had significant undocumented
adjustments and there was still no
documentation of correction.
F: General Aid (3)
Title I funds paid for private school
teachers to attend diocesan education
conferences that were required of all
private school teachers in the Diocese of
Little Rock.
                                            MR
F: Program Responsibility (10)
The state has not ensured that private
school providers are employees of the
district or of third-party contractors.

(see also 3.3)




F: Establish Process and Issue
Guidance (6)
The state should finish its formal
                                            MR
complaint procedures, and ensure that
districts implement their own procedures
and provide guidance to schools.




F: Establish COP (2)
                                            MR
The state did not have a COP in place.
F: Physical Inventory (9)
Districts were not conducting periodic
physical inventories.

F: Labels (12)
Districts used self-stick removable labels
or permanent marker to label inventory
                                             F: Locating Inventory Items (9)
items.
                                             ED was unable to locate a substantial
                                             number of equipment items selected for
F: Equipment Transfers (3)
                                             inspection from inventory lists.
Districts did not have adequate
documentation to account for Title I
                                             F: Physical Inventory (9)
equipment transfers.
                                             Effective policies and procedures for the
                                             physical inventory of equipment purchased
F: Locating Inventory Items (9)
                                             with Title I funds do not exist or are not
The district was unable to locate
                                             being applied at districts.
equipment items selected for inspection.
                                             F: Capitalization Threshold (2)
F: Equipment Location (3)
                                             A district used an excessive threshold for
Items were found at locations different
                                             capitalizing Title I equipment.
from those listed on Title I equipment
lists.

F: Log-Out Procedures (5)
The state did not have a checkout policy
for laptop computers, and did not
document equipment removals.
                                                            F: Inadequate Invoices (13)
                                                            Four separate findings regarding invoices:
                                                            Two districts approved contractor invoices
                                                            with no description of services provided,
                                                            location of service, and number of students
                                                            served. At one district, vendor invoices
                                                            presented to support disbursements had
                                                            no notations indicating date of receipt or
               F: Insufficient Documentation (14)           approval signature. One district paid an
               Two separate findings regarding              invoice that included charges for
               documentation: transactions did not          instructional services provided to students
               include signatures or descriptions of        from both that district and a neighboring
               services or goods; and others were           district; the state should have required the
               missing check reimbursement requests         service provider to bill the neighboring
               and check copies.                            district separately. One district paid
                                                            invoices with altered dates.
               F: Segregation of Duties (4)
               A district must establish adequate           F: Purchase Orders (12)
               segregation of duties in the procurement     One district paid an unapproved invoice
               process.                                     without a purchase order, even though the
                                                            amount was above the state limit requiring
                                                            a purchase order.

                                                            F: Missing Contracts
                                                            Two districts were unable to provide copies
                                                            of contracts with a provider of instructional
                                                            services to support disbursements selected
                                                            for test.




                                                               F: Obligation Policy
                                                               Failure to follow the state policy of
               F: Personnel Improperly Charged (3)             obligating funds on a "first-in, first-out"
               One school district erroneously included basis resulted in federal funds expiring.
               a non-Title I staffer on a list of Title I-paid The state must ensure that it makes a
               staff.                                          timely distribution of undistributed school
                                                               improvement funds carried over to the next
                                                               fiscal year.




  (F) and recommendations (R) from all three monitoring areas.
mmendations (R) from all available state data for that indicator.
 more than one state, the total number of occurrences will appear in parentheses.
rated into three rows for the purpose of this chart.
          District of Columbia                             Georgia
         Feb. 27-March 10, 2006                       March 20-24, 2006
                  F=37                                      F=24
                  R=3                                       R=6




                                         F: Inadequate Monitoring: Part A (5),
                                         Even Start (3), N&D (9), and McKinney (8)
                                         The state's procedures for monitoring
F: Timely Corrective Action              districts were insufficient; state monitoring
The state did not ensure that charter    reports indicated that districts were in
school districts develop and implement   compliance in all areas, whereas ED
corrective actions for issues of         identified a number of areas of
noncompliance identified through its     noncompliance. The state could use onsite
monitoring process.                      monitoring procedures, the district
                                         application review and approval process, or
                                         some other mechanism, for monitoring its
                                         districts.




F: Science Content Standards (2)
The state does not yet have approved
                                                              MR
content standards or performance level
descriptors for its science standards.
F: Reading and Math Achievement
Standards (3)
The state does not yet have approved
                                                               MR
achievement standards in
reading/language arts and mathematics,
although it plans to do so by fall 2006.




                                        F: Implement Assessment System for
                                        Students with Disabilities (2)
F: Implement General Assessment System The state's revised alternate assessment
The state must implement the            system will not be available for use in
comprehensive assessment system in      making AYP determinations during the
language arts and mathematics in spring 2005-06 school year.
2006; establish achievement standards
during the summer; and use those as the R: Test Accommodation Guidance
basis for AYP determinations.           The state provides standardized
                                        accommodations, but should ensure that
                                        districts actually implement them.




                                           R: Comprehensive Quality Assurance Plan
                                           The state has basic auditing functions, but
                                           would benefit from developing a plan to
                    MR                     monitor support, standardizing data quality
                                           procedures, and targeting SWD, LEP
                                           students, and other "high-risk" subgroups
                                           where the chance of data errors is high.
                     MR                                             MR




F: Data Elements Missing, State (10)
The state does not publish a state report        F: Data Elements Missing, State (10)
card that includes all required components.      The state report card was missing
Data missing included disaggregated              information on the percentage of teachers
results, comparisons to objectives, and          with emergency or provisional credentials
information on graduation rate, AYP and          and on the percentage of classes not
classes not taught by highly qualified           taught by highly qualified teachers.
teachers.




F: Data Elements Missing, Local (12)             F: Data Elements Missing, Local (12)
None of the district report cards included all   District report cards were missing
required components. The state may either        information on the percentage of teachers
prepare district report cards, or may            with emergency or provisional credentials
implement procedures to review locally           and on the percentage of classes not
developed report cards.                          taught by highly qualified teachers.




                     MR                                             MR




                     MR                                             MR




          District of Columbia                                    Georgia
          Feb. 27-March 10, 2006                             March 20-24, 2006
F: Tracking Compliance
The state's system for identifying
paraprofessionals and their progress
toward highly qualified status is
inadequate. It must develop a system to
ensure that paraprofessionals meet highly
qualified requirements.
                                               MR
F: High School Diploma
The state has not ensured that all
paraprofessionals working in a program
supported with Title I funds have earned a
secondary school diploma or its equivalent.
Three paraprofessionals had not
completed high school.




F: Establish Support System (3)
The state has no organized system of
delivering technical assistance to districts
and schools in improvement. Funding is         MR
used largely to assist teachers and
paraprofessionals in meeting qualification
requirements.
F: Parental Involvement Policy (12)
The state did not ensure that districts and
schools have school-parent compacts.
                                             F: Parental Involvement Policy (12)
F: Annual Evaluation                         The state has not ensured that districts and
The state must ensure that districts and     schools have a written parental
charter schools conduct an annual            involvement policy in place.
evaluation of parental involvement policies.

(see also 3.3)




                     MR                                        (see 3.3)
                                              F: Ineligible School Offered as Choice
                                              The state allowed a charter/magnet school
                                              in improvement to be offered as an option
R: Collect/Analyze Participation Data (7)
                                              for school choice.
The state maintains choice participation
data only for public Title I schools; it should
                                                R: Collect/Analyze Participation Data (7)
maintain participation data for charter
                                                The state should collect statewide choice
schools as well.
                                                participation data on a more frequent basis
                                                to determine trends and make adjustments
                                                if necessary.




R: Collect/Analyze Participation Data (9)     R: Collect/Analyze Participation Data (9)
The state maintains SES participation data    The state should collect statewide SES
only for public Title I schools; it should    participation data on a more frequent basis
maintain participation data for charter       to determine trends and make adjustments
schools as well.                              if necessary.
F: Plans Missing Elements (7)
The state has not ensured that school
improvement plans for schools also
operating schoolwide programs contained
all required elements for schoolwide               MR
programs, specifically early childhood
transition to local elementary programs,
and strategies to attract highly qualified
staff.




                    MR                             MR




          District of Columbia                   Georgia
          Feb. 27-March 10, 2006             March 20-24, 2006
                                                 R: Eligibility Criteria
                                                 ED suggests adjusting an operations
                                                 manual to clarify the district eligibility
                                                 criteria for basic and concentration grants.

                      MR                         R: Carryover Clarification
                                                 The state handbook states that a district
                                                 may allocate carryover funds back to
                                                 schools on an equitable basis, but should
                                                 mention that districts may need to calculate
                                                 private school participants' portion.




