RCSD Audit Student Placement

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OFFICE O F ! A U D I T O R G E N E R A L Student Placement Audit Report January 12,2010

Transcript of RCSD Audit Student Placement

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OFFICE OF! AUDITOR GENERAL

Student Placement

Audit Report

January 12,2010

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Student Placement

Table of Contents

Report Section Pages

Executive Summary 2

Summary of Recommendations 3

Observations, Recommendations and Action Plans

Comprehensive Protocols and Procedures

Compliance with Board Policy

Organizational Synergies

Registration - Process Timing

Registration - Universal Pre-Kindergarten

Registration - Roles and Responsibilities

Registration - Documentation

Registration - Data Entry

Registration - Monitoring

Seat Capacity - Process and Automation

Seat Capacity - Dropped Students

Interdepartmental Protocols

Information and Communication

Information Access and Storage

System Support

Lottery ProcessTransfers - Process

Transfers - Processing

Transfers - Alternate Programs

Transfers - Special Ed

Transfers - Communication

Monitoring and Reporting

Staffing Concerns

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Student Placement

Executive Summary

OBJECTIVE

To evaluate the operating control environment surrounding the student placement and registration process.

BACKGROUND

Student Equity & Placement are responsible for the registration and placement of approximately 5,000 students annually. The

Department recruits for Pre-K, Kindergarten, MAP, general admissions, 7th grade admissions, International Baccalaureate & Edison

Schools and facilitates the students that opt out of District schools. The Department assists with CSE and Annual Review changes in

programs and temporary placement of Special Ed students. Placement and registration services are currently supported at St. Paul,

Goodman, and Hart Street locations.

SCOPE

This audit will evaluate the effectiveness of the internal controls for Student Equity & Placement operations. We will evaluate

compliance with State regulations and District policies and procedures. We will determine if adequate controls have been

implemented to ensure timely and accurate registration and placement within the District for all students.

CONCLUSION

Student Placement is a critical function that significantly impacts every school building. Additional clarity through documented

operating protocols and procedures for the entire Student Equity and Placement process will improve operations. Documentedprotocols for enrollment, communications, documentation standards, lottery procedures, and regulatory considerations should be

established. Once protocols are created, enforcement and support for complying with procedures will improve school interactions and

simplify the student placement process. Standard timelines for enrollment, implementation of a registration checklist to ensure files

are complete, dropped student monitoring and data entry standards are all areas where the control environment should be improved.

Student Placement management and staff work diligently to ensure that students are placed in a fair and equitable manner. Additional

organizational support will facilitate this department in meeting their desired objectives.

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Student Placement

Summary of Recommendations

1 Develop comprehensive written protocols and procedures for the entire Student Equity and Placement Department.

Include protocols regarding enrollment, communications, documentation standards, lotteryprocedures, and regulatory

considerations. Communicate the protocols to relevant internal and external stakeholders and enforce compliance with

the protocols.

2 (1 of2) Consider reevaluating the current Managed Choice policy criteria and determine if the economic climate and school

performance data warrant changes to Board policy. (Board Policy Committee)

2 (20f 2) Evaluate the existing Board policies surrounding Managed Choice and placement and ensure that District operating

practices are in alignment with policy. Ifmanagement believes that the Board policy is not aligned with currentmanagement direction, request the Board to make changes to the existing policy.

Create aprotocol outlining criteriafor closing the enrollment of a school to new students. Createprotocols regarding

transfers for secondary and elementary including criteria in how transfers are measured and enforced when they are

accepted or denied.

3 Partner with Parent Engagement, School Based Groups, Transportation, Food Service and Special Education to

capitalize on departmental synergies relating toparent contact and communication opportunities. Evaluate ways to

minimize the number of requests for information from parents and build those relationships tofurther increase

communication with parents.

4 Develop a recurring annual timeline for student registration. Set clear deadlines for dependent activities to ensure aconsistent schedule can be maintained tofacilitate the registration process.

5 Develop a roll up selection process for the preschool students. Consider early identification of kindergarten school at

the time of preschool placement. This could reduce the kindergarten registration in excess of 1000 students.

