FY16 Unit Count Performance Audit Final Report (Signed)

8/17/2019 FY16 Unit Count Performance Audit Final Report (Signed)

1/31

R. Thomas Wagner, Jr., CFE, CGFM, CICA

Auditor of Accounts

State of Delaware

Office of Auditor of Accounts

Statewide eSchoolPLU S and Unit Count

Performance Audit

Fiscal Year Ending June 30 2016

Issuance Date: May 4 2016


2/31

STATE OF DELAWARE

O

FFICE OF

A

UDITOR OF

A

CCOUNTS

R.

T

HOMAS

W

AGNER

,

J

R

.,

CFE,

CGFM,

CICA P

HONE

:

302-739-4241

A

UDITOR OF

A

CCOUNTS

F

AX

:

302-739-4217

401 FEDERAL STREET ● TOWNSEND BUILDING ● SUITE ONE ● DOVER, DE 19901

V

ISIT OUR WEBSITE TO VIEW

,

DOWNLOAD

,

OR PRINT AUDIT REPORTS AND OTHER INFORMATION

http://auditor.delaware.gov

To the Specified User(s) of the Report:

The Honorable Dr. Steven H. Godowsky SecretaryDepartment of Education401 Federal Street, Suite 2Dover, Delaware 19901

Superintendents, All School DistrictsBusiness Managers, All School DistrictsCharter Heads, All Charter SchoolsBusiness Managers, All Charter Schools

The attached report provides the results of the Statewide eSchoolPLUS and Unit CountPerformance Audit for the fiscal year ending June 30, 2016.

My office was authorized, under 29 Del. C., c. 29, to perform post audits of all the financialtransactions of all State agencies. The law requires that the audits be made in conformity withgenerally accepted auditing principles and practices. Such principles and practices are establishedby the U.S. General Accounting Office, which has issued generally accepted government auditingstandards.

We conducted this performance audit in accordance with Generally Accepted Government Auditing Standards issued by the Comptroller General of the United States. Those standards

require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide areasonable basis for our findings, and conclusions based on our audit objectives. We believe thatthe evidence obtained provides a reasonable basis for our findings and conclusions based on ouraudit objectives.

This report can be accessed online through the Auditor of Accounts website athttp://www.auditor.delaware.gov .

Sincerely,

R. Thomas Wagner, Jr., CFE, CGFM, CICA Auditor of Accounts

May 4, 2016


3/31

State of Delaware Statewide eSchoolPLUS and Unit Count Performance Audit

i

State of Delaware

Office of Auditor of Accounts

R. Thomas Wagner, Jr., CFE, CGFM, CICA

At a Glance

Working Hard to Protect YOUR Tax Dollars

Why W e Did This Review

The Office of Auditor of Accounts (AOA)conducted a performanceaudit of eSchoolPLUS andthe annual Unit Count (alsoknown as the September30th Unit Count) for theperiod July 1, 2015 through June 30, 2016 to determinethe sufficiency andreliability of the processesencompassing the UnitCount. The work isintended to supplement theaudit coverage alreadyobtained through theannual StatewideComprehensive AnnualFinancial Report and the

Statewide Single Audit.

For further information onthis release, please contact:

Kathleen A. Davies

CPA-PA, CFE, CISA,

CGFM, CGAP

Chief Administrative

Auditor/Deputy

(302) 857-3919

What We Found

AOA found that there was a lack of management participation in key operationalactivities. Several districts and charter schools failed to attend the entranceconference or to develop individualized policies and procedures governing UnitCount. Some charter schools delegated these responsibilities to InnovativeSchools.

AOA found that there is a lack of uniform standards surrounding the Unit Countprocess. This includes the format and required documents of the comprehensiveenrollment file. As a result, we identified incidents of missing and incompletedocumentation.

Many of the inconsistencies and errors we found could be attributed to lack oftraining. While DOE administers training annually, there is no requirement thatindividuals attend this training before being assigned Unit Count responsibilities. AOA encountered several instances where the individual performing key UnitCount tasks had not attended the training and were unfamiliar with the UnitCount processes.

AOA found a total of 9 students who should not have been included in the UnitCount. These disallowances were attributed to errors and failure to follow therequirements provided for in DOE’s Unit Count Manual.

There is also no standard for qualifying a child for Early Admission toKindergarten. The districts and charter schools are responsible for developingtheir own plans and must only follow the broad requirements provided for inDelaware Code. As a result, there were 28 students across four charter schools whose enrollment in Early Kindergarten was unsupported.

DOE has a process for the monitoring of Units earned for special education andtheir allocation. However, no such process exists for monitoring of the Units

related to regular education. There is also no statewide requirement for thedistricts or charters to maintain a staffing plan detailing how the Units wereallocated, nor is DOE monitoring the allocation and use of such funding. Thisposes an increased risk for non-compliance with funding allocation generated bythe Unit Count including potential to overcharge or undercharge.

Lastly, AOA found weaknesses in the IT controls surrounding Unit Count PLUSthat DOE should address to ensure proper segregation of duties and continuity ofoperations.


4/31


Table of Contents ii

Table of Contents

Objective, Scope, and Methodology 1

Background 2

Procedures and Results 9

Appendix A

Appendix B

22

24

Appendix C 25

Abbreviations

AOA Auditor of AccountsAOC All Other CostsCMO Charter Management OrganizationCOSO

Committee of Sponsoring Organizations of the Treadway CommissionCRSD Caesar Rodney School DistrictCTE Career and Technical EducationDOD Department of DefenseDOE Department of EducationDSU Delaware State UniversityFISCAM Federal Information System Controls Audit Manual

FSR Full Student RegisterHS

High SchoolIDEA Individuals with Disabilities Education AcIEP Individual Education PlansIMS Identity Management SystemIT Information TechnologyK KindergartenNCCVT New Castle County Vo-TechOMB

Office of Management and Budget


5/31


Objective, Scope, and Methodology 1

Objective, Scope, and M ethodology

The audit objective was to determine the reliability and sufficiency of the various processes thatcontribute to the annual Unit Count for the period of July 1, 2015 through June 30, 2016. Ouraudit concentrated on analyzing the processes that can result in the incorrect funding based on

ineligible student enrollment. The work is intended to supplement the audit coverage alreadyobtained through the annual Statewide Comprehensive Annual Financial Report and the StatewideSingle Audit.

The Office of Auditor of Accounts (AOA) performed the following procedures:

Obtained the Full Student Register (FSR) to corroborate numbers submitted during UnitCount.

Obtained attendance records for Unit Count training to determine if all districts wererepresented.

Inspected the processes in place regarding Unit Count to determine if they are in line with

the DOE manual. Interviewed various school staff regarding the processes around Unit Count to determine

their understanding.

Obtained details regarding DOE staff duties covering Unit Count processes to determine ifcurrent staffing is sufficient.

Evaluated the process to admit students early to kindergarten.

Reviewed and evaluated IT controls for Unit Count PLUS.

Our observations, findings, and related recommendations resulting from these procedures arepresented in this report.


6/31


Background 2

Background

Introduction

At September 2015, the Delaware Department of Education (DOE), located in Dover, served 19school districts and 27 charter schools.1 The mission of the Department is to promote the highest

quality education for every Delaware student by providing visionary leadership and superiorservice. The Department is headed by a cabinet secretary and consists of approximately 261 staffmembers. The Department’s major funding source is the State General Fund.