F: Timely Funding to Districts
The state has not ensured a timely plan
approval and release of Title I funds. The
                                                                      MR
state must provide funding to its districts in
a timely manner after a district plan is
received, reviewed and approved.
                                                 F: Professional Development (5)
                                                 Title I schools in improvement must set
                                                 aside 10 percent of Title I funds for
                                                 professional development.
                                                 (above item was originally reported under
                                                 2.4)

                                                 F: Rank Order Procedures (4)
                                                 Districts have not complied with the
                                                 provision of Title I allowing districts to "skip"
                                                 an eligible school that has a higher
F: Parental Involvement (8)
                                                 percentage of children from low-income
The state has not ensured that its districts
                                                 families if certain conditions are met.
reserve at least 1 percent of their allocation
for parental involvement activities and
                                                 F: Equitable Services -- Families (5),
allocate 95 percent of that to schools. One
                                                 Teachers (6)
district has used the reservation to fund
                                                 Prior to allocating funds to districts, the
four parent offices to serve as liaisons
                                                 state must ensure that the districts properly
between parents and schools, and parents
                                                 calculate the equitable services
were not involved in this decision.
                                                 reservations for private school families and
                                                 teachers as part of the budget
(originally reported under 2.8)
                                                 determination process.

                                                 F: Parental Involvement (8)
                                                 The state has not ensured that its districts
                                                 reserve at least one percent of their
                                                 allocation for parental involvement
                                                 activities and allocate 95 percent of that to
                                                 schools. The state's handbook indicates
                                                 that 95 percent must be spent at the school
                                                 level, not that the funds must be allocated
                                                 to schools.




                     MR                                                MR




                     MR                                                MR
                                             F: Parental Involvement Centers
                                             Parental involvement centers funded with
                    MR                       Title I funds, although focused on parents
                                             from Title I schools, provide services to any
                                             parents from the district who request them.




                                             F: Verify Reimbursement Requests
F: Timely Corrective Action (8)
                                             The state relies on A-133 audits to verify
The state did not complete timely corrective
                                             local agency drawdowns, but does not
actions for recurring audit findings.
                                             regularly review audit findings.
F: General Aid (3)
                                                 F: Program Responsibility (10)
Title I funds should be directed towards
                                                 Districts must maintain control of Title I
Title I students in private schools, not be
                                                 programs in private schools. Moreover,
used to meet the general needs of private
                                                 simply providing the private school with
school students.
                                                 instructional materials and supplies does
                                                 not meet equitable service requirements.
F: Program Responsibility (10)
Four separate findings relating to program
                                                 F: Assess Program Effectiveness (5)
responsibility: Districts must take full
                                                 The state should determine what
responsibility for Title I private school
                                                 constitutes annual progress, how the Title I
implementation. Specifically, districts must
                                                 program will be assessed, and how annual
provide oversight over third party providers,
                                                 progress will be measured.
contractors, and reimbursement for
invoices from third party providers.
                                                 F: Participant Eligibility (5)
                                                 Districts must use multiple educational
F: Consultation (5)
                                                 criteria to identify private school students;
The state does not collect "affirmation of
                                                 private school officials currently rely on a
consultation" forms annually.
                                                 single test or a similar measure.
F: Participant Eligibility (5)
                                             F: Consultation (5)
Districts must establish educationally
                                             Districts simply invite private school
related objective criteria to identify private
                                             families and teachers of private school
school students for Title I services.
                                             students to parental involvement and
                                             professional development activities that
F: Assess Program Effectiveness (5)
                                             have been designed for public school
The state should determine what
                                             families and teachers, rather than activities
constitutes annual progress, how the Title I
                                             developed in consultation with private
program will be assessed, and how annual
                                             school representatives.
progress will be measured.
                                                 R: Guidance on Use of Limited Funds
R: Ineligible School
                                                 States should provide guidance to districts
Equitable services are being provided for
                                                 with low equitable services reservations on
students at what might be more properly
                                                 how to effectively provide services with
identified as an institution for neglected
                                                 small sums of money.
students rather than a private school.



F: Implement Process (2)
The state has not ensured that districts
have copies of its complaint procedures,                               MR
and that districts are aware of complaint
policies.




F: Membership (7)
The state did not ensure that the COP was
                                                                       MR
in compliance with the membership
requirements.
F: Date of Purchase (2)
The state did not provide an equipment list
that included date of purchase.

F: Locating Inventory Items (9)
Two separate findings regarding locating
inventory items: The state could not locate
items selected for inspection, including an
application of software.
                                               F: Equipment Records (14)
F: Labels (12)
                                               Neither district visited was able to provide
Three separate findings relating to labels:
                                               an accurate current list of equipment.
At the state level, two equipment items did
not contain an Asset ID tag; labels were
                                               F: Physical Inventory (9)
improperly placed on hardware rather than
                                               Two findings relating to physical
software; and Title I equipment at private
                                               inventories: Districts should conduct
schools was not labeled.
                                               reviews to ensure adequate internal
                                               controls and should conduct periodic
F: Equipment Records (14)
                                               physical inventories; and districts must
Four separate findings relating to
                                               reconcile physical inventories of equipment
equipment records: listings were
                                               at schools to district-level records.
duplicated; omitted; outdated; or
incomplete.

F: Documentation
The state did not have documentation for a
software purchase.

F: Equipment Policies and Procedures
Districts did not have policies and
procedures for the use of Title I equipment.
          F: Purchase Cards
          The state must provide guidance to
          districts and Purchase Card holders to
          provide guidance about prohibited
          transactions. Districts must provide
          periodic mandatory training and monitor
          compliance.

          F: Federal Travel Regulations
          Districts must conduct reviews of travelers'
          expenditures; employees should to utilize
     MR   rates within federal travel rate limits, and
          districts should conduct periodic reviews of
          travel expense reports.

          F: Inadequate Invoices (13)
          At one district, three transactions did not
          include a date on the vendor's invoice.

          F: Purchase Orders (12)
          Districts were approving purchase orders
          after goods and services were ordered and
          received.




     MR                        MR




s.
                                                                                         Monitorin

                 Hawaii                                      Kansas
             Apr. 17-21, 2006                             Jan. 9-13, 2006
                   F=20                                        F=22
                   R=6                                          R=4




F: Inadequate Monitoring: N&D (9),
                                             F: Inadequate Monitoring: McKinney (8)
McKinney (8)
                                             The state had not developed monitoring
The state had not monitored its state N&D
                                             indicators, a monitoring protocol, or a
program. The McKinney state liaison and
                                             schedule to conduct compliance monitoring
state coordinator are the same person; the
                                             for the McKinney program for funded or
state must provide for independent
                                             non-funded districts.
monitoring of McKinney program.




F: Science Content Standards (2)
The state must finalize science content                         MR
standards for the alternate assessment.
F: Reading and Math Achievement
Standards (3), Science Achievement
Standards (3)
                                                                   MR
Academic content standards must be
completed and aligned to academic
achievement standards.




F: Parental Notification (2), Participation
by LEP and Disabled Students
                                               F: LEP Student Testing
The state did not validate reports that all
                                               LEP students were allowed to take a
children with limited English proficiency or
                                               listening assessment, even though it is not
disabilities participated in the tests. The
                                               a valid reading assessment. The listening
state did not inform parents that their
                                               assessment was also administered as an
child's achievement will be based on
                                               out-of-grade level assessment, which is
alternate achievement standards. The state
                                               prohibited.
must promote the adoption of state-
approved accommodations.




F: Monitor Assessments (2), Ensure Data
Quality
The state does not monitor administration
                                                                   MR
of its assessment and does not ensure that
final assessment data released to the
public contain all data corrections.
                                           F: Communicate Guidelines
                                           The state must inform districts that
                                           students repeating a grade must take
                                           assessments, and their scores must count
                    MR
                                           in AYP calculations. The state should also
                                           tell districts that if truant students are
                                           present during the testing window they
                                           must also be tested.




F: Data Elements Missing, State (10)
The state report was missing elements,
and school-level reports do not describe
                                                                MR
content-based competencies or report
measurement error to parents. This is a
repeat finding.


                                           R: Distribute Hard Copies
                                           District report cards are currently only
                                           available on the state website; districts
                                           should make hard copies available in a
                                           language that parents can understand.
                    MR
                                           R: Translate Reports
                                           Two districts did not have reports available
                                           in Spanish, although both have a
                                           significant number of Spanish-speaking
                                           parents.




                    MR                                          MR




                    MR                                          MR



                                                                                          Monitoring A

                 Hawaii                                      Kansas
            Apr. 17-21, 2006                              Jan. 9-13, 2006
     (originally reported under 2.3)

     F: "Non-Highly Qualified" Notification
MR   One district has not notified parents when
     students have been taught for four weeks
     or more by a teacher who is not highly
     qualified.




MR                        MR
(see 2.4 and 2.5)

R: Technical Assistance
The state should provide technical
assistance to schools in preparing parental                      (see 2.1 and 2.4)
notification letters and in exploring ways to
expand outreach to increase parental
involvement.




                                                   F: Incomplete Notification (4)
                                                   District notification must include information
                                                   on how parents can become involved and
                                                   what the district is doing to help the school
F: Incomplete Notification (4)
                                                   improve.
District parental notification letters failed to
include a variety of information relating to
                                                   (the above item was originally reported
identification.
                                                   under 2.3)
(the above item was originally reported
                                                   F: Plans Missing Components (5)
under 2.3)
                                                   Although the state's current school
                                                   improvement plan template is complete,
                                                   the previous ones were missing required
                                                   components.
F: Notification Missing Elements (5)
School choice notifications were missing
elements.