Implement a preferred selection process for early identification of the desired school.

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Student Placement

Summary of Recommendations

6 Define role definitions between SE&P and other functional units. Designate specific roles and responsibilitiesfor the

SE&P related activities. Evaluate feasibility and functional reporting alignment of current roles and responsibilities to

ensure desired results can be achieved.

7 Establish a standard format and checklist to ensure student registration files are consistently obtained and pertinent

documents retained. Periodically perform a management review to ensure the process is working as intended.

Evaluate the Chancery system access and determine why records can be deleted outside of SE&P and make

appropriate changes to maintain control of student system records.

8 Establish data entry standards for entering address information in Chancery SMS. Specifically, develop standardabbreviations and naming conventions that will be utilized for common words in street names (i.e. Doctor, Saint, Alpha

streets, numeric streets, etc.).

Establish aplan to cleanse the current data in order to make the appropriate corrections in Chancery SMS.

9 Establish and communicate formal procedures for processing pending files. Include timelines for outstanding

requests and create monitoring procedures to ensure the procedures are adhered to. Identify how pending files should

be monitored and include monitoring frequency and escalation procedures.

10 Create aprocess to standardize the calculation, automation and modifications of District seating capacity and

projections.

11 Create aprocess that identifies dropped students that includes information that is seat specific, timely and accurate.

Consider using statistical trend analysis to determine the percent of dropped students at a location.

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Student Placement

Summary of Recommendations

12 Define and communicate agreed upon interdepartmental procedures for the student placements: equitable procedures

for placement across schools, transfer of students to schools, pre-established conditions for non-acceptance, and

criteriafor closing enrollment for grades. Document agreed upon procedures for extenuating circumstances such as:

Special Education, Safety, Availability, Dropped Students & Special Agreements.

13 Enhance the SE&P websites to include useful information regarding the services provided by Student Equity &

Placement. Also improve the content of selection books to include testing and demographic data.

14 Review staff access and ensure that access is in alignment with job responsibilities and make appropriate changes as

needed. Discontinue the use of shared password access and store operating files on the network in a defined location.

15 Document, prioritize, and resolve any system related barriers that prohibit complete use of the automation in the SE&P

processes. Assign SE&P operating responsibility for a system liaison that will ensure system functionality positively

impacts all cross functional areas. Monitor system performance of automated functions and report progress againstthe planned improvements.

16 Develop clear comprehensive processes and standards toplace all students through SE&P activities. Document lottery

standards and evaluate opportunities for additional automation to eliminate the various independent manual

processes. Test Chancery prior to the lottery to ensure system logic is aligned with desired outcomes.

17 Develop, communicate and implement standard information, timelines and communications required for transfers.Require that these standards are maintained for each zone. Ensure that documentation and communications are

consistently performed and methods are established to consolidate and monitor transfers on a district-wide basis.

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Student Placement

Summary of Recommendations.

18 Develop transfer standards, including documentation, timelines, and acceptance procedures with escalation,

processing priorities, monitoring and reporting practices to support accurate and timely dispositions of transfers.

Monitoring should require that unmet requests are tracked until resolved and standard reasons for denials should be

established.

19 Create, communicate and implement standard protocols that specifY the documentation required for alternate

placements, timelines, authorizations, and the duration for placement.

20 Reevaluate the current process for receiving CSE change letters and determine if it isfeasible to only receive changesin services. Establish aplan topromptly update Special Education students when services are changed.

21 Establish formal communication protocols that include senior management acceptance and communicate changes to

procedures affecting schools with appropriate support.

22 Implement tracking, monitoring and reporting against standard metrics in SE&P functions including registration,

lottery, transfers, waitlists, and seat projections. Utilize the results to improve performance in SE&P.

23 Consider creating apolicy that disallows related parties within the same department or in a direct reporting

relationship to minimize potential disruption to organizational objectives.

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Student Placement

Observations, Recommendations and Action Plans

Comprehensive Protocols and Procedures

There is a lack of comprehensive protocols and procedures for the entire Student Equity and Placement (SE&P) Department.