Delaware school districts and charter schools receive State funding based on a calculation by theDOE using each district’s September 30th Unit Count. Pursuant to 14 Del. C. §1704(1) the numberof units shall be calculated based upon the total enrollment of pupils in each school district as ofthe last school day of September. All students counted during the measurement period aremonitored for attendance during the last 10 student days prior to September 30th to determinetheir inclusion in the Unit Count. The Unit Count calculation includes the total pupil enrollmenton the last school day in September2 and considers various factors such as grade level and, if

applicable, the special education needs of the child. According to DOE’s Unit Count RegulationsManual and Unit Count Training materials, enrollment is defined as “…unless there is reason tobelieve that a pupil’s attendance during the ten-day period is fleeting or momentary, his/herpresence in school for all or part of the 10 days effectively “enrolls” him/her as of the last day ofSeptember for the school year.” The parameters of when to count a student when absent areunspecified and require a serious judgment call by the district or charter school. The 2015 UnitCount began on Thursday, September 17, 20153 and ended on Wednesday, September 30, 2015.This period may also be referred to as the FY16 Unit Count.

All districts and charter schools complete the September 30th enrollment and unit computationreporting requirements through a link between eSchoolPLUS4, the statewide pupil accounting

system, and Unit Count PLUS, a DOE web-based Identity Management System (IMS) applicationthat enables districts and charter schools to verify their September enrollment and unit allotmentreporting requirements. eSchoolPLUS is a system offering the following tools for managingstudent information:

Student Administration – Provides school districts with the tools to manage day-to-daystudent administration and information such as enrollment, demographics, schedules,attendance, discipline, standardized tests, report cards, and transcripts.

Teacher Access Center – Provides teachers with an online gradebook , assignment andattendance management system, and the ability to easily communicate with parents.

1 The Delaware Met, which was included in our review, closed on January 22, 2016.2 14 Del. C. §17043 An in-service day during the 10-day window allows for the school district or charter school to back up a day for thestart date (i.e. Unit Count would begin on Wednesday, September 16, 2015 and end on Wednesday, September 30,2015).4 eSchoolPLUS is a comprehensive student information management application that provides powerful tools forteachers, administrators, parents, and students. This application was developed by SunGard Public Sector Inc.


7/31


Background 3

Home Access Center – Provides parents the ability to be more informed of their child’sgrades, attendance, assignments, and discipline information.

IEPPLUS – Provides school districts with a means to manage all Individual EducationPlans (IEP)5 for students with special education needs, which streamlines the Federal and

State special education reporting process.

How is the Unit Count Performed?

The Unit Count process is performed at the school district level and starts when a student isenrolled in a district and his or her information is entered into eSchoolPLUS. System access iscontrolled through a user file. District and charter school staff are assigned access rights either atthe school level or both the district and school level. The required Unit Count calculationsprescribed by 14 Del. C. §1703(a) are preloaded into the system. Provided the formula 6 is codedcorrectly in the system, this process will help ensure the mathematical accuracy of the Unit Countcalculation.7 Once the Unit Count process starts, the following events occur:

Enrollment and student demographic data for each student including special educationdata maintained in eSchoolPLUS, is captured twice daily at 11:30 a.m. and 11:30 p.m. andloaded into Unit Count PLUS which automatically generates enrollment, units, and district-level position allotments.

All IEP information entered into IEPPLUS is integrated into eSchoolPLUS as scheduledby the individual district/charter school and then captured twice daily along with enrollmentand student demographic data for each student at 11:30 a.m. and 11:30 p.m. and loadedinto Unit Count PLUS.

Unit Count PLUS calculates occupational-vocational units based on the schedules for

students who are enrolled in state-approved Career and Technical Education (CTE)Program courses.8

After the Unit Count process is complete, the district/charter school’s Unit Count Coordinator isrequired to submit to the signed and dated Needs Based Detail by School Report for all schools intheir district/charter school and the signed and dated cover letter to the State Unit CountCoordinator9 by the designated deadline. Each building administrator is required to generate theeSchoolPLUS Full Student Register (FSR) Attendance report. This report is signed and dated bythe building administrators and placed in the school’s audit file as verification of studentattendance during the last 10 school days of September for student’s counted in the September 30th Unit Count.

5 IEPs are federally mandated by the Individuals with Disabilities Education Act. An IEP defines the individualizedobjectives of a child who has been found with a disability, as defined by federal regulations.6 See Table 1 7 Key factors to Unit Count calculation: 1)eligible student, 2)appropriate grade level, 3)accuracy of special needsclassification, and 4)preloaded formula prescribed by State code.8 The scheduling component of eSchoolPLUS tracks the number of minutes in each approved CTE class. Inaddition, the system ensures that those students who are enrolled in both regular and occupational-vocationalprograms are not double-counted during the Unit Count.9 See Section “DOE Staffing” to see State Unit Count Coordinator’s duties as it relates to the Unit Count.


8/31


Background 4

How is Funding Received?

There are three primary state funding types received by public school districts and charter schoolsas a result of units generated through the September 30th Unit Count. The categories are DivisionI (Salaries and Benefits), Division II (All-Other Costs and Energy), and Division III (Equalization).

Division I Salaries and Benefits)Division I funding pays the state share of salary and benefits.10 It is intended to provideapproximately 70% of a teacher’s salary with the balance provided by local funds. DivisionI units generate authorized positions yielding from various formulas for teachers,administrators, and instructional staff.

“Table 1” below, shows teachers that are earned per a prescribed number of pupilscounted in each funding needs category.

Table 1: Division I Teacher U nits

Funding Needs Category

11

Teachers Earned

12

Preschool 1 per 12.8 pupils

K-3 (Regular and Special Education) 1 per 16.2 pupils

4-12 Regular Education 1 per 20.0 pupils

4-12 Basic Special Education (Basic) 1 per 8.4 pupils

Pre K-12 Intensive Special Education(Intensive)

1 per 6.0 pupils

Pre K-12 Complex Special Education(Complex)

1 per 2.6 pupils

“Table 2” below provides examples of other administrative and instructional positions thatare generated based on the total number of units counted.

Table 2: Division I Support Staff and Administrator Units

Position

13

Positions Earned

14

Superintendent 15 1 per District

Assistant Superintendent 1 per 300 units (maximum 2)

Director 1 per first 200 units; 1 per 100 unitsthereafter (maximum 6)

Supervisor 1 per 150 units

Supervisor of Transportation 1 per 7,000 or more transported pupils

Specialist – Visiting Teacher 1 per 250 units

Specialists – Related services positions which include physical therapists,

1 per 57 units K-3, 4-12 RegularEducation, and 4-12 Basic; 1 per 5.5

10 14 Del. C. §170211 For unit definitions, please refer to 14 Del. C. §1703(d).12 14 Del. C. §1703(a)13 14 Del. C. §1301 states that position classifications are defined by the certifying board.14 14 Del. C.1315 Per 14 Del. C. §1306(b), each school district is entitled to one superintendent. The superintendent’s salary scaleincorporates unit amounts into the salary calculation.