(the above item was originally reported
under 2.3)                                                       MR

R: Collect/Analyze Participation Data (7)
The state should analyze choice
participation rates and establish methods
to increase rates where applicable.




R: Collect/Analyze Participation Data (9)
The state should analyze SES participation
rates and establish methods to increase
                                              R: Determine Provider Effectiveness
rates where applicable.
                                              The state has used surveys to determine
                                              parental and school satisfaction with SES
R: Increase Providers (2)
                                              services, and should continue to explore
The state approved ten SES providers, but
                                              possible avenues for gathering information
only four provided services; it should try to
                                              on provider effectiveness.
increase the number of providers by
requesting proposals more than once a
year.
R: Offer Guidance to Combine Plans (8),
Annual Update (4)
If a schoolwide program is also a school in
improvement, it is recommended that it
create a single plan. Where are school has
operated as a schoolwide for a
considerable period of time, the state
should ensure the schoolwide plan is
                                                   MR
annually updated.

R: Parental Involvement (3)
Districts should help parents understand
how to be involved in schoolwide
programs; involvement activities should
especially target parents of the lowest-
achieving students.




                    MR                             MR




                                                                Monitoring Area 3

                  Hawaii                         Kansas
             Apr. 17-21, 2006                 Jan. 9-13, 2006
MR   MR




MR   MR
F: Equitable Services -- Teachers (6),
Students (2)
Private school teachers and students did
not receive equitable services from the
                                                                    MR
state based on the total amount of funds
available for Title I.

(originally reported under 3.6)




                     MR                                             MR




                                               F: Schools Not Comparable
                                               One district did not complete required
                                               comparability calculations, and not all its
F: Performing Calculations (3)                 Title I schools were comparable.
The state had not received charter school
data, and therefore made Title I allocations   R: Paraprofessionals (2)
based on incomplete data.                      The state and districts should consider
                                               whether a paraprofessional is equivalent to
                                               a teacher or instructional staff member in
                                               comparability determinations.
     F: Personnel Funding (2)
     Title I funds were used to supplant other
     funds; personnel paid with Title I funds
     worked as central administrative staff, in
     non-Title I schools, and at an instructional
     center providing support to both Title I and
MR   non-Title I schools.

     F: Review Supplement-Not-Supplant
     Requirement
     The state did not ensure that supplement
     not supplant requirements were regularly
     reviewed by certified public accountants.




MR                        MR
                 (see 3.3)                   MR




                   MR                        MR




F: Membership (7)
The state's current COP does not include a
                                             MR
representative of the private school
community as required.
                                             F: Safeguard All Items
                                             Although not required by federal law, the
                                             state requires its agencies to "safeguard"
                                             all capital items with a useful life of more
                                             than one year -- even those under the
                                             capitalization rate of $5,000. Since this
                                             requirement exists, the state must have
F: Equipment Records (14)
                                             documented procedures to implement it.
One item was recorded twice on an
                                             ED cited two different deficiencies under
equipment inventory record.
                                             this heading.
F: Labels (12)
                                           F: Equipment Records (14)
One equipment item did not have a label or
                                           Two findings relating to equipment records:
property tag affixed.
                                           one item had no documentation to show
                                           that it had been checked out; and another
F: Log-Out Procedures (5)
                                           item had an incorrect inventory number.
The state and schools did not maintain a
system to account for equipment used off-
                                           F: Equipment Location (3)
site; the state should develop a
                                           The state listing of Title I equipment did not
documented check out process.
                                           identify the location of each item.
F: Equipment Transfers (3)
                                             F: Date of Purchase (2)
The state has no requirement to document
                                             The state's listing of Title I equipment did
the transfer of equipment purchased with
                                             not include date of purchase, just the date
Title I funds for the exclusive use of
                                             it was added to the inventory.
another program.
                                             F: Controls (3)
                                             Thirty-four items purchased with Title I
                                             funds were not on the district inventory list.
                                             In addition, one district was not able to
                                             locate an expensive item of Title I
                                             equipment.
F: Segregation of Duties (4)
The state did not ensure that schools      F: Insufficient Documentation (14)
maintained an adequate segregation of      Two separate findings relating to
duties in the procurement and cash         documentation: Claimants did not sign
disbursement process.                      worksheets accompanying two travel
                                           vouchers; and one district did not have
F: Sample Signatures                       documentation for journal entries or journal
The state did not ensure that the payments entry adjustments.
processing office maintained a list of
sample signatures of individuals at each   F: Purchase Orders (12)
school. The state processes payments       Three separate findings relating to
without adequate controls to ensure        purchase orders: purchase order
individuals with appropriate authority     adjustments did not have signatures or
approve transactions.                      initials; one district was not consistently
                                           using purchase orders; and cancelled
F: Purchase Orders (12)                    purchase orders were not documented.
The state did not ensure that purchase
orders were consistently created and       F: Printing Requests
approved prior to ordering and receiving   Districts must provide documentation for
the delivery of goods and services.        printing requests.

F: Inadequate Invoices (13)                     F: Inadequate Invoices (13)
Two separate findings relating to               One district did not use a date-received
inadequate invoices: One transaction has a      indication on invoices, and one invoice was
contract with no date of signature, and         not initialed or signed to indicate receipt of
another has no description of services          goods.
provided.




F: Timely Drawdown (2)
The state did not ensure timely drawdown
of Title I funds and the application of funds                        MR
to the school year the funds were intended
to support.
                                  Monitoring Area 1: Accountability
                                                                                       States
                Kentucky                                New Hampshire
             Jan. 23-27, 2006                            March 6-10, 2006
                   F=12                                       F=16
                   R=3                                         R=6




                                            F: Inadequate Monitoring: N&D (9),
                                            McKinney (8)
                                            The state did not have an N&D monitoring
                                            protocol, schedule for monitoring state or
                                            local subgrantees, or evidence of
F: Inadequate Monitoring: Part A (5)        completed monitoring activities. The state
The state's current monitoring plan does    monitors McKinney grantees, but does not
not monitor sub-recipients annually using   monitor non-grantees for compliance with
objective criteria. The state should        McKinney.
especially focus on SES, and should
review parental notification letters.       R: Augment Desk Review (2)
                                            The state should align desk reviews with
                                            other administrative and programmatic
                                            monitoring protocols to create a more
                                            comprehensive and integrated monitoring
                                            process.




                    MR                                          MR
                     MR                                             MR




F: Implement Assessment System for
Students with Disabilities (2)
The state does not plan to conduct state-
standards-based alternate assessments for                           MR
students with severe cognitive disabilities
for grades 3, 5, 6, and 7 until 2006-07. ED
is considering further administrative action.




                                                F: Improvement Appeals
                                                The state provides criteria for districts or
                                                schools to appeal improvement
                     MR                         designations, and sometimes grants
                                                appeals for reasons not aligned with NCLB
                                                requirements. It should discontinue this
                                                practice.
                    MR                                       MR




F: Data Elements Missing, State (10)
State report cards did not include
information on all students tested, and                      MR
were also missing information, such as
teacher qualifications.




                                          F: Data Elements Missing, Local (12),
F: Data Elements Missing, Local (12)
                                          Report Cards Missing
District report cards did not include
                                          District report cards do not include
information on all students tested, and
                                          information about their schools'
were also missing information, such as
                                          improvement designations. Some districts
teacher qualifications.
                                          had not published a report card at all.




                    MR                                       MR




                    MR                                       MR



                            Monitoring Area 2: Instructional Support
                                                                                     States
                Kentucky                              New Hampshire
             Jan. 23-27, 2006                         March 6-10, 2006
F: Right to Request Qualifications (3)
Schools must notify parents of their right to
                                                MR
request to see the qualifications of their
child's teachers.




                     MR                         MR
                                                 F: Annual Parent Meeting
                                                 The state must notify districts that they
                                                 must conduct an annual meeting for
                                                 parents that includes information about the
                                                 Title I program in each school. Districts
                                                 should document this meeting.

                                                 R: Increase Parental Understanding (2)
                                                 Parents are not clear about the meaning of
                                                 AYP. Districts should create involvement
                      MR                         activities that will help them understand the
                                                 system and their role in improvement
                                                 planning, and how to take advantage of
                                                 opportunities available.

                                                 R: Schoolwide Parental Involvement
                                                 Parents are not clear about the purpose of
                                                 a schoolwide program or how they can
                                                 become involved in the planning,
                                                 implementation, and evaluation of such a
                                                 program.