Although some protocols and procedures are documented, they are not complete. Operating procedures were inconsistently performed

due to a general lack of standard procedures and protocols. Desk procedures, which communicate how to perform daily

responsibilities in compliance with protocols, are also not complete. The following key protocols were not formalized:

• Methods to communicate with the public regarding enrollment and registrations

• Communication protocols to schools and other departments regarding SE&P procedures

• Requirements for original birth or baptismal documentation for enrollment

• Application and enrollment procedures for schools that place students outside of SE&P

• Schools that are exempt from SE&P automated lottery procedures

• Placement for students with special education needs and alternative schools

• Key regulatory considerations for placing students; such as transfers for SURR and SINI schools.

Formal protocols for SE&P should be detailed, comprehensive and current to ensure consistent application and compliance. Written

and communicated protocols would enhance the consistency of recorded data, consistency in the handling of transactions, and aid in

holding employees accountable for the work performed.

Develop comprehensive written protocols and procedures for the entire Student Equity and Placement Department. Include

protocols regarding enrollment, communications, documentation standards, lottery procedures, and regulatory considerations.

Communicate the protocols to relevant internal and external stakeholders and enforce compliance with the protocols.

Management Responses: We reviewed the existing Student Equity and Placement (SE&P) Manual to determine the requiredimprovements. The updated manual will include the protocols and procedures that will be implemented in the upcoming 2010-2011

school year. We will communicate with stakeholders by July 2010 regarding the updated protocols. We will start monitoring internal

practices and external compliance starting in September 2010.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student.

& Placement. 2010

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Student Placement

Observations, Recommendations and Action Plans

Compliance with Board Policy

Board Policy requires that committees are formalized in each of the three zones to monitor school performance and equity on an

annual basis. The intent of this practice was to increase communication of school offerings and competitiveness. The District was also

directed to establish centers in each of the three zones; however, a recent consolidation has moved all three centers to one location. It

is management's intent to use satellite offices to support the various zones. While the Board policy addresses elementary transfers, it

does not offer guidance for secondary schools. Specifically, guidance should be established regarding reasons for denial of transfers,

and responsibilities for closing schools to students. Itshould be noted that even though the policy does not articulate specific transfer

prerequisites, SE&P has adopted practices to deny transfers based on GPA, failing performance and attendance. However, such

criteria is not consistently measured nor is it consistently enforced.

Consider reevaluating the current Managed Choice policy criteria and determine if the economic climate and school performance

data warrant changes to Board policy.

Management Responses: SE&P, with the assistance of the Office of Accountability, will evaluate the Manage Choice policy data to

determine the benefits of the existing program. The results will be presented to the Policy Committee with any recommendations for

change.

Responsibility: Gladys Pedraza-Burgos, Chief of Youth Development and Family Services; Jeannette Silvers, Chief, Office of

Accountability.

Due Date: June 2010

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Student Placement

Observations, Recommendations and Action Plans

Evaluate the existing Board policies surrounding Managed Choice and placement and ensure that District operating practices are

in alignment with policy. Ifmanagement believes that the Board policy is not aligned with current management direction, requestthe Board to make changes to the existing policy. Create aprotocol outlining criteria for closing the enrollment of a school to new

students. Createprotocols regarding transfers for secondary and elementary including criteria in how transfers are measured and

enforced when they are accepted or denied.

Management Responses: SE&P will review the existing Board policies surrounding Managed Choice and Placement to ensure that

the operating practices are in alignment with policy. We are evaluating data to determine what changes are warranted regarding

Managed Choice and Placement. Outcomes will be presented to the Board Policy Committee for changes. We will create a protocol

outlining criteria for closing the enrollment of a school to new students. We will also create protocols regarding transfers for

elementary and secondary schools. Additional clarity will be provided regarding how transfers are measured and enforced along with

acceptance and denial tracking.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equity

and Placement.

Due Date: June 20I0

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Student Placement

Observations, Recommendations and Action Plans

Organizational Synergies

Student Equity & Placement functions independently from operating departments and schools. Placement is the first point of contact

for families entering the Rochester City Schools. It is an ideal opportunity to inform families about the District and any expectations

that exist for new students. Communication of district programs and operating units should be strategically aligned to ensure critical

information is presented and facilitation of information gathering occurs. There are natural synergies amongst the departments to

work together more effectively. Due to the difficulty in obtaining parent participation for documentation and attendance for meetings,

addressing all key points of contact and documentation upon entrance is ideal.