9/31


Background 5

occupational therapists, speech languagepathologists, school psychologists orother related service specialist

Intensive units; 1 per 3 Complex units

CTE Programs are also funded based on the September 30th Unit Count and result incorresponding occupational-vocational units. Delaware CTE Programs include, but are

not limited to, Agriscience, Business Finance and Marketing, Family and ConsumerSciences, and Skilled and Technical Sciences.16 For New Castle County VocationalTechnical School District, Polytech School District, and Sussex Technical School District,every 30 students enrolled equals one occupational-vocational unit. For reorganized schooldistricts and charter schools, occupational-vocational units are based on the minutes per week a pupil is provided an approved CTE Program.17

Charter Schools

Students enrolled in a charter school and included in the charter school’s unit count mustbe listed on the enrollment roster within Unit Count PLUS. The roster provides the basisfor transferring local funds18 attached to students who are enrolled in and are attending a

charter school. Additionally, this roster serves as an audit trail.

Division II All-Other Costs and Energy)

Division II funding consists of All Other Costs (AOC) and Energy.19 AOC fundingprovides resources for the classroom which include textbooks, furniture, and otherclassroom equipment. Energy funds pay to heat and cool school buildings. EarnedDivision II Vocational AOC funds provide resources to CTE programs. The unit valuesof AOC and Energy are approved annually in the Operation Budget Bill. For FY 2016,school districts and charter schools will receive $2,925 for each AOC Unit and $2,435 foreach Energy Unit.20 For example, for every 100 units, the school district or charter school would receive $292,500 for AOC and $243,500 for Energy.

Division III Equalization )

Division III funding, referred to as equalization funding, attempts to balance the disparityin funding received by districts as a result of disproportionate property values.21 Equalization is intended to ensure that each district has substantially the same level ofresources with which to educate each student. School districts receive varying amountsbased on a complex tax effort formula that takes into consideration the property wealth of adistrict compared to the State average property wealth, as well as the district’s tax effort, or willingness of the district’s citizens to accept higher tax rates. The Equalization PolicyCommittee was established in 1989 to review the formula annually and makerecommendations as needed.22 Upon completion of the calculation, total state equalization

shall be computed by multiplying the State’s share per unit times the number of units of

16 http://www.doe.k12.de.us/Page/15717 14 Del. C. §1703(g)18 From the student’s district of residence.19 14 Del. C. §1702, §170620 FY 2016 House Substitute No. 1 for House Bill No. 225, Section 318, page 21321 14 Del. C. §1702, §1707(g)22 2016 Equalization Committee Report


10/31


Background 6

pupils enrolled in the school district, the vocational school district, or the special school inthe fiscal year for which the Division III funds are appropriated. Division III funding isdiscretional and may be used by school districts for virtually any purpose.

School Funding and Appropriation

Since the Unit Count is not finalized until after the school year begins, DOE performs preliminarycalculations in June of each year, and OMB preloads a portion of Division I, II, and III funds forthe beginning of the fiscal year. These funds are not available until the beginning of the new fiscal year. DOE monitors Division I funds and OMB will transfer funding over to meet salary andbenefit needs as necessary. After the November certification of the Unit Count by the Secretary ofEducation, the remaining Division II and Division III funds are transferred to the school districtsby OMB.

If, after the units are certified a student is disqualified through the auditing process from the UnitCount, the units will be recalculated without that student. Another eligible student shall not besubstituted for the disqualified student. A student who has been identified as special educationand is receiving special education services that is disqualified from the Unit Count due toirregularities contained within supporting documentation may be included in the regularenrollment category provided the student meets eligibility requirements. Only a studentdisqualified by the audit process may be reassigned to another unit category. In no event can thisadjustment result in a net increase in units for a district. 23

Out-of-state children whose parent or legal guardian is employed on a full-time basis by anyreorganized school district may attend school in the district where the parent or guardian isemployed during the period of the parent or guardian’s employment upon written approval of thereceiving district and payment of tuition if charged by the district. Such children may not beincluded in the September 30th Unit Count for state funding purposes.

Student dependents of military and civilian Department of Defense (DOD) personnel who residein Dover Air Force Base housing who enroll in a district through the Choice program or in acharter school must be reported by the receiving district/charter school to the Caesar RodneySchool District (CRSD). Federal funds covering educational services for these students would thenbe transferred by the CRSD to the State to cover state costs associated with their education and tothe receiving district to cover local costs.

DOE Special Education Monitoring

The DOE is authorized by Title 14 of the Delaware Code to adopt rules and procedures toadminister and authenticate the count of children with disabilities as outlined in Chapter 17, Title14 of the Delaware Code. The DOE conducts verification processes to ensure districts and

charter schools report students in special education units in a manner consistent with 14 Del. C.§1703 and 14 DE Admin Code Section 928 and 701. The number of special education unitsreported by the districts and charter schools in 2015 will be compared to the number reported in2014. If 5% more or less units in a category are reported between 2014 and 2015, the DOE shall:

23 14 Del. Admin C. §701 (8.0)


11/31


Background 7

Contact the district/charter school and request a written explanation for the increase ordecrease in units reported, and/or;

Conduct a formal audit of the units reported by the district/charter school. The audit mayinclude, but is not limited to, on-site record reviews, as well as classroom observations,

and/or interviews with teachers, administrators, related service providers, and other schoolstaff.

DOE currently conducts on-site compliance monitoring of each district and charter school on afive year rotating cycle. The districts and charter schools monitored by the DOE during the 2015-2016 school year will also be included in a verification process to ensure the proper count ofchildren with disabilities are reported. If DOE receives any information indicating the erroneousreporting of special education units, the DOE may conduct a verification process, and/or refer thematter to the State Auditor and other agencies required by law.

The DOE is authorized by the Delaware Code to request financial reports or other information

deemed necessary from districts and charter schools to ensure the appropriate use of unitsearned.24 Districts and charter schools are required to provide reports and information asrequested by DOE.

The Delaware Code requires school districts and charter schools to count students with disabilitiesin Needs Based Funding Units based on the individual needs of each student. At the completionof the IEP team meeting, the team (which includes parents or guardians) must discuss and reviewthe needs based funding unit as it relates to the adequacy of resources to implement the programand placement outlines in the IEP.25 The review and discussion should occur at least once a year,and may coincide with the IEP team’s annual review of the child’s IEP.26 DOE can reportinformation to the State Auditor of Accounts and take any additional actions required by law.

DOE Staffing

The State Education Associate, Unit Count Coordinator plays an integral role in the Unit Countprocess and is the primary point of contact for all districts and charter schools. The Unit CountCoordinator’s responsibilities are not limited to the Unit Count process, and include the following:

April 1st Charter Enrollment

Estimated Unit Count

May 1st Charter Enrollment & Unit Allotment

September 30th Unit Count

Unit Count Training

Statewide School Choice Coordinator (policies and procedures and applications and formsdevelopment and maintenance)

Non-public Schools’ Coordinator (Policies and procedures)

24 See 14 Del. C. §1703 (9).25 See 14 Del. C. §1703(d)(8).26 34 C.F. R. Section 300, 324


12/31


Background 8

Charter Closures (relocation of active students to their new schools, fulfill records requestand send student cumulative folders to their new school)

Statewide School Profiles Coordinator (August release, October release, January release, April release)

The State Education Associate, School Accounts performs necessary duties to load the funds intoaccounts for the school districts. This role includes:

Allocate and oversee the administration of state school funds generated as part of the UnitCount process, which includes completing the template to preload money into districtaccounts in June.