                                                 F: State Notification for Districts in
                                                 Improvement
                                                 The state must issue the notice telling
                                                 parents when a district is identified as in
                                                 need of improvement; districts were
F: Incomplete Notification (4)                   notifying parents about district
Although the state provided guidance,            improvement status on district letterhead.
district parental notification letters did not   The state may ask districts to actually send
give information on what identification          the notifications, but the notice must be on
means, reasons for identification, and how       state letterhead.
parents can become involved.
                                                 R: Peer Review (2)
                                                 The state should provide technical
                                                 assistance to districts about the purpose
                                                 and structure of the peer review of school
                                                 improvement plans.
F: Denying Public School Choice
One district was improperly denying school
                                           (originally reported under 2.6)
choice options to parents.
                                            F: Notification Missing Elements (5)
R: Increase Parental Information
                                            District letters did not consistently include
Although parents were pleased with SES,
                                            all required components.
there were uninformed regarding parental
involvement activities and school choice.




                                            F: SES Provider Contracts
                                            The state has not ensured that district
                                            contracts with SES providers contain all the
                                            required information.

                                            (see also, 2.5)
                    MR
                                            R: Collect/Analyze Participation Data (9)
                                            The state should analyze district public
                                            school choice and SES participation rates,
                                            and, when rates are low, review district
                                            implementation practices.
                    R: Offer Guidance to Combine Plans (8)
                    The state should include specific
                    information for districts to guide the
      MR
                    development of a single school plan for a
                    school in in improvement that is also
                    operating a schoolwide program.




      MR                                MR




      Monitoring Area 3: SEA Fiduciary Responsibilities
                                                                States
  Kentucky                      New Hampshire
Jan. 23-27, 2006                 March 6-10, 2006
MR   MR




MR   MR
MR   MR




MR   MR




MR   MR
MR                       MR




     F: Corrective Action Plans (9)
     Neither the state nor the reviewed districts
     established or implemented procedures for
MR
     the preparations of corrective action plans
     and the timely completion of corrective
     actions to address audit findings.
                   MR                                          MR




                                           F: Establish Process and Issue Guidance
                                           (6)
F: Establish Process and Issue Guidance
                                           The state had a formal complaint policy
(6)
                                           and procedures in place at the time of the
Districts did not have formalized
                                           onsite review, but lacked adequate follow-
procedures for recording and documenting
                                           up and tracking procedures. District
complaints, such as established systems
                                           procedures were spotty and the state was
for logging and tracking.
                                           unable to document guidance supplied to
                                           districts on the issue.


R: Charter and Organizing Principles       F: Membership (7)
The Federal Programs Director was unable   The COP was not in compliance with
to provide a charter, memoranda of         membership requirements; the state must
operations, or formalized operating        review and document the process for
principles; the state must formalize the   selecting members, the terms of
process of selecting members.              membership and the frequency of meetings.
                                                F: Equipment Records (14)
                                                Equipment records were missing such
                                                information as date of purchase, actual
F: Locating Inventory Items (9)
                                                cost, ID numbers, and equipment condition
ED was unable to locate some of the
                                                or location.
equipment items selected for inspection.
                                                F: Log-Out Procedures (5)
F: Labels (12)
                                                At the state, the only equipment log-out
The state should label inventory with Asset
                                                procedure was a calendar identifying dates
ID tags, and Title I labeling, if applicable,
                                                when equipment was needed; no controls
when the item is added to the inventory
                                                were in place to establish accountability for
listing.
                                                those who checked out equipment. The
                                                state must develop a plan for equipment
(the following item was originally reported
                                                log-out procedures.
under 3.10)
F: Create Master Inventory
                                                F: Labels (12)
Districts are currently using several
                                                Three items of equipment located for
different inventory listings, and should
                                                inspection did not have property tags.
create one master inventory listing.
Inventory lists were also missing
                                                F: Timely Purchases (3)
information such as asset ID numbers,
                                                At one district, there were 63 items on the
cost, and location.
                                                equipment list that were obsolete or
                                                damaged; the state acquired equipment
                                                before it was actually needed.
F: Purchase Orders (12)
Purchase orders were missing information,
were issued at the end of the purchasing
                                               F: Unallowable Expenditure (3)
process, or differed from the invoice
                                               An invoice for a non-Title I program was
amount.
                                               paid using Title I funds.
R: Purchase Orders
                                               F: Approval Process
The state and its districts require purchase
                                               At one district, a person who was not the
orders for all disbursements, however
                                               approver was using the signature stamp of
small, but ED recommends that the state
                                               the approver and approved all purchase
establish a "floor" around $250 to make it
                                               orders and invoices. The approvals were
unnecessary to use a purchase order for
                                               not dated.
small amounts.

(see also, 3.9)




                     MR




                                                            Key
untability
        States
                             New York                                     Oklahoma
                           Jan 8-13, 2006                              Oct. 24-28, 2005
                                F=17                                         F=27
                                R=7                                          R=7




                                                        F: Inadequate Monitoring: Part A (5), Even
                                                        Start (3), N&D (9), McKinney (8)
                                                        The state's current monitoring system has
             R: Augment Desk Review (2)                 not made any findings even though ED
             The state should augment its desk review   monitors found a number of problems with
             process to include a more extensive review district compliance. The state must ensure
             of district fiscal issues.                 it has an effective method for monitoring
                                                        compliance, and might utilize onsite
                                                        monitoring or the district application review
                                                        process.




                                 MR                                           MR
                     MR                         MR




F: Out-of-Level Testing (3)
The state must discontinue its practice of
permitting schools to test some students
                                                MR
with disabilities at an instructional level
three years below the grade in which they
are enrolled.




R: Verify Alternate Assessment Standards
The state's alternate assessment was
developed prior to issuance of regulations;
the state should verify that it meets current
requirements.

R: English as Second Language Test
As specified in its workbook, the state is
                                                MR
using its ESOL test as the academic test
for LEP students; however, the test is
under peer review and the state must be
prepared to make other arrangements if
peer reviewers determine the ESOL test
does not cover the same academic content
or holds LEP students to rigorous
standards.
                                 F: Disaggregate Data
                                 In disaggregating achievement data for the
                                 ethnic/racial and economically
                                 disadvantaged subgroups, the state
                                 excluded the scores of LEP students and
                                 SWD students. Hence, accountability
                                 determinations for schools and districts
                     MR          were incorrect. The state must properly
                                 disaggregate the data. This finding may
                                 generate administrative action by ED.

                                 R: Timely Determinations (3)
                                 ED recommends that the state make AYP
                                 determinations by Aug. 15 and produce
                                 report cards by Sept. 1.




                                 F: Data Elements Missing, State (10)
                                 The state did not report student
                     MR
                                 achievement results disaggregated by the
                                 required subgroups (see Indicator 1.5).




                                 F: Data Elements Missing, Local (12)
                                 The state did not report student
                     MR
                                 achievement results disaggregated by the
                                 required subgroups (see Indicator 1.5).




                     MR                              MR




                     MR                              MR



onal Support
       States
                 New York                       Oklahoma
                Jan 8-13, 2006                Oct. 24-28, 2005
     R: Plan for Paraprofessional Support (2)
     The state should require districts to
     delineate a plan of action for
MR   paraprofessionals that identifies ways they
     will provide training and technical
     assistance and assist those who have not
     yet met the requirement.




     R: Help Districts Access Support
     The state should make efforts to ensure
MR   that its districts understand the various
     technical support services available and
     how districts can access those services.
F: Parental Involvement Policy (12)
Two districts' plans lacked required
elements, while in another district there
was no evidence that school parental
involvement policies were provided to          F: Parental Involvement Policy (12),
parents.                                       Separate School Plans (4)
                                               The state must ensure that districts work
R: Peer Review                                 jointly with parents to establish a parental
The state should provide technical             involvement policy that includes the six
assistance and guidance to districts to        requirements to build parents' capacity to
ensure that school improvement plans           be involved in school. Schools also must
adequately address parents' role.              work with parents to establish and
                                               disseminate a fully conforming parental
R: Retain Copies of Policy                     involvement policy.
ED recommends that, in addition to mailing
parents a copy of the parental involvement
policy, schools keep copies on hand for
parents to consult.




F: Timely Improvement Notification (2)
The state did not notify parents in a timely
                                                                    MR
manner about districts identified for
improvement.
MR                        MR




     R: Collect/Analyze Participation Data (9)
     ED recommends that the state maintain
     information on SES by individual school
     district to use in monitoring participation
     rates and to evaluate the effectiveness of
MR   efforts to increase participation

     (Note: At the time the monitoring report
     was submitted, ED was still reviewing
     evidence to determine if parents were
     notified of SES options in a timely manner.)
        F: Plans Missing Elements (7)
        The state has not ensured that schoolwide
        plans contain all required elements.
                                                        F: Plans Missing Elements (7)
        R: Offer Guidance to Combine Plans (8)
                                                        The school improvement plan template
        The state should include specific
                                                        used by the state does not include the 10
        information for districts to guide the
                                                        required components.
        development of a single school plan for a
        school in in improvement that is also
                                                        R: Clarify Template
        operating a schoolwide program.
                                                        The state should add a table of contents to
                                                        its school improvement plan template
        R: Annual Update (4)
                                                        identifying where the equivalent schoolwide
        The state should provide guidance to
                                                        program plan component is located.
        schoolwide programs that have been
        operating for a significant period of time to
        ensure they annually review and update
        their plans.