Partner with Parent Engagement, School Based Groups, Transportation, Food Service and Special Education to capitalize on

departmental synergies relating toparent contact and communication opportunities. Evaluate ways to minimize the number ofrequests for information from parents and build those relationships tofurther increase communication with parents.

Management Responses: SE&P has started meeting to establish criteria to develop and maintain departmental synergies relating to

parent contact and communication opportunities. We have started meeting with Parent Engagement, School Based Groups,

Transportation, Food Service, Special Education and Teaching and Learning. Ultimately, we will work to streamline the number of

separate parent requests for information.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equity

and Placement.

Due Date: June 2010 and Ongoing

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Student Placement

Observations, Recommendations and Action Plans

Registration - Process Timing

The registration process lacks formalized protocols to facilitate a consistent, effective process. The registration process fluctuatesfrom year to year based on the impact of school openings, closings and redesign. These changes necessitate increased outreach and

communication to ensure that the public is aware of the required timing for registration. A lack of consistency in these processes from

year to year can negatively impact school planning and enrollment for a new school year. Administration should establish a

comprehensive schedule with timelines to determine when critical decisions must be made to drive the registration process for the new

school year.

Develop a recurring annual timeline for student registration. Set clear deadlines for dependent activities to ensure a consistent

schedule can be maintained tofacilitate the registration process.

Management Responses: SE&P has benchmarked registration processes against similar districts, and agree to establishing a

congruent timeline for the new registrations and associated lotteries at district points, such as entering PreK, entering Kindergarten and

moving into high school. Protocols and procedures will be documented for this process, including required timelines for meeting the

schedule.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: August 1,2010

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Student Placement

Observations, Recommendations and Action Plans

Registration - Universal Pre-Kindergarten

Students enrolled in the Universal Pre-Kindergarten (UPK) program complete the registration process and submit required

documentation to Placement. When the student is ready to attend Kindergarten within one to two years, they are required to repeat the

process and Placement obtains the same registration documents again. This practice requires duplication of administrative paper work

for SE&P, as well as the parent. The rationale for registering the students isbecause the UPK school that was attended may not be in

the proper zone. Recognizing that there could be moves that result in zone changes, it would be appropriate to obtain a system report

to identify which students attend schools outside of their zone and request duplicate registration on an exception basis. At a minimum,

Placement procedures should maintain the required documentation to streamline the process for parents. Processing duplicate

paperwork is a very inefficient process that is likely frustrating for parents.

Develop a roll up selection process for the preschool students. Consider early identification of kindergarten school at the time ofpreschool placement. This could reduce the kindergarten registration traffic in excess of1000 students. Implement a preferred

selection process for early identification of the desired school.

Management Responses: Universal Pre-Kindergarten (UPK) funding requires the district to offer open enrollment at all school

locations. We will evaluate the feasibility and interest for parents to select a Pre-Kindergarten school that their child would be eligible

to attend for K-6. If feasible, we will offer a preferred roll-up and eliminate Kindergarten enrollment for students. The PreK

programs are mostly half-day and have no transportation; therefore, only parents who can transport children to and from school would

be able to participate.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: June 2010

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Student Placement

Observations, Recommendations and Action Plans

Registration - Roles and Responsibilities

There is a lack of definition and clarification surrounding the responsibilities for the individual roles to support accurate

registration/enrollment. SE&P has different individuals responsible for various functions in the enrollment process, such as selection

support specialists and Guidance Counselors. There is a lack of clarity surrounding which activities are performed by which role and

how the roles should function together. Generally, the individuals performed roles somewhat independent of other individuals in the

process. Additionally, the functional alignment of the responsibilities does not ensure that student information is accurately and

promptly entered in the Student Information System. There is a lack of specificity in daily operating deliverables, how they should be

performed, what should be performed and who should monitor activities for compliance, which is needed to ensure the department

objectives are being met. Specifically, responsibility should be assigned for: guidance counseling, parent engagement, process

monitoring and follow up.