Converting Division II and III units into dollars after the Unit Count is certified

Making adjustments as necessary based off further review

The Director of Exceptional Children Resources performs duties involving Special Educationincluding:

Statewide monitoring of Special Education

Overseeing the State of Delaware’s compliance with the Individuals with DisabilitiesEducation Act by monitoring various performance indicators.

Early Admission to K indergarten

A child entering kindergarten must be age 5 on or before August 31st of the respective year. TheDOE decided that early admission to kindergarten for gifted students should be determined byprofessionally qualified persons27 and the local district’s assessment of the best interest of thechild.28 All districts and charter schools must be able to demonstrate through documentation thatthese students are “gifted and talented”. Documentation as to how these students were determined

to be “gifted and talented” should be aligned with 14 Del. C. §2702(b) and should be included inthe district/charter school’s Unit Count audit file.

Funding for charter schools is limited to students lawfully enrolled in grades K through 12 as thecharter school may be approved to operate. Charter schools shall not include any Pre-K studentsin their enrollment for Unit Count purposes.

Unit Count Training

Unit Count Training is provided by DOE to all school districts and charter schools every year.During the training, the State Unit Count Coordinator reviews the Unit Count process andhighlights any changes from the previous year. Reference materials and guides are provided on the

DOE website and are available after training for all school districts and charter schools to access.Unit Count Training is highly encouraged but is not mandatory.

27 14 Del. C. §3101(6)28 14 Del. C. §2702(b)


13/31

State of Delaware

Statewide eSchoolPLUS and U nit Count Performance Audit


Procedures and Results

In 2008, DOE converted from a manual Unit Count process to an automated process using theeSchoolPLUS environment. In 2011, DOE implemented IMS Unit Count PLUS in response to

the Needs Based Funding law changes. Unit Count PLUS integrates with eSchoolPLUS andcalculates the units earned by funding needs categories as described in the background of thisreport.

While the implementation of this system reduced the risk of funding calculation errors and movedthe environment from a highly manual to a more automated process, there is still a need to ensurethat units as reported in the system are valid, properly classified, and supported. A portion of thisprocess is, and will continue to be, reliant on key manual processes. The processes must havestructure that supports validity and accuracy of the Unit Count that drives three major categories,Division I, II, and III, of funding.

Our audit concentrated on analyzing the reliability and sufficiency of processes that can result inthe incorrect funding based on ineligible student enrollment. The work is intended to supplementthe audit coverage already obtained through the annual Statewide Comprehensive AnnualFinancial Report and the Statewide Single Audit.

Need For M anagement’s Participation in Key O perational Activities

Innovative Schools

Management’s responsibilities under the Committee of Sponsoring Organizations of the TreadwayCommission (COSO) includes, but is not limited to, establishing, with board oversight, structures,reporting lines, and appropriate authorities and responsibilities in the pursuit of the organizationsobjectives.29

AOA expected personnel from the schools that were trained in Unit Count Procedures to handlecommunication throughout the engagement. However, during the initial correspondence for theaudit, we noticed that Innovative Schools Project Manager and many of her colleagues were themain points of contact for several of the charter schools during the Unit Count. While InnovativeSchools could serve to support management in operational processes, the charter schools shouldnot delegate their responsibilities.

Many of the charter schools use Innovative Schools as their Charter Management Organization(CMO). Innovative Schools30 is a non-profit resource center for Delaware public schools. It servesas a local intermediary for the State of Delaware, and acts as an on-the-ground partner to public

schools located within the State. According to Innovative Schools, they research highly successfulprograms countrywide that align with the State’s initiatives. Innovative Schools works directly withschools to implement these programs efficiently and effectively.

Innovative Schools supports the State’s public schools through programs offered in three divisions:

29 Committee of Sponsoring Organizations of the Treadway Commission (COSO), Internal Control – IntegratedFramework, Principle No. 3.30 http://www.innovativeschools.org/about-us


14/31

State of Delaware



Innovative School Models that embody modern ways of teaching and learning that havebeen replicated successfully in public schools across the country.

Innovative School Staffing to ensure that schools have a reliable source of leaders andteachers trained to lead and inspire modern schooling.

Innovative School Solutions to streamline school administrative functions, allowing moredollars to be directed to the classroom.

Contracting for services does not relieve Management at a charter school from its responsibilitiesunder COSO. If Management delegates its roles and responsibilities to perform key functions,they are directly responsible for the outcome. Further, Management is required to performmonitoring activities that will help evaluate and communicate internal control deficiencies.31

Lack of Entrance Conference Participation

To initiate the audit, AOA scheduled an entrance conference for the districts and a separate one

for the charter schools.

32

The entrance conference, that included arrangement for a teleconferenceoption, was to inform the Superintendents/Charter School Heads and Unit Count personnel of theaudit plan. There was a lack of attendance and involvement from both the district and charterschools with regards to the entrance conference.

AOA would have expected those districts and charter schools who were unable to attend theteleconference to respond requesting an additional meeting or details; however, this did not occur.Lack of entrance conference participation alone does not represent a major finding; however, suchinattentiveness may have contributed to various weaknesses identified throughout the report.

Of the 19 School Districts, Appoquinimink and Colonial School Districts were not representedduring the entrance conference. Fourteen of the 27 charter schools (52%) did not haverepresentation during the entrance conference. Of those 14, three of the schools below permittedfour Innovative Schools representatives to participate on their behalf. The charter schools that didnot participate are as follows:

Academia Antonia Alonso33

Academy of Dover

Charter School of Wilmington

Delaware Academy of Public Safety and Security

Delaware College Preparatory Academy

Delaware Military Academy

Early College High School at DSU30

EastSide Charter School

Family Foundations Academy

Gateway Lab School

Great Oaks Charter School30

31 COSO, Internal Control – Integrated Framework, Monitoring Activities, Principles No. 16. and 17.32 Appendix A details the total population of State of Delaware schools.33 Said to be represented by Innovative Schools during the entrance conference.


15/31

State of Delaware



Odyssey Charter School

Prestige Academy

Thomas Edison Charter School

Failure to Develop and Im plement W ritten Policies and Procedures

DOE, in their Unit Count training, indicated that all districts and charter schools should have a setof policies and procedures specific to the Unit Count process that notates roles andresponsibilities. Hence, on October 5, 2015, we requested policies and procedures from all schooldistricts and charter schools.34 AOA found the following districts and charter schools conductedtheir Unit Count without an individualized Policy and Procedure Manual:

Laurel School District

Academia Antonia Alonso

Delaware Design Lab High School

Early College High School at DSU First State Military Academy

Freire Charter School

Gateway Lab School

Great Oaks Charter School

Odyssey Charter School

The Delaware Met

Thomas Edison Charter School

All districts and charter schools should follow DOE instructions regarding school specific Unit

Count Manuals. These manuals should consider all aspects of COSO. Further, AOA hasdiscussed with DOE including this as a requirement in the DOE Unit Count Manual in addition tothe communication already provided in DOE’s training. Many of the issues identified throughoutthe report could be resolved in part by developing individualized Policy and Procedure Manuals.