                             MR                                             MR




Responsibilities
      States
                         New York                                       Oklahoma
                       Jan 8-13, 2006                                Oct. 24-28, 2005
     F: Carryover Waivers
     The state must require districts requesting
     waivers of the 15 percent carryover limit to
MR
     explain why the limit was exceeded and the
     actions it will take to bring the excess
     carryover below the maximum.




MR                       MR
     F: Annual Determination
     The state must annually determine that
     districts are complying with all basic Title I
     fiscal requirements prior to awarding funds.

     F: School Allocations -- Hold-Harmless
     Schools identified for corrective action or
     restructuring must receive at least 85
     percent of their allocation from the previous
     year.

     F: Parental Involvement (8)
     The state must ensure that districts
MR
     allocate at least 95 percent of parental
     involvement reservations to schools.

     F: Equitable Services -- Families (5),
     Teachers (6)
     Districts must reserve equitable funding for
     services for the families and teachers of
     participating private school children.

     F: Professional Development (5)
     Districts in improvement must reserve at
     least 10 percent of Title I, A funds for
     professional development.




MR                        MR




MR                        MR
                      MR                                            MR




F: Corrective Action Plans (9)
The state should provide guidance to           F: Corrective Action Plans (9)
districts for the preparation of corrective    The state should provide guidance to
action plans and the timely completion of      districts for the preparation of corrective
corrective action.                             action plans and the timely completion of
                                               corrective action.
F: Timely Corrective Action (8)
The state failed to follow up on a district    F: Timely Corrective Action (8)
cited twice before for failure to failure to   The state did not complete timely corrective
review purchasing and disbursement             actions for recurring audit findings.
procedures.
                                             F: Assess Program Effectiveness (5),
                                             Consultation (6)
                                             Districts must determine how the Title I
                                             program serving private school children will
                                             be assessed, and how annual progress will
                                             be measured. They must also file written
                                             affirmation of consultation.

                                             F: Program Responsibility (10)
                                             In one district the Title I private school
                    MR
                                             program was implemented by a private
                                             school principal. Districts may not delegate
                                             the responsibility for implementing the
                                             program to private schools or their officials.

                                             F: Participant Eligibility (5)
                                             Districts should establish, in consultation
                                             with private school officials, educationally
                                             related objective criteria to identify private
                                             school students for Title I services.




F: Implement Process (2)
The state was unable to document the
implementation of its policy for                                   MR
administering written complaint and appeal
procedures.




                    MR                                             MR
                                              F: Locating Inventory Items (9)
                                              The state was unable to locate certain
                                              equipment items selected for inspection
F: Timely Purchases (3)
                                              from inventory lists.
At one district, equipment was purchased
years before it was actually needed; this
                                              F: Physical Inventory (9)
may cause equipment to be obsolete and
                                              Neither the state nor the districts performed
out of warranty before it is ever used.
                                              a reconciliation of physical inventory of
                                              equipment to the inventory recorded in the
F: Controls (3)
                                              system.
Districts did not reconcile physical
inventories to equipment lists or update the
                                             F: Equipment Transfers (3)
equipment lists. One district did not have
                                             Neither the state nor the districts recorded
written procedures for stolen property, did
                                             transfers of equipment on a regular basis.
not use budget codes, and was not able to
locate items selected for inspection.
                                             F: Controls (3)
                                             Neither the state nor one of the districts
F: Tracking Equipment (2)
                                             maintained adequate controls to account
The state did not ensure that districts
                                             for procurement, location, custody, and
maintained effective policies and
                                             security of, Title I equipment.
procedures for tracking the location of the
Title I inventory.
                                             F: Labels (12)
                                             A district did not put property tags on
                                             equipment.
F: Insufficient Documentation (14)
Three separate findings relating to
documentation: checks were signed but not
dated at one district; vendor invoice
amounts differed from payment amounts             F: Purchase Orders (12)
and purchase orders lacked signatures;            One district used purchase orders that
and disbursements did not all include             allow disbursements to as many as five
vendor's receipts/invoices as supporting          vendors on one "blanket" purchase order.
documentation.
                                                  F: Segregation of Duties (4)
F: Telephone Bid Summary Form                     Districts must have a process to control
In four instances the telephone bid               segregation of duties for approval in the
summary was not used where it should              automated procurement system.
have been, and in one instance a district
selected the highest bidder without               F: Inadequate Contracts
documented justification.                         Contracts to vendors for professional
                                                  services must clearly specify deliverables.
F: Unallowable Expenditure (3)
Title I funds were used to purchase a             R: Approval Communication
refrigerator and microwave with no                The district should communicate the
explanation.                                      authorization of purchase orders directly to
                                                  the accounting office, rather than simply
F: School District Disbursement                   posting Board approvals on a web site.
The state changed district-submitted forms
claiming indirect costs with no explanation.  R: Procurement Process
                                              Control over the procurement process for
F: Unallowable Expenditure (3), Time and professional services should be exercised
Effort Documentation                          by the district financial officer, not by
At one district, six employees were charged budget analysts in the Title I office.
to Title I, A funds but were not listed as
Title I staff, and semi-annual certifications
for dedicated employees were not
maintained.




F: Personnel Improperly Charged (3)
In one district, seven employees that were
                                                                       MR
not on the list of Title I staff were paid with
Title I funds.
                Oregon                      South Carolina
          Feb. 27-March 3, 2006            June 12-16, 2006
                  F=22                           F=14
                  R=4                            R=1




F: Inadequate Monitoring: N&D (9)
The state does not have a system for             MR
monitoring the state agency N&D program.




                   MR                            MR
F: Reading and Math Achievement
Standards (3), Science Achievement
Standards (3), Alternate Achievement
Standards (2)
The state must re-establish academic
                                                 MR
achievement standards in reading and
math; adopt academic achievement
descriptors in science; and re-establish
alternate achievement standards based on
content standards.




F: Out-of-Level Testing (3)
The state's assessment system includes an
out-of-level assessment option, for which it
                                                 MR
received approval last year. It must apply
for the 2 percent flexibility during the 2005-
06 school year.




F: Monitor Assessments (2)
The state must provide evidence of a
system for monitoring the ongoing quality
                                                 MR
of its assessment system, including test
administrations at the district and school
levels.
                                              F: Identification of Districts for Improvement
                                              The state identified districts for
F: Timely Determinations (3)                  improvement by simply counting a district's
The state did not release 2005 AYP results school that were in improvement and
for schools and districts to the public prior placing the district in improvement if a
to the beginning of the next school year,     majority of its schools are in improvement.
and does not have a plan for periodically     This does not conform with the procedure
reviewing its accountability system so that in the state's workbook (or with the law)
unforeseen changes can be quickly             which requires disaggregation of student
addressed.                                    performance. The state must recalculate
                                              district ED reserves the right to take
                                              administrative action.




                     MR                                            MR




                                              F: Data Elements Missing, Local (12)
                                              The state's template for district report cards
                     MR
                                              does not show how the district's students
                                              did in comparison to students statewide.




                     MR                                            MR




                     MR                                            MR




                  Oregon                                    South Carolina
           Feb. 27-March 3, 2006                           June 12-16, 2006
(originally reported under 2.3)

F: Right to Request Qualifications (3)
One district did not notify parents of their    MR
right to request information on the
qualifications of their child's teacher or
paraprofessional.




F: Establish Support System (3)
The state is currently piloting its statewide
system of support, but must provide a           MR
detailed plan for fully implementing this
system.
F: Parental Involvement Policy (12),
Separate School Plans (4)
Districts have not complied with all parental
                                                F: Parental Involvement Policy (12)
involvement policy requirements; one
                                                One district's parental involvement policy
district's policy was a decade out of date
                                                omitted several required components.
and did not include required components.
In addition, some schools are using the
                                                (see also, 2.4 and 2.5)
district policy instead of individual plans.

(see also, 2.1 and 2.6)




                                                (originally reported under 2.3)

F: Plans Missing Components (5)                 F: Incomplete Notification (4)
School improvement plans were missing           One district did not notify parents about
required components.                            how they can become involved in
                                                addressing the academic issues that
                                                caused their child’s school to be identified.
                                              (originally reported under 2.3)

                                              F: Insufficient Publicity
                                              One district notified parents regarding
                     MR
                                              public school choice through the mail, but it
                                              did not use broader means such as
                                              newspapers, posters and the Internet, as
                                              required.




(originally reported under 2.3)

F: Notification Missing Elements (4)                               MR
One district's SES letters omitted required
information.
F: Plans Missing Elements (7)
The state has not ensured that schoolwide
plans contain all required elements.
                                            R: Offer Guidance to Combine Plans (8)
R: Increase Schoolwide Program              The state should include specific
Guidance (2)                                information for districts to guide the
Because schools are confused about the      development of a single school plan for a
difference between schoolwide and           school in in improvement that is also
targeted assistance programs, the state     operating a schoolwide program.
should provide guidance about the
purposes and requirements of each
program.