Define role definitions between SE&P and other functional units. Designate specific roles and responsibilities for the SE&P

related activities. Evaluate feasibility and functional reporting alignment of current roles and responsibilities to ensure desired

results can be achieved.

Management Responses: An annual review of Placement's Manual has been performed. Protocols and procedures will be

established. The updated SE&P Manual will include clarification of roles between SE&P and other functional units. Additional clarity

will also be provided for internal roles in the SE&P Manual. Functional reporting will be an outcome from the established role clarity.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: August 1,2010

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Student Placement

Observations, Recommendations and Action Plans

Registration - Documentation

There was no consistent documentation method for registration fi les and they were not signed or dated by the School Selection

Specialist (SSS). Inconsistent documentation was obtained and retained in student enrollment folders completed in the registration

process. Since there were no notations or preparer signatures required on the student file to identify who processed the file, should an

error occur or a deviation from the communicated practices, it would be difficult to determine why it occurred. The differences in the

files varied based on the person that processed the folder. Although a checklist existed, it was used inconsistently. Registration file

exceptions identified during our testing included the following:

• Registration not signed by parent,

• Birth certificate not presented at time of registration,

• Processing date not indicated on registration,

• Registration sheets not signed by SSS,

• Clerks did not always indicate the SSS they were enrolling student for, and

• Emergency contact forms were not scanned and sent to the school.

• Chancery SMS enrollment records are being changed (added and deleted) by individuals outside of SE&P.

There should be a standard format for preparing student registrat ion files. Sign-Offs should occur to indicate that personnel are

responsible for the contents of the folder. There should be a periodic management review to validate the process is working as

intended. Not signing off on registration folders and checklists causes a lack of ownership and accountability. This can lead to

inaccurate data, incomplete information and inability to provide the schools consistent and timely information.

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Student Placement

Observations, Recommendations and Action Plans

Establish a standard format and checklist to ensure student registration files are consistently obtained and pertinent documents

retained. Periodically perform a management review to ensure the process is working as intended. Evaluate the Chancery systemaccess and determine why records can he changed (added and deleted) outside ofSE&P and make appropriate changes to

maintain control of student system records.

Management Responses: Updated checklists for student registration files have been established and implemented. Pertinent

documents such as: Registration Form, Emergency Notification Form, Birth Certificate, Immunization Record, copy of Enrollment

Screen from Chancery, Report Card and Transcript are now being scanned to ensure that important documents are retained. To

ensure that management review is being documented, the Registrar's initials (SSS or Administrator) is required to authorize

enrollment in Chancery. SE&P will be meeting with the Office of Accountability to evaluate Chancery system access for student

registration files in order to make the appropriate changes to maintain control of student records.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equityand Placement, Jeannette Silvers, Chief, Office of Accountability

Due Date: August 1, 2010

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Student Placement

Observations, Recommendations and Action Plans

Registration - Data Entry

There were various inconsistencies noted in how registration data was entered into Chancery SMS. Student address information such

as street names were inconsistently abbreviated and spelled based on the individual performing the data entry. For instance, Doctor is

entered as Doctor, Dr, or Doc. Additional standard entr ies to consider are: way, saint , numeric streets, and how to enter apartment

numbers. In addition, some addresses had no zip code or the zip code was incorrect. Standards should be established and utilized

regarding how to enter long or commonly abbreviated streets. Errors and variations in data entry make it diff icult to analyze student

information from the Chancery system. It also makes it difficult to prepare District mailing l ists. Placement should establish entry

standards and perform verification procedures to ensure data in Chancery SMS is accurate.

Establish data entry standards for entering address information in Chancery SMS. Specifically, develop standard abbreviations

and naming conventions that will be utilizedfor common words in street names (i.e. Doctor, Saint, Alpha streets, numeric streets,

etc.). Establish aplan to cleanse the current data in order to make the appropriate corrections in Chancery SMS.