School Un it Count Personnel Ineffectiveness

As is done each year, Unit Count Training was offered by DOE on July 21, 201535, to all districtsand charter schools. All School Unit Count Coordinators, in addition to anyone working in aposition that supports the Unit Count process, are encouraged to attend this training. In addition, AOA was able to observe the significant amount of support and coaching provided to the schools

regarding the Unit Count process, which can be complex and tedious.

AOA performed procedures to verify there was representation by all of the districts and charterschools. Throughout the engagement, AOA determined that many of the Unit Count duties arenot necessarily handled by the Unit Count Coordinators. Some duties are delegated to individuals who did not attend the training and are unfamiliar with the Unit Count process. It was notuncommon for those directly charged with Unit Count responsibilities to lack any knowledge

34 Appendix A35 DOE offers Unit Count training annually in July.


16/31

State of Delaware



about the existence of key reports, much less how to use those reports. The problem is furthercompounded in schools that lack Unit Count Manuals mentioned earlier in this report.

Assigning Unit Count responsibilities to individuals without adequate training resulted in AOA’srequest for FSRs being met with submissions that were blank, incomplete, and for the wrong

timeframe. As a result, AOA had to make additional requests in order to receive correctdocumentation due to the following issues represented by “X” in “Table 3” below.

Table 3: Documentation Issues

District/ Charter Schools

Blank

Document

Missing

Pages

Wrong

Dates

Missing

Students

Unfamiliar

With

Reports

EastSide Charter School X X36

Family Foundations Academy

X X36

Kuumba Academy X

Prestige Academy X X X X

In addition to the previous recommendation on individual Unit Count Manuals, AOArecommends that districts and charter schools work to ensure all parties involved in the UnitCount process are aware of their respective responsibilities to promote effective internal controlsand adequate continuity and cross training of Unit Count staff. Failure to follow through with theserecommendations will result in continued operating inefficiencies, at the schools and DOE, andincrease risk of errors and non-compliance.

Enrollment and Unit Count Errors

Enrollment Review: Disallowances

In order to evaluate the reliability and sufficiency of the various processes that contribute to theannual Unit Count, AOA sampled 450 students statewide from 9 districts (27 schools) and 18charter schools37 and compared the FSR Attendance reports to the Student Lists (Names Behindthe Numbers) and conducted onsite visits to substantiate enrollment. According to DOE’s UnitCount Regulations Manual and Unit Count Training materials, enrollment is defined as “…unlessthere is reason to believe that a pupil’s attendance during the ten-day period (last 10 days of schoolin September) is fleeting or momentary, his/her presence in school for all or part of the 10 days

effectively “enrolls” him/her as of the last day of September for the school year.” AOA used thiscriterion when evaluating attendance and found the criterion to lack a definition for “fleeting andmomentary”. Since the criterion was very subjective, we worked closely with the DOE Unit Count

36 AOA received numerous phone calls from the secretary handling Unit Count with questions as to what the forms are(she did not know what the FSR was), how to access certain documents, and the contact information for DOE UnitCount Coordinator.37 For a full list of schools sampled, see Appendix B.


17/31

State of Delaware



Coordinator to evaluate attendance documentation.38 When onsite, AOA found that the schoolshad no clear understanding of what constitutes “fleeting and momentary “and even voiced thisconcern to AOA.

Through our review, AOA identified 9 students that were counted in the Unit Count that should

be disallowed. Of the 9 disallowances identified, 4 students met the criterion of “fleeting andmomentary”. Additionally, AOA found 4 students who were included in the Unit Count whonever attended school for the current school year. Lastly, AOA identified one student who wasenrolled in a distance learning program that does not meet the DOE Unit Count RegulationsManual’s (Section 6.2) requirements for inclusion.

“Table 4” below provides specifics related to the 9 disallowances identified by AOA.

Table 4: Unit Count Disallowances

School of Disallowances Reason for Disallowance(s)

Academy of Dover 1 Fleeting & MomentaryCaesar Rodney High School 1 Fleeting & Momentary

Cape Henlopen High School 1 Fleeting & Momentary

Christiana High School 1 Distance LearningException


1 No Show

Delaware Design Lab HighSchool

1 No Show

First State Military Academy 1 Fleeting & Momentary

Prestige Academy 2 No Shows

Again, these 9 disallowances were derived from a sample; therefore, there could be additional“Fleeting & Momentary” and “No Show” students not identified during our audit. AOArecommends DOE take a firm position on repayment of funds relative to these disallowedstudents for FY 2016.

Enrollment Review: Lack of Attendance Verification

Delaware Academy of Public Safety and Security and Prestige Academy did not have a process to validate that teachers had entered attendance into eSchoolPLUS. AOA was unable to determine ifthe lack of internal controls surrounding attendance during the Unit Count resulted in any errors atDelaware Academy of Public Safety and Security. Prestige Academy did disclose to AOA thatthere were known attendance issues that have since been rectified; however, AOA is unsure of any

impact this may have had on the Unit Count.

Enrollment Review: Missing FSRs

As described in the Background section, each building administrator is required to generate theeSchoolPLUS FSR attendance report. This report is signed and dated by the buildingadministrators and placed in the school’s audit file as the school’s verification of student attendance

38 Documentation included gradebooks, work samples, doctor excuses, parent notes, transfer documentation,homebound agreements, and outside agency agreements.


18/31

State of Delaware



during the last 10 school days of September for student’s counted in the school’s September 30th Unit Count. While onsite, AOA reviewed for this requirement and found that 42 of the 45schools visited maintained this report in their audit file. Three of the 45 schools visited, whichincluded Delaware College Preparatory Academy, Family Foundations Academy, and GatewayLab, were unable to provide AOA evidence that this step of the Unit Count was completed. AOA

found this extremely alarming, as this report is used to substantiate the entire Unit Count process.

Enrollment Review: Missing Documentation

As part of our attendance review, AOA reviewed documentation for attendance validation,excused absences (doctor excuses and parent notes), gradebooks, work samples, transferdocumentation, homebound agreements, and outside agency agreements. Through our review wedetermined the following:

Gateway Lab and the Delaware Met failed to retain copies of notes for excused absences.

The Delaware Met failed to retain transfer documentation for transfer students.

Enrollment Review: Reporting Issues

During AOA’s review of attendance, we determined that the districts and charter schools are using various views in eSchoolPLUS to produce attendance reports necessary for the Unit Count. It wasdiscovered that there are various views available for running the FSR attendance reports ineSchoolPLUS. Each view displays a variety of attendance information i.e. tardy –excused/unexcused, absence – excused/unexcused, Home Bound Instruction, Outside Agency,etc. AOA obtained the FSRs to corroborate the numbers submitted during the Unit Count.Upon reviewing the FSRs for each school, we noted several inconsistencies with the view selection.Some views were more descriptive than others. It was determined that no statewide eSchoolPLUS Attendance View standard exists for running the FSR attendance report which can result ininaccurate data. As an example, Dunbar Elementary School submitted to DOE a FSR that onlydisplayed excused absences. Since the FSR is reviewed by administrators and used to substantiate

the students included in the Unit Count, it is critical that the most comprehensive view is used todemonstrate attendance. AOA would recommend that DOE specify which “view” the FSR isprinted in when submitting for the September 30th Unit Count.