R: Augment Targeted Assistance Program
Guidance
Because schools are confused about the
difference between schoolwide and
                                                                MR
targeted assistance programs, the state
should provide guidance about the
purposes and requirements of each
program.




                 Oregon                                  South Carolina
          Feb. 27-March 3, 2006                         June 12-16, 2006
MR   MR




MR   MR
                      MR                         MR




ED issued no finding, but noted that it was
working with districts to identify options for
funding extended day kindergarten to             MR
ensure districts comply with Title I
requirements




                      MR                         MR
                                           F: Personnel Funding (2)
                                           The district used a Title I team (nurse,
                                           psychologist, social worker) to screen
                                           children for a district-operated preschool
                    MR                     that was extended with Title I funds. Since
                                           the basic preschool program was district-
                                           funded, a district-funded team should do
                                           the screening. Title I staff must be used to
                                           supplement the team, not replace them.




F: Timely Corrective Action (8)
The state did not implement corrective
action steps, and did not ensure timely
completion of corrective action plans to
address audit findings and
recommendations.
F: Participant Eligibility (5)
One district selected children attending
                                              F: Program Responsibility (10)
private schools for Title I services based on
                                              A district implemented its private school
multiple, educationally-related objective
                                              program, in consultation with the private
criteria, but did not necessarily select
                                              school, through a third-party contractor.
children who also resided in a participating
                                              However, the district had no contract,
Title I school attendance area.
                                              purchase order, or invoice associated with
                                              the contract. This violates several
F: Consultation (5)
                                              requirements regarding contract
The state must require that districts forward
                                              management and does not provide for
annually documentation that the required
                                              adequate monitoring of the services.
consultation has occurred, such as written
affirmation forms.




F: Establish Process and Issue Guidance
(6)
The state had no formal complaint
procedures in place at the time of the                            MR
onsite review, and must ensure that
complaint procedures have been
disseminated to districts.




F: Membership (7)
The state has not ensured that its COP has
the required membership. Membership lists                         MR
must include the membership category that
each member represents.
F: Equipment Records (14)
Districts did not maintain records of
equipment purchased with Title I funds.
None visited were able to provide an
accurate, current list of equipment.
                                              F: Labels (12)
F: Stolen and Missing Equipment Policies
                                              At one district, none of the Title I items
Districts did not have policies on how to
                                              tested had a tag with the property item.
account for stolen or missing equipment.
                                              Instead, the labels had equipment serial
                                              numbers.
F: Equipment Record Reviews
Neither the state nor districts reviewed
                                              F: Equipment Records (14)
equipment records.
                                              Two separate findings: Districts failed to
                                              maintain updated lists of equipment that
F: Physical Inventory (9)
                                              reflected transfers to different locations. A
The state does not perform reconciliations
                                              district listed an item on its Title I inventory
of district equipment lists.
                                              that was actually purchased with a Title III
                                              language acquisition grant.
F: Timely Delivery
The state must develop a corrective action
                                              F: Physical Inventory (9)
plan to ensure timely delivery of Title I
                                              A district failed to perform a reconciliation
equipment to a school after the district
                                              of its equipment list.
takes delivery from the vendor.
                                              F: Equipment Location (3)
R: Equipment Report Templates
                                              A district moved a desk from one room to
The state should develop a template for
                                              another without noting this on the inventory.
inventory lists.

R: Stolen and Missing Policy Development
The state's corrective action plan should
include policies about reporting stolen and
missing items to the police.
F: Insufficient Documentation (14)
The state does not perform reviews to           F: Insufficient Documentation (15)
ensure adequate internal controls and           At one district, invoices for several items
proper disbursements. Two district              lacked the date of receipt or the approval
transactions examined were not charged to       signature. At another district, the financial
Title I, Part A, and two Title I, Part A        office simply compares the invoice with the
charges did not include an approval             original order to ensure the items match;
signature.                                      there is no provision for the official that
                                                actually receives the goods to annotate the
F: Verify Reimbursement Requests                invoice to verify receip and approval. ED
The state does not appear to have an            regards this as a control weakness. Under
effective process to perform timely             a separate finding, an invoice lacked an
verifications of the accuracy, justification,   adequate description of the services
and approval of district reimbursement          provided.
requests.




F: Diversion of Funds
The state must ensure that its districts
allocate Title I funds only to Title I
programs; one district "loaned" Title I
resources to the Reading First Program for
seven months.
                Tennessee                                           Utah
              May 22-26, 2006                                 Dec. 12-15, 2005
                   F=14                                             F=28
                   R=6                                              R=6




                                                F: Inadequate Monitoring: Part A (5)
                                                Because of the many findings under
                                                instructional support and fiduciary
                                                responsibilities, ED concluded that the
                                                state's monitoring process is inadequate.
F: Inadequate Monitoring: N&D (9)
The state does not have a process for           R: More Frequent Monitoring
monitoring the state agency portion of the      The state should identify districts that need
N&D program, and performance data               to monitored on-site more frequently, and
reported under this program component           might use the district application review
may be compromised. (The monitoring             process to further monitor districts.
report also cites Even Start as having a
monitoring deficiency, but it is not global.)   R: Onsite Monitoring
                                                ED recommends that the state conduct
                                                onsite monitoring of high-risk districts and
                                                schools on testing accommodations and
                                                data-quality procedures, instead of desk-
                                                monitoring.




                      MR                                             MR
                                              R: Categorizing LEP Students
                                              The state is properly implementing ED's
                                              2004 LEP flexibility policy, but some
                                              districts are confused. The state should
                                              clarify.

                                              R: Standardize Translations
                                              The state should ensure language
                    MR                        competency of translators, and should
                                              standardize translations of test
                                              administration directions in the five most
                                              common languages.

                                              R: Native Language Expression
                                              The state should consider allowing native
                                              language expression in recording
                                              comprehension responses.



R: Alternative Assessment Participation
Data
The state should report to districts the
                                              F: Student Population Change Appeals
number of students with disabilities who
                                              The state improperly allows and grants
participate in the various types of
                                              appeals based on changes in student
alternative assessments by grade and
                                              populations. The provision to include only
content area.
                                              students that have attended a full
                                              academic year in AYP determinations
R: Differentiate Assessment Data
                                              already reduces the impact of changes in
The state's data should differentiate
                                              student populations.
between students who had directions read
allowed to them and those who also had
items for reading tests read aloud to them.




                    MR                                             MR
     MR                               MR




                  F: Data Elements Missing, State (10)
                  The state report is missing information on
                  the percentage of classes not taught by a
     MR
                  highly qualified teacher disaggregated by
                  high and low poverty schools and a list of
                  schools and districts in improvement.




                  F: Data Elements Missing, Local (12)
                  The district reports are missing information
                  on the percentage of classes not taught by
                  a highly qualified teacher disaggregated by
     MR
                  high and low poverty schools and a list of
                  schools in improvement, as well as
                  academic achievement that compares
                  school, district, and state results.




     MR                               MR




     MR                               MR




 Tennessee                           Utah
May 22-26, 2006                Dec. 12-15, 2005
     (originally reported under 2.3)

     F: Right to Request Qualifications (3)
MR
     Schools must notify parents of their right to
     request to see the qualifications of their
     child's teachers.




     F: Establish Support System (3)
     The state must provide a detailed plan and
     timeline for developing and implementing a
     statewide system of supports, including the
MR
     role of each component, what technical
     assistance will be provided, how districts
     will access the system, and how the state
     will oversee the system.
            F: Parental Involvement Policy (12),
            Separate School Plans (4)
            Districts should involve parents in
            developing plans, provide technical
            assistance, coordinate involvement
(see 2.6)
            policies, and conduct annual evaluations.
            Also, Title I schools should not use district
            policies for individual schools.

            (see 2.5 and 2.6; see also, 2.1 and 2.4)




            F: Plans Missing Components (5),
            Individual School Plans
            School improvement plans were missing
            required components, and four schools had
            identical school plans rather than
            differentiating based on individual school
            needs.
  MR
            originally reported under 2.3:

            F: Timely Improvement Notification (2)
            The state must immediately notify parents
            of districts identified for improvement,
            including reasons for the identification and
            how parents can participate in improving
            their districts.
                                              (originally reported under 2.3)

R: Collect/Analyze Participation Data (7)     F: Timely Choice Notification, Notification
The state should conduct an analysis of       Missing Elements (5)
choice participation rates, and, when rates   Parental notification letters were not
are low, determine the cause and establish    complete and required parents to contact
methods to increase rates.                    principals for information on how to access
                                              choice services. Notification letters must be
                                              timely and complete.




F: Notification Missing Elements (4)
SES letters were missing information on     (originally reported under 2.3)
the identity of approved providers and
where parents could easily obtain a sign-up F: Notification Missing Elements (4),
form without attending a meeting.           Untimely SES Notification
                                            Parental notification letters were not
(item above was originally reported under   complete and required parents to contact
2.3)                                        principals for information on how to access
                                            SES services. Notification letters must be
R: Collect/Analyze Participation Data (9)   timely and complete.
The state should conduct an analysis of
SES participation rates, and, when rates
are low, determine the cause and establish
methods to increase rates.
                  F: Plans Missing Elements (7)
                  The state has not ensured that schoolwide
                  plans contain all required elements.