Management Responses: Biweekly meetings with the Chancery Team, which includes SE&P and IM&T staff, have been set up to

establish data entry standards in Chancery SMS. Additionally, these meetings will address the creation of a plan to cleanse and make

the appropriate corrections to data in Chancery SMS. The data cleansing process will be ongoing; however, current data entry will be

improved with monitoring.

Responsibility: Gladys Pedraza-Burgos, Chief , Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: August 1, 2010

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Student Placement

Observations, Recommendations and Action Plans

Registration - Monitoring

Standardized procedures do not exist to ensure timely monitoring and processing of pending registrations/enrollment. Our review

noted a lack of monitoring procedures to ensure that pending enrollments are monitored and completed. The process performed by

individuals had varying degrees of completeness, consistency, and effectiveness. This was particularly evident within the drawer.

There were random notes on folders, incomplete checklists, and attached post-it notes from the preparer. The folders lacked

consistency due to the lack of a defined process. In addition, there was a need for more consistent analysis and review of pending

information to process enrollments. Appropriate timelines should be established for reviewing files, communicating with the

requestor, and monitoring the pending files. With these changes, SE&P customers will receive improved service.

Establish and communicate formal procedures for processing pending files. Include timelines for outstanding requests and create

monitoring procedures to ensure the procedures are adhered to. Identify how pending files should be monitored and includemonitoring frequency and escalation procedures.

Management Responses: A process has been established and communicated for the regular review and monitoring of Student

Registration Files. Timelines will be formalized for processing files once all parent approvals are received. These procedures will be

included in the SE&PManual, including escalation procedures when delays are due to internal matters.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: August 2010

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Student Placement

Observations, Recommendations andAction Plans

Seat Capacity - Process and Automation

There is no defined process to obtain annual seat capacity or document subsequent changes to seat capacity and projections.Additionally, SE&P uses a labor intensive manual seat capacity spreadsheet to make placement decisions. Seat projections are

generally estimated based on the number of estimated 7th grade seats required. Seat capacity is established as the number of available

seats at each school. This past year , seat capacity came from multiple sources with final designations provided by School Principals.

While elementary is grade specific, secondary is building specific. This practice makes i t diff icult to assign secondary students since

visibility is limited at a grade and class level. The capacity or changes in capacity are not consistently loaded into Chancery SMS. As

a result, a class could appear to have availability when no seats are available. When management directs adjustments to capacity, the

changes are not tracked nor are the changes formally approved. When adjustments are not maintained within reporting, there is no

audit trail or seat capacity change history. SE&P should evaluate system reports to automate the capacity process, then implement a

standard automated process for identifying and modifying annual seat capacity. The capacities should be detailed enough to enter into

Chancery by grade and special classes.

Create a process to standardize the calculation, automation and modifications of District seating capacity and projections.

Management Responses: Through partnering with the Chancery Team, a process to create the standardization of calculations,

automation and modification of District seating capacity and projections will be addressed for elementary and secondary schools. To

date, elementary seating capacity is being updated on a daily basis.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equity

and Placement.

Due Date: July 1, 2010

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Student Placement

Observations, Recommendations and Action Plans

Seat Capacity - Dropped Students

There is no centralized, effective process to identify dropped students, thus resulting in unidentified open seats. Schools directlyupdate Chancery for students that are dropped which may not be timely. SE&P identifies those students from a report that does not

differentiate special education from general education. The current process is not specific, nor timely enough to assure accurate seat

availability by program. SE&P is responsible for all enrollments, transfers and moves to alternative programs, but does not originate

the drop transactions for students. The timeliness of schools reporting dropped students directly impacts open seats; specifically the

identification of special education seats and the maximization and utilization of teachers. The identification of available seats due to

dropped students needs to be seat specific, timely and accurate. Unreported seat vacancies interfere with timely and accurate student

placements, and negatively impacts teacher and resource utilization.

Create a process that identifies dropped students that includes information that is seat specific, timely and accurate. Consider

using statistical trend analysis to determine the percent of dropped students at a location.

Management Responses: The Drop Process is being developed in partnership with the Legal Department and Attendance. The new

process will be included in the Superintendent's Regulations and the SE&P Process Manual.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement, Chuck Johnson, Chief Legal Counsel.