During our review of the FSRs, AOA also noted reporting issues at Cape Henlopen High Schooland Delaware Academy of Public Safety and Security. Cape Henlopen High School failed to set a value for the max field in the Criteria Details page in eSchoolPLUS, resulting in students beingmarked as absent for the whole day who were in fact only tardy. Delaware Academy of PublicSafety and Security incorrectly coded two students as absent in eSchoolPLUS instead of to anOutside Agency. Although these reporting errors had no impact on the end result of the UnitCount, there could potentially be other issues outside of our audit sample that could negatively

impact the Unit Count.

Enrollment Review: Comprehensive Enrollment File

During the attendance review, AOA also requested each school’s comprehensive enrollment file,often referred to as the “Unit Count Audit Binder”, as required per DE Admin. Code 701.39

39 DE Admin. Code 701 states, “Each school shall maintain September enrollment records in a manner which willallow for efficient enrollment audits by the Department of Education and the State Auditor of Accounts. At the end ofSeptember, each school shall assemble a comprehensive enrollment file that contains all necessary support materialsto substantiate the enrollments reported.”


19/31

State of Delaware



Throughout this process we found the level of organization of the enrollment files to be on variousends of the spectrum. Some schools, such as those schools from the Red Clay and ChristinaSchool Districts, were extremely organized, making the audit process very efficient. Other schoolshad an enrollment file that lacked certain items that would constitute a comprehensive enrollmentfile. These schools were able to piece together the requested documentation while AOA waited

onsite to review. Delaware Academy of Public Safety and Security claimed to maintain an auditfile but was unable to provide AOA with one after multiple requests. The schools listed below were able to provide the requested documentation; however, the documentation was not kept in a“comprehensive enrollment file”.


George Read Middle School

Milford High School

Providence Creek Academy

Sussex Tech High School

William Penn High School Wilmington Manor Elementary School

A majority of the schools visited by AOA expressed concern about the vague requirements and were requesting feedback from AOA on what should be included in their enrollment file. AOAbelieves that inclusion of a “Unit Count Enrollment File Checklist” in the DOE RegulationsManual would help to alleviate this issue.

Unsupported Early Adm ission to Kindergarten

In the beginning stages of the audit, DOE expressed concerns of the abuse of the Early Admissionto Kindergarten process. Prior to 2009, DOE was responsible for evaluating “gifted and talented”

children, and according to DOE, in those years there were less than 10 Early Admissions toKindergarten students across the entire State of Delaware. Charter schools are not allowed statefunding for Pre-K, and AOA believes that some schools are using this process as a way tocircumvent the system to receive state funding for children that normally would not be eligible tobe counted in the September 30th Unit Count, and to also alleviate families of the responsibility ofseeking daycare for underage children.

AOA completed a statewide review of Early Admission to Kindergarten and determined that noneof the school districts throughout the State had an Early Admissions to Kindergarten. However,four of the charter schools had a total of 28 Early Admission students as demonstrated in “Table5” below.

Table 5: Statewide Early Admissions to Kindergarten

School Number of Students

EastSide Charter School 11

Family Foundations Academy 12

Kuumba Academy 3

Delaware College Preparatory Academy 2


20/31

State of Delaware



No standard assessment or scoring rubric currently exists for Early Admissions to Kindergarten inthe State of Delaware. DOE allows each school district and charter school to develop their ownassessment and requires only that assessments follow the guidelines of 14 Del. C. §3101(6) withsupporting documents identified as Early Admission to Kindergarten. Specifically, the guidelinesshould follow:

14 Del. C. §3101(6) (6) "Gifted or talented child" means a child in the chronological age group 4 through the endof the school year in which the child attains the age of 21 or until receipt of a regular highschool diploma, whichever occurs first, who by virtue of certain outstanding abilities iscapable of a high performance in an identified field. Such an individual, identified byprofessionally qualified persons, may require differentiated educational programs or servicesbeyond those normally provided by the regular school program in order to realize thatindividual's full contribution to self and society. A child capable of high performance asherein defined includes one with demonstrated achievement and/or potential ability in anyof the following areas, singularly or in combination:

a. General intellectual ability;

b. Specific academic aptitude;

c. Creative or productive thinking;

d. Leadership ability;

e. Visual and performing arts ability;

f. Psychomotor ability.

Upon closer examination, AOA learned about various problems with the early admissions process

at these charter schools and all 28 early admissions should be disqualified.

Two of the charter schools (EastSide and Family Foundations) had no standardizedassessment or scoring rubric.

EastSide and Family Foundations did not consistently perform the same evaluation for allEarly Admissions.

Kuumba was unable to provide any supporting documentation for the three students theyincluded in the Unit Count and stated that any students admitted early were done so inerror.

Evaluation forms for EastSide and Family Foundations were labelled “Pre-K” even thoughcharter schools are not permitted to include Pre-K students in their Unit Count

enrollment.

EastSide altered assessments to allow Early Admissions, see “Figure 1" below.

All evaluation forms prepared by Delaware College Preparatory Academy did not supportEarly Admissions, as there were various mathematical errors and the instructions on theevaluation forms were not followed.

Family Foundations Academy publicized the incorrect final enrollment date of October30th on their website instead of the August 31st deadline. See “Figure 2” below.


21/31

State of Delaware



Figure 1: Early Admission to Kindergarten Documentation – EastSide Charter

School


22/31

State of Delaware



Figure 2: Family Foundations Academy Website

Despite all the time and effort on DOE’s part to support the schools through training andindividual instructions on how to ensure proper Unit Counts, the lack of attention to adhering tofunding guidelines for these four charter schools is disconcerting and demonstrates a disregard fortheir responsibilities to ensure fiscal accountability. AOA recommends DOE take a firm positionon repayment of funds relative to these early admission students for FY 2016. Further, AOA hasoffered to review the prior two fiscal years in the area of Early Enrollment and report on theoutcome.

Division I Funding

Monitoring of Complex Funding Requirements During planning of the engagement, DOE requested that AOA include procedures to verify theuse of Division I funding. AOA requested documentation that DOE represented woulddemonstrate the districts’ and charter schools’ final application of Division I funds; thisdocumentation was generally referred to as “staffing plans” by DOE. As the audit progressed,DOE explained that, although not required of the districts and charter schools, the “staffing plan”should demonstrate that the units filled are consistent with the units earned per the Needs BasedPosition Entitlement Report.40

During our review, we found broad variations in “staffing plan” submissions. Some schools weremore detailed, while others lacked information to identify whose salary was being charged tospecific Division I categories. It was very apparent that the reports did not consistently provideproof of a school’s process to ensure appropriate application of Division I funding, nor did DOEhave a process to monitor this process throughout the funding period.

40 A report that is prepared by DOE detailing the earned units by position for each district and charter school.


23/31

State of Delaware



DOE insisted that AOA should perform procedures to reconcile the use of these funds because oftheir desire to learn if districts overcharge the State for Division I funding.41 Since performing areconciliation is a management function, AOA did not perform the reconciliation procedure. Had AOA spent the time on reconciling, it would have created an audit impairment.42 DOE’s requestto have AOA identify overcharges through reconciliation procedures does not address the lack of

monitoring that is needed to ensure funds are used appropriately and in accordance withregulations. This is a much broader issue than simply identifying overcharges.