                  R: Offer Guidance to Combine Plans (8),
                  Annual Update (4)
     MR           The state should develop a template for
                  combining schoolwide and improvement
                  plans into a single plan that meets all
                  requirements, and should ensure that
                  schools operating schoolwide plans
                  annually review and revise their plans.




     MR                              MR




 Tennessee                          Utah
May 22-26, 2006                Dec. 12-15, 2005
                                                F: Support System Reservation
                                                The state did not expend 5 percent of the 4
                                                percent reserved from the Title I, A
                                                allocation to create and maintain a
                                                statewide system of support for schools in
                                                improvement.

                                                F: Reallocation Policy
                      MR                        The state must develop a policy for
                                                reallocating Title I, Part A funds.

                                                F: District Applications
                                                The state should develop a process for
                                                reviewing applications so that districts
                                                applying for school improvement funds
                                                describe how they will provide resources
                                                for lowest-achieving schools.




R: Identify Set-Asides
The state should consider requiring
districts to use the form it developed to
                                                                    MR
determine set-aside amounts. District and
state staff were not able to clearly identify
set-aside amounts.
F: Rank Order Procedures (4)
                                                 F: Parental Involvement (8)
One district used grade-span grouping to
                                                 The state has not ensured that districts
rank its schools, but grouped certain
                                                 allocate at least 95 percent of their 1
schools in an "alternative" category,
                                                 percent parental involvement set-aside
separate from their normal grade-span
                                                 directly to their schools. Instead, the funds
grouping. The result was that an alternative
                                                 are retained at district level and each Title I
school was not served even though
                                                 school is required to reserve at least 1
schools serving the same grade level with
                                                 percent of its allocation for parental
lower poverty levels were funded.
                                                 involvement activities.
F: Equitable Services -- Families (5),
                                                 F: Equitable Services -- Families (5),
Teachers (6), Instructional Set-Aside (2)
                                                 Teachers (6)
A district failed to use the correct method to
                                                 Districts must reserve an equitable portion
calculate the private school set-aside for
                                                 of Title I funds to provide equitable services
services to private school families and
                                                 to families and teachers of participating
teachers and for the district-wide
                                                 private school students.
instructional services. Although the
amounts set-aside for these purposes
                                                 F: Professional Development (5)
actually met the required amounts, the
                                                 D istricts in improvement reserve at least
incorrect procedure did not guarantee that
                                                 10 percent of Title I, A funds for
set-asides would meet federal
                                                 professional development.
requirements.




                     MR                                                MR




R: Paraprofessionals (2)
Two districts count paraprofessionals as
full time equivalent (FTE) staff when
calculating comparability; while not in
violation of the statute, ED recommends                                MR
that districts count paraprofessionals as
less than a FTE since paraprofessionals
must work under the supervision as a
highly qualified teacher.
Note: ED will work with the state to clarify
supplement not supplant requirements as
they apply to districts funding pre-K                              MR
programs with both Title I and state pre-K
funds.




                                               F: Corrective Action Plans (9)
                                               The state did not provide guidance to
                                               districts, in the form of documented
                     MR                        procedures, for the preparation of
                                               corrective action plans and the timely
                                               completion of corrective actions to address
                                               audit findings.
                                              F: General Aid (3), Participant Eligibility (6)
                                              In one district, Title I-funded services
F: Instructional Services
                                              provided to private school children were
Funds generated for instruction for private
                                              supplanting private school services and
school children must be used only for
                                              were delivered to children who were not
instructional services. One district's
                                              eligible for Title I.
contracts for instructional services, per se,
did not match the amount on the budget for
                                              F: Consultation (5)
services for private school students.
                                              Districts must consult with private school
                                              officials and obtain written confirmation of
F: Program Responsibility (10)
                                              this consultation.
Districts must maintain control of the
program for participating private school
                                              F: Assess Program Effectiveness (5)
children; a private school contractor, rather
                                              Districts should establish standards to
than district staff, signed purchase orders
                                              determine what constitutes annual
and then invoiced districts.
                                              progress for Title I programs serving
                                              private school children.
F: Third-Party Contractors
A district's contract with a contractor to
                                              F: Participant Eligibility (5)
serve private school students referred to
                                              Districts should establish, in consultation
supplemental educational services, which
                                              with private school officials, educationally
are governed by different requirements.
                                              related objective criteria to identify private
Districts must ensure that third parties
                                              school students for Title I services.
provide the Title I services with Title I's
private school requirements, and must
                                              F: Paraprofessionals
have signed contracts with providers that
                                              Paraprofessionals providing services to
give detailed descriptions of services to be
                                              private school students must be supervised
provided.
                                              by a highly qualified teacher employed by
                                              the district (not by private school teachers).




                     MR                                             MR




F: Membership (7)                             F: Membership (7), Involvement
The state has not ensured that its COP has    The state must ensure that members of the
the required membership; its COP currently    COP meet membership requirements, and
has only one representative of private        that the COP be involved in state
school children.                              administration of Title I.
F: Locating Inventory Items (9)
One item selected for inspection had been
moved with no record, and one item was
not in working condition.

F: Labels (12)                               F: Locating Inventory Items (9)
Some equipment items were missing            The state was unable to locate certain
property tags, or were labeled with self-    equipment items chosen for inspection
stick removable labels or directly with      from inventory lists.
permanent marker.

F: Equipment Records (14)
One district's record of equipment did not
include the cost of each item.
F: Payment Requests
Payment requests did not include the date
and signature (or initials) of individuals with
authority to approve payments. ED regards
                                                F: Purchase Orders (12)
this as a material weakness.
                                                One district issued purchase orders at the
                                                end of the purchase process.
F: Purchase Orders (12)
Some purchase orders and invoices were
                                                F: Insufficient Documentation (14)
missing signatures or dates.
                                                The state must make sure to provide payee
                                                information or supporting documentation
F: Data Accuracy
                                                for disbursement payments.
In one district, a disbursement was
recorded incorrectly. The state must
develop a plan to ensure that data entered
into the procurement system are accurate.




                                             F: Personnel Improperly Charged (3)
                                             The state did not ensure the timely
                    MR                       reclassification of salary and benefits when
                                             an employee transfers from one program to
                                             another within the department.
     Vermont                         West Virginia
Nov. 28-Dec. 2, 2005                  Apr. 3-7, 2006
       F=22                                F=11
        R=3                                R=8




                       F: Inadequate Monitoring: N&D (9)
                       The state has not monitored either the
                       state agency or the local component of the
                       program for several years. Monitoring of
        MR
                       the local component is scheduled for 2006-
                       07. (The monitors also cited a deficiency in
                       follow-up on Part A audits, but this was not
                       a global finding.)




        MR                                 MR
F: Alternate Achievement Standards (2)
There are no alternate achievement
standards associated with Vermont's
Adapted Assessment, which is intended for
students working toward the same
standards and grade-level expectations as
                                            MR
their grade-level peers but at a
substantially lower level of performance.
The state must develop a documented
standards-setting process for making
proficiency decisions rather than using
recommendations of the Assessment team.




F: Out-of-Level Testing (3)
The state must eliminate its out-of-level
option on its Adapted Assessment in
                                            MR
compliance with the December 2003
regulation on the 1 percent cap when
calculating AYP.




                     MR                     MR
F: Timely Determinations (3)
The state must provide decisions about
AYP in time for districts to implement the
required provisions before the beginning of
the next academic year.
                                                                   MR
R: Define Governance and District
Accountability
In 2004, the state legislature changed the
governance structure and the definition of
an LEA; the state's accountability workbook
should reflect those changes.




F: Data Elements Missing, State (10)          F: Data Elements Missing, State (10)
The state report does not include the         The state report is missing information on
percentage of classes not taught by a         the comparison of actual achievement
highly qualified teacher disaggregated by     levels to the state's objectives, and recent
high and low poverty schools.                 two-year trends in student achievement.




F: Data Elements Missing, Local (12)
                                              F: Data Elements Missing, Local (12)
District report cards were missing required
                                              The district reports are missing information
information: disaggregated student
                                              on student achievement disaggregated by
achievement at each proficiency level;
                                              categories such as race, gender, disability
comparison of actual achievement to
                                              status, etc.
objectives; how students served by the
district compared to the state as a whole;
                                              R: Web-Based Report Card
the percentage of students not tested,
                                              The state should improve the accessibility
whether a district made AYP; and teacher
                                              of data on its web-based report card.
qualifications.




                    MR                                             MR




                    MR                                             MR




                 Vermont                                    West Virginia
           Nov. 28-Dec. 2, 2005                              Apr. 3-7, 2006
                    MR                        MR




F: Distinguished Principals and Teachers,
Academic Achievement Award Program
The state must ensure that its statewide
                                              MR
system of support includes distinguished
principals and teachers, and must establish
an Academic Achievement Award Program.
                                             F: Parental Involvement Policy (12)
                                             Not all districts and schools have
F: Parental Involvement Policy (12)
                                             completed the process necessary to
Parental involvement policies were missing
                                             develop updated parental involvement
components relating to building parent
                                             policies.
capacity for involvement. Policies should
also include plans for annual evaluations of
                                             R: Increase Parental Understanding (2)
effectiveness and identification of barriers
                                             Parents are not always clear about how
to involvement.
                                             parental involvement policies differ from
                                             parent-school compacts.