Due Date: August 1,2010

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Student Placement

Observations, Recommendations and Action Plans

Interdepartmental Protocols

There is no agreed upon interdepartmental process to assign or reject individual student placements, nor close a school to additional

placements. SE&P has been working with Principals and Chiefs on a case-by-case basis to place students. Principals, with the

support of their respective Chief, have the ability to close a grade level, school or refuse a placement. The formal reasons for the

closings and student refusals are not consistently provided to SE&P. There are no standards in place to support the closing of a grade

level or defined criteria used to refuse a placement. There are also no defined escalation procedures when a placement is rejected.

The Director of SE&P does not have the . to enforce of a student for education or . education.

Define and communicate agreed upon interdepartmental procedures for the student placements: equitable procedures for

placement across schools, transfer of students to schools, pre-established conditions for non-acceptance, and criteriafor closing

enrollment for grades. Document agreed upon procedures for extenuating circumstances such as: Special Education, Safety,

Availability, Dropped students & Special Agreements.

Management Responses: Interdepartmental procedures will be established to support the process. We will include documentation

regarding the circumstances that warrant deviation from the established process or priority handling. These circumstances will require

documentation and approval for the exception. In order to change to a prescribed, equitable process, SEP under the direction of the

Chief of Youth and Family Services will propose a process to the Chief which would include criteria for closing secondary schools

and grades. The proposal would specifically not include an option for principals to decline a placement or to provide a less-than-full

schedule for an entering student. The Chief of Youth and Family Services will then work with Senior Management (Zone Chiefs) toobtain agreement to the new processes.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement Due Date: August 1,2010

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Student Placement

Observations, Recommendations and Action Plans

Information and Communication

The RCSD website has been under development. During this development, it should be modified to provide parents with enhanced,

useful information concerning Student Equity & Placement. Previously, catalog hyperlinks did not always provide information. The

website lacked information regarding their services and information relevant for students with special education needs, transfer

guidelines, and school of choice processes. Considering that Student Placement is the first point contact for the District,

comprehensive guidance would be helpful to prospective families. Additionally, improved content should be provided to parents in

hard copy and online to communicate school offerings. Specifically, items such as test scores and demographic information could be

useful. This information could assist parents in making informed decisions.

Enhance the SE&P websites to include useful information regarding the services provided by Student Equity&Placement. Also

improve the content of selection books to include testing and demographic data.

Management Responses: The SE&P website currently offers Parent Tips and Kindergarten Recruitment booklets. SE&P will

evaluate the demographic and testing data available and include this information on the site. We will also improve the site to increase

ease of use for parents.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: June 2010

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Student Placement

Observations, Recommendations and Action Plans

Information Access and Storage

User passwords are being shared in order to perform regular job functions. The passwords were shared to look up student

information. Individual passwords exist to identify the individual responsible for system transactions. Sharing passwords makes it

difficult to enforce accountability. If system access has not been provided, it is possible that the responsibility could grant a user with

control over a process from beginning to end. We noted that in SE&P, access levels are not aligned with individual responsibilities.

We also noted that staff were performing critical work functions and maintaining critical files on their desktop hard drives. This

practice results in data not being backed up on the network. A theft occurred during our audit and two desktops were stolen. This

resulted in lost files, and subsequently, OAG provided copies of files obtained during the audit to assist management in data recovery

efforts.

Review staff access and ensure that access is in alignment withjob responsibilities and make appropriate changes as needed.

Discontinue the use of shared password access and store operating files on the network in a defined location.

Management Responses: Passwords are no longer being shared. Staff access has been reviewed and adjusted to match job

responsibilities. Operating files are now stored on network.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equity

and Placement.

Due Date: Completed.

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Student Placement

Observations, Recommendations and Action Plans

System Support

SE&P functions lacked desk procedures to detail how to use the system to perform standardized daily activities. Chancery is only

partially used for student lotteries and errors occur due to a lack of adequate planning and testing. In the last lottery, Chancery letters

to parents were incorrect and detailed documentation did not exist for running the lotteries. The reconciliation process for post lottery

results is not formalized nor is the associated processing of resulting waitlists. Additionally, seat availability reports and projections

are manually prepared and tracked, when the system is capable of online real time reporting. Additional system resources and support

should be utilized to fully utilize the Chancery system to yield the desired result.

Document, prioritize, and resolve any system related barriers that prohibit complete use of the automation in the SE&P processes.

Assign SE&P operating responsibility for a system liaison that will ensure system functionality positively impacts all cross

functional areas. Monitor system performance of automated functions and report progress against the planned improvements.

Management Responses: SE&P is now meeting biweekly with the Chancery Team in order to work through a prioritized list of

needs, to include the documentation, prioritization and resolution of system related barriers. A SE&P department liaison has been

designated. The SE&P Department Administration is working with Chancery daily to monitor the system performance of automated

functions and to report progress against the planned improvements.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: June 2010 and Ongoing

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Student Placement

Observations, Recommendations and Action Plans

Lottery Process

A comprehensive process, standards and expectations regarding the lottery process is not adequately defined. Current specifications

for the lottery, as provided by SE&P do not include system changes that are required for SE&P to function effectively. Timing of

events, system and data dependencies, inter-departmental communications, verification procedures, treatment of placements

performed outside of Chancery and treatment of unassigned student practices are not formalized. We were advised that the most

recent lottery produced incorrect notifications to some parents and over enrolled some kindergarten classes. These problems occurred

because the automated lottery process was established without adequate testing. Additionally, a reconciliation of student requests to

placements was not retained. SE&P should document, provide lottery standards, and ensure Chancery logic is aligned to yield proper

outcomes. Chancery should be configured to address recurring placement activities in an automated manner. Without automation,

SE&P manually handles all anomalies including: over enrollments, unassigned students, and waitlists resulting from students not

receiving their first or second choice.

Develop clear comprehensive processes and standards toplace all students through SE&P activities. Document lottery standards

and evaluate opportunities for additional automation to eliminate the various independent manual processes. Test Chancery prior

to the lottery to ensure system logic is aligned with desired outcomes.

Management Responses: Processes are being formalized for the existing Lottery. We will review the feasibility of including all

populations in the Lottery process. We will be in a position to consider additional automation after the 2010-2011 lotteries are

completed. We will ensure that testing is comprehensive for the 2010-2011 lotteries.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, StudentEquity and Placement.

Due Date: May 2010

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Student Placement

Observations, Recommendations and Action Plans

Transfers - Process

Current transfer practices within the SE&P occur by zones. The procedures followed are not standardized, although a similar format

is used to capture the information, different information is obtained for transfers. As a result, the transfer data can not be combined or

managed in a comprehensive format. SE&P could benefit from standard documentation, information coding, consistent definitions,

and how information is recorded. We also noted that the information retained to support transfer decisions was inconsistent. For

example, grade point average and attendance information was inconsistently obtained in making transfer decisions. There is also

subjectivity in the amount of data and time period for data to support transfer decisions. While some forms existed, forms utilized

were not consistently completed, signed and dated. In addition, the data obtained did not consistently align with electronic

spreadsheets prepared. The "District Representative Confirmation" signature on the elementary forms is almost never signed. It is

also unclear if letters to parents occur as required, since proof of communication was not always evident from the documentation. We

noted inconsistency of communicat ion to parents regarding the acceptance or denial of transfers. Overall, there is substantial

opportunity for improvement and defined protocols to handle student transfers and parent communication to establish a consistentexpectation.

Develop, communicate and implement standard information, timelines and communications required/or transfers. Require that

these standards are maintained for each zone. Ensure that documentation and communications are consistently performed and

methods are established to consolidate and monitor transfers on a district-wide basis.

Management Responses: We have established standards and protocols for the transfer process. These standards include information

required, timelines and communication protocols for the transfer process. We have commenced the documentation process to

facilitate compliance with the process. We will also reinforce these standards across all zones, since one Placement Office supports al lzones.

Responsibilitv: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement Due Date: August 1,2010

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Student Placement

Observations, Recommendations and Action Plans

Transfers - Processing

SE&P indicated that many School Principals freely approve student transfers out of their school without a similar willingness toaccept students. At times the student transfer process is performed with