Under Principle 10 Section 10.01 of the United States Government Accountability Office’sStandards for Internal Control, management should design control activities to achieve objectivesand respond to risk. Management (management for the State includes both DOE and the districtsand charter schools) should have control processes in place to mitigate the risks that Division Ifunding is not properly allocated in accordance with the Delaware Code.43

AOA believes that DOE can play a significant role in establishing a requirement for areconciliation process with a standardized format for reporting the results of the reconciliation.

Additionally, we recommend that DOE monitor this process throughout the period to ensureappropriate funding and use of staffing is occurring.

DOE Monitoring

DOE Special Education Monitoring

As stated in the background section of this report, the DOE is authorized by Title 14 of theDelaware Code to adopt rules and procedures to administer and authenticate the count of children with disabilities as outlined in Chapter 17, Title 14 of the Delaware Code. The DOE conducts verification processes to ensure districts and charter schools report students in special educationunits in a manner consistent with 14 Del. C. §1703 and 14 DE Admin Code Section 928 and 701.

The number of special education units reported by the districts and charter schools in 2015 will becompared to the number reported in 2014. If 5% more or less units in a category are reportedbetween 2014 and 2015, the DOE shall:

Contact the district/charter school and request a written explanation for the increase ordecrease in units reported, and/or;

Conduct a formal audit of the units reported by the district/charter school. The audit mayinclude, but is not limited to, on-site record reviews, as well as classroom observations,and/or interviews with teachers, administrators, related service providers, and other schoolstaff.

DOE currently conducts on-site compliance monitoring of each district and charter school on afive year rotating cycle. The districts and charter schools monitored by the DOE during the 2015-2016 school year will also be included in a verification process to ensure the proper count of

41 Charter schools are given a lump sum by DOE that is calculated based on the number of units earned and thecurrent salaries of staff; therefore, charter schools are unable to overcharge the State.42 Government Auditing Standards, Section 3.50d. states that preparing an audited entity’s accounting records willalways impair an auditor’s independence with respect to an audited entity.43 See Appendix C for the position allocation requirements of the Delaware Code.


24/31

State of Delaware



children with disabilities are reported. If DOE receives any information indicating the erroneousreporting of special education units, the DOE may conduct a verification process, and/or refer thematter to the Office of Auditor of Accounts and other agencies required by law.

The DOE is authorized by the Delaware Code to request financial reports or other information

deemed necessary from districts and charter schools to ensure the appropriate use of unitsearned.44 Districts and charter schools are required to provide reports and information asrequested by DOE.

The Delaware Code requires school districts and charter schools to count students with disabilitiesin Needs Based Funding units based on the individual needs of each student. At the completionof the IEP team meeting, the team (which includes parents or guardians) must discuss and reviewthe Needs Based Funding unit as it relates to the adequacy of resources to implement the programand placement outlined in the IEP.45 The review and discussion should occur at least once a year,and may coincide with the IEP team’s annual review of the child’s IEP.46 DOE can reportinformation to the State Auditor of Accounts and take any additional actions required by law.

Statewide monitoring of Special Education, as detailed above, is performed by the Director ofExceptional Children Resources. The Director, along with her team, also verifies the complianceof the Individuals with Disabilities Education Act (IDEA). Each team member is assigned tomonitor various annual performance indicators.

Based on our review of processes used by DOE, we believe there is adequate monitoring in placeto catch widespread abuse of special education units.

DOE Regular Education Monitoring

While DOE demonstrated a strong commitment to dedicating resources to Special Education

monitoring as described in the previous section, we found that the same level of monitoring wasnot performed at DOE over Regular Education.

Most of the work involved with monitoring the Unit Count lies solely with the DOE Unit CountCoordinator. The Unit Count Coordinator not only has to conduct the annual Unit Counttraining, and monitor and assist with certifying the September 30 th Unit Count, but also serves asthe main point of contact for any issues/discrepancies post-Unit Count.

Given the extensive work associated with the Regular Education Unit Count, it would be beneficialand more efficient to have a DOE Unit Count team to assist the DOE Unit Count Coordinator inmonitoring the regular education units. This team could assist in monitoring the staffing plans

detailed in the Division I Funding Section of this report. While the Unit Count Coordinator ismaking every effort to perform monitoring as time permits, there are insufficient resources tocommit to a formal process with regular monitoring for Regular Education.

44 See 14 Del. C. §1703 (9).45 See 14 Del. C. §1702(d)(8).46 34 C.F. R. Section 300, 324


25/31

State of Delaware



Unit Count PLUS IT Controls

Overall the internal controls surrounding Unit Count PLUS were aligned with the InformationSystems Controls documented in FISCAM. However, we observed three areas for DOE’sconsideration:

The Unit Count PLUS Developer has no backup in Unit Count PLUS; he is the onlyone with access to the system, and in case of an emergency there is no one in place toseamlessly take over his role.

There is no workflow approval in FogBugz;47 when changes need to be made, no one isreviewing and approving these changes. These changes should be reviewed for propersegregation of duties.

There is no formal documentation regarding the use of Unit Count PLUS for the end

user. Aside from generic information, there is no User Guide to help instruct someoneon the use and development of the application, which could assist in continuity in theevent of employee turnover.

47 FogBugz is an integrated web-based project management system featuring bug/issue tracking developed by Fog CreekSoftware.


26/31

State of Delaware


Appendix A 22

Appendix A

48 Table based on September 2015 data.

Total Population of Delaware Schools

48

Districts (19)

Number of

Schools in District

Appoquinimink 16

Brandywine 16

Caesar Rodney 12

Cape Henlopen 9

Capital 13

Christina 31

Colonial 15

Delmar 4

Indian River 17

Lake Forest 7

Laurel 4

Milford 7

NCCVT 5

Polytech 1Red Clay 27

Seaford 8

Smyrna 8

Sussex Tech 1

Woodbridge 4

Total Number of District Schools 205

Charter Schools (27) Number of

Schools in Charter

Academia Antonia Alonso 1

Academy of Dover 1

Campus Community 1

Charter School of Wilmington 1DE Academy of Public Safety 1

DE College Prep Academy 1

DE Design-Lab High School 1

DE Military Academy 1

Early College HS at DSU 1

EastSide Charter 1

Family Foundations 1

First State Military Academy 1

First State Montessori Academy 1

Freire Charter School 1

Gateway Lab School 1

Great Oaks Charter School 1

Kuumba Academy 1

Las Americas Aspira Academy 1

MOT Charter 1

Newark Charter 1

Odyssey Charter 1

Positive Outcomes 1


27/31

State of Delaware


Appendix A 23

Prestige Academy 1

Providence Creek 1

Sussex Academy 1

The Delaware Met 1

Thomas Edison 1

Total Charter Schools 27

Statewide School Count 232


28/31

State of Delaware


Appendix B 24

Appendix BDistrict and Charter Schools Visited by AOA (45)

School Name District/Charter

Concord High School Brandywine

Mt. Pleasant Elementary Brandywine

Springer Middle School BrandywineCaesar Rodney High School Caesar Rodney

Simpson Elementary Caesar Rodney

Brittingham Elementary Cape Henlopen

Cape Henlopen High School Cape Henlopen

Bayard Middle School Christina

Christiana High School Christina

Gallaher Elementary School Christina

Kirk Middle School Christina

Newark High School Christina

West Park Place Elementary Christina

Penn High Colonial

Read Middle School Colonial

Wilmington Manor Elementary Colonial

Georgetown Elementary Indian River

Millsboro Middle School Indian River

Sussex Central High School Indian River

Dunbar Elementary Laurel

Milford High School Milford

A I DuPont High School Red Clay

Heritage Elementary Red Clay

Highlands Elementary Red Clay

Linden Hill Elementary Red Clay

Marbrook Elementary Red ClaySussex Tech High School Sussex Tech

Academia Antonia Alonso Academia Antonia Alonso

Academy of Dover Academy of Dover

DE Academy of Public Safety DE Academy of Public Safety

DE College Preparatory Academy DE College Preparatory Academy

DE Design-Lab High School DE Design-Lab High School

DE Military Academy DE Military Academy

Early College HS at DSU Early College HS at DSU

EastSide Charter EastSide Charter

Family Foundations Family Foundations

First State Military Academy First State Military Academy

Freire Charter School Freire Charter SchoolGateway Lab School Gateway Lab School

Great Oaks Charter School Great Oaks Charter School

Kuumba Academy Kuumba Academy

Newark Charter Newark Charter

Prestige Academy Prestige Academy

Providence Creek Providence Creek

The Delaware MET The Delaware MET


29/31

State of Delaware


Appendix C 25

Appendix CDelaware Code Requirements for Use of Earned Units

Each unit below is converted into state funds needed for a specific position’s salary applied to the

category for that school year unless an exemption is elected by the district or school by followingthe guidelines below.

Once the district or charter school has decided which individual employee to assign to the unit, thestate portion of salaries paid to employees is based on the State Salary Schedule outlined in 14Del.C. ch. 13. The amount from the schedule is determined based on that specific employee’sposition, years of experience, level of education, professional degrees, licenses and certificationsheld, number of months employed (10, 11, or 12), and types of students served (regular, basis,complex, intensive, etc.).

Hence, the need to identify and follow the application of a specific individual throughout the

funding cycle is critical to ensure that the units filled are consistent with the units earned. Withoutsuch ongoing record keeping and monitoring, an employee could be charged to the unit but not beused in the appropriate capacity.

We have extracted the specific funding requirements from the Delaware Code and have detailedthem below to help elaborate on the complex funding requirements.

Preschool students

Earn 1 unit per 12.8 students

Funds must be used to support services for the students but are not limited to employingteachers only.

The funds may be used to hire preschool special education teachers, paraprofessionals,and speech and language pathologists, or other related services personnel as determined atthe local level.

The units may also be used to secure contractual services.

K-3 students


At least 20% of teachers at the K-3 building level must be certified in the area of specialeducation.

98% of the Division I units must be allocated to the schools that generated them

The school board can waive the 98% rule by a vote held at a public meeting

4-12 Regular Education

Earn 1 unit per 20 students



4-12 Basic Special Education (Basic)



30/31

State of Delaware


Appendix C 26



All units generated by special education students are to be used for professional staff tosupport students with disabilities, to include special education teachers, schoolpsychologists, speech/language pathologists, reading specialists, educational diagnosticians,counselors, class aides and social workers.

Districts are authorized to use up to 5% of the units for para-professionals or to cash themin for related services.

Pre K-12 Intensive Special Education (Intensive)

Earn 1 unit per 6 students

100% of the units must support the students that generate them.

Used for special education teachers, school psychologists, speech/language pathologists,reading specialists, educational diagnosticians, counselors, class aides and social workers.

Units may also be used to cash-in for other related services.

Pre K-12 Complex Special Education (Complex)


100% of the units must support the students that generate them.

Used for special education teachers, school psychologists, speech/language pathologists,reading specialists, educational diagnosticians, counselors, class aides and social workers.

Units may also be used to cash-in for other related services.

Academic excellence units (K-12)

Each district earns 1 unit for each 250 students, grades K through 12

Used for reading, communications skills, mathematics, science, social studies, elementaryand secondary counseling, elementary and secondary foreign languages, elementary and

secondary performing arts, elementary physical education, elementary music, elementaryart, library services, career education in grades 7 and 8, paraprofessionals, programs forgifted and talented pupils, career placement counselors, programs for limited Englishproficient pupils, programs for children at risk as defined by the Department of Education,programs to promote improved school climate and discipline, intervention specialists,programs to provide additional time, and an athletic trainer.

30% of academic excellence units can be cashed-in at a rate of $35,000/unit

Related services units (K-12)

1 unit for each 57 units of the K-3, 4-12 (regular education) and basic units.

1 unit for each 5.5 units of the pre-K-12 intensive units.

1 unit for each 3.0 units of the pre-K-12 complex units.

Used for special services such as speech therapy, occupational therapy, physical therapy,early identification and assessment of disabilities, special counseling services,developmental, corrective or supportive services

12 month students (K-12)

Programs for children with severe mental disabilities, autism, traumatic brain injury,deaf/blindness, or orthopedic disabilities


31/31

State of Delaware


State share calculated at 100% of complex units and 30% of intensive units earned

Programs limited to 1,426 hours for students with autism and 1,282 hours for all otherstudents

Occupational-Vocational Units (7-12)

1 unit earned per 30 students

Only available to New Castle County Vo-Tech, Kent County Vo-Tech, and Sussex County Vo-Tech School Districts.

Students counted in occupational-vocational units shall be deducted from the regular unitusing the formula: Occupational-vocational units x .5deductible units

Delaware Code Position Entitlements

Position Allotment

Classroom Teacher 1 per each Division 1 unit

Superintendent 1 per school district (not charters)

Assistant Superintendent 1 per 300 Division 1 units (max of 2)

Director 1 for the first 200 Division 1 units plus 1 for each additional100 units (max of 6)

Administrative Assistant 1 per school district or charter school

11 Month Supervisor 1 for each 150 Division 1 units

Related Services Specialists Unit (K-3, 4-12 Regular, and Basic 4-12) (10 months)

1 for each 57 units

Related Services Specialists Unit(Intensive) (11 months)

1 for each 5.5 units

Related Services Specialists Unit(Complex) (12 months)

1 for each 3 units

Visiting Teacher 1 for each 250 Division 1 units

Nurse 1 for each 40 Division 1 units

Academic Excellence Unit 1 for each 250 pupils (up to 30% may be cashed in)Secretary 1 for every 10 units for the first 100 units; 1 for every 12 units

thereafter

Driver Education Teacher 1 for every 125 tenth grade students

Building and Grounds Supervisor 1 per school district (requires a minimum of 95 custodial units;12 custodial units = 1 custodial position)

Food Services Supervisor 1 if less than 500 units with 4 or more buildings with schoollunch programs; 1 if having 500 units or more

Transportation Supervisor 1 for every 7000 or more transported students (based on totalenrollment)

Reading Cadre Position 1 per school district (not charters)

FY16 Unit Count Performance Audit Final Report (Signed)

Documents

Transcript of FY16 Unit Count Performance Audit Final Report (Signed)