F: Teacher Mentoring Program
School improvement plans were missing
the required teacher mentoring component.                         MR

(see also 2.7)
     R: Collect/Analyze Participation Data (7)
     The state should analyze choice
     participation rates and establish
     procedures to increase rates where
     possible.
MR
     R: Coordinate Choice and SES
     Notifications
     Where applicable, districts should try to
     make choice and SES letters arrive at the
     same time so that parents are aware of
     both opportunities.




     R: Collect/Analyze Participation Data (9)
     The state should analyze SES participation
     rates and establish procedures to increase
     rates where possible.

MR   R: Coordinate Choice and SES
     Notifications
     Where applicable, districts should try to
     make choice and SES letters arrive at the
     same time so that parents are aware of
     both opportunities.
F: Plans Missing Elements (7)
Schoolwide plans were missing
components for recruiting and retaining
highly qualified teachers and assisting
preschool children to transition to school.
                                                   MR
R: Offer Guidance to Combine Plans (8)
The state should include specific
information for districts to guide the
development of a single school plan for a
school in in improvement that is also
operating a schoolwide program.




                     MR                            MR




                 Vermont                      West Virginia
            Nov. 28-Dec. 2, 2005              Apr. 3-7, 2006
F: School Improvement Fund Distribution
Protocol
The state must finishing developing the
protocols for making grant awards for
school improvement, methodologies for           MR
distributing funds, and a plan for allocating
unused funds to districts. It must also
clarify the role of districts and Committees
of Practitioners in the process.




                     MR                         MR
MR   MR




MR   MR




MR   MR
                     MR                                               MR




F: Corrective Action Plans (9)
The state should provide guidance to
districts for the preparation of corrective
action plans and the timely completion of
                                                 F: Corrective Action Plans (9)
corrective action.
                                                 The state did not ensure that its districts
                                                 prepare corrective action plans and
F: Management Letter Not Issued
                                                 complete in a timely manner corrective
A management letter that addressed a
                                                 actions to address audit findings.
district's financial statement audit report
was not available for review; if the state did
not issue a letter, it must explain to ED why
it did not.
                    MR                       MR




F: Establish Process and Issue Guidance
(6)
The state should develop formal complaint
                                             MR
procedures, and ensure districts implement
the procedures and provide guidance to
schools.



F: Establish COP (2)
The state must complete its reconstitution
of COP membership, prepare a list of
qualifications for membership, and publish   MR
a roster. The state must also finalize a
description of duties and designate
subgroups to work with related programs.
                                              F: Equipment Records (14)
                                              Equipment records had incomplete
                                              information about equipment, purchase
                                              dates, and item types.

F: Physical Inventory (9)                     F: Log-Out Procedures (5)
Districts must conduct annual physical        The state does not have effective
inventories and reconcile the physical        procedures to maintains custody and
inventories to equipment recorded in          control of equipment used off-site.
property systems.
                                              F: Labels (12)
F: Labels (11)                                Items did not have property tags, or had
The state must establish controls to          incorrect serial numbers recorded.
account for procurement, location, custody,
and security of, equipment, including bar     F: Timely Purchases (3)
codes, property tags, or alternative means    Three items selected for inspection were
of identifying equipment.                     obsolete, and some equipment was
                                              acquired before it was actually needed.

                                              F: Capitalization Threshold (2)
                                              One district's capitalization threshold
                                              exceed the state policy's limit.
F: Segregation of Duties (4)
Districts must have a process to control
segregation of duties for approval in the
automated procurement system.

F: Inadequate Invoices (13)
A vendor invoice did not include a notation
indicating approval signature.

F: Purchase Orders (12)
One district approved a purchase order
after goods were already received.
                                              F: Inadequate Invoices (13)
F: Insufficient Documentation (14)
                                              Invoices did not indicate the description of
Two separate findings relating to
                                              services provided or the number of
documentation: one district was not able to
                                              students served.
provide invoices or receipts to support
transactions; and another district did not
have sufficient documentation to support a
purchase order.

F: School Lunch Applications
School lunch applications, used for
eligibility, were not fully completed.

R: District Guidance
The state should refine its guidance on
employee certification and adapting local
forms.




                      MR                                           MR
                 Wyoming
               June 5-9, 2006
                   F=13
                   R=14


F: Inadequate Monitoring: Part A (5), Even
Start (3), N&D (9), McKinney (8)
The state indicated that one district was in
compliance with Part A, but the ED team
identified areas not in compliance. The
state did not monitor Even Start grantees,
and the grantees were not using required
data collection instruments. The state did
not monitor the N&D state agency
component; a contractor monitored the
local component but the state did not follow-
up. Under McKinney, the state reviewed
district data reports but the state did not
monitor districts with or without McKinney
grants sufficient to ensure compliance.

R: Timely Monitoring
The state has a three-year plan to monitor
districts, but did not perform all scheduled
on-site visits. The state should revise its
schedule to ensure that all districts receive
monitoring visits within a prescribed period
of time.




                     MR
MR




MR




MR
     MR




     MR




     MR




     MR




     MR




 Wyoming
June 5-9, 2006
                      MR




R: Instructional Facilitators
Since the state considers instructional
facilitators part of its statewide system of
support, the facilitators must be
knowledgeable about Title I school
improvement requirements and well-
informed about technical assistance and
support efforts.
                   MR




F: Plans Missing Components (5)
The template used by schools does not
contain required components, and as a
result school improvement plans are
missing components.

F: Plans Missing Components (5)
Although the state has provided guidance,
district improvement plans do not include
all required components.

F: Improvement Status
One district in improvement made AYP for
one year and was considered to be no
longer in improvement; the state should
clarify requirements for districts in
improvement.

R: Revise Plan Templates
The state should revise school
improvement templates so that NCLB
requirements correspond with a state
agency's requirements.
                    MR




R: Increase Providers (2)
Interviews indicated that SES options were
limited to online approaches; the state
should seek input about what SES interest
parents and should expand the pool of
potential providers.

R: Timely SES
SES were not offered until late in the
school year; the state should provide
technical assistance to encourage districts
to offer SES earlier in the year.
R: Integrate State Plans
The state should consider integrating the
schoolwide plan into a state agency's
improvement planning process.

R: Offer Guidance to Combine Plans (8)
The state should include specific
information for districts to guide the
development of a single school plan for a
school in in improvement that is also
operating a schoolwide program.

R: Increase Schoolwide Program
Guidance (2)
Confusion exists at the school level about
the purpose of schoolwide programs and
how they operate.

R: Parental Involvement (3)
Parents may not be clear about the
purpose of schoolwide programs or how to
become involved.




                    MR




                Wyoming
              June 5-9, 2006
                    MR




R: Clarify Budget
The state should consider adding a ten-
percent professional development set-
aside as a separate entry on its
consolidated application budget.

R: Calculating Equitable Services
The state should add details showing how
to calculate equitable services
reservations, including distributing a
worksheet developed by one district.
F: Rank Order Procedures (4)
Some low-poverty schools received higher
per-pupil amounts than higher-poverty
schools.

F: Per-Pupil Allocations (2), Parental
Involvement (8)
The state did not ensure that districts
correctly reserved funds before allocating
funds to schools. One district did not set
aside the required 1 percent for parental
involvement; instead, it required each
school to set aside 2 percent of its funds
for this purpose.

R: Calculating Poverty Percentages (2)
The state should consider requiring
districts to use only public school data
when calculating poverty percentages for
rank ordering services.

R: Pooling Funds
The state should provide guidance to
districts serving private school children on
the pooling of funds if not all private
schools choose to participate in Title I.

R: Allocation Rationales
The state should consider asking for a
rationale when a district, even one exempt
from rank order requirements, allocates
Title I funds out of rank order.




                     MR




F: Performing Calculations (3)
Districts were not completing comparability
calculations annually and submitting
documentation to the state once every two
years.
MR




MR
F: Program Responsibility (10)
One district provides instructional services
through a paraprofessional, but allows
private school teachers to monitor the
individual.

F: Consultation (5)
The state did not collect signed affirmation
forms to verify that required consultations
were occurring.

F: Complaint Procedures
The state failed to ensure that private
school personnel were aware of their right
to complain if a district did not participate in
meaningful consultation.

F: Assess Program Effectiveness (5)
Districts must determine how the Title I
program in private schools will be
assessed and how annual progress will be
measured.




F: Establish Process and Issue Guidance
(6)
The state's draft complaint procedures
have not been reviewed by the Committee
of Practitioners, approved by state
leadership, or disseminated to the public.




F: Membership (7)
The state COP is missing required
members; specifically, there are no private
school representatives.
Not reviewed
Not reviewed




Not reviewed

								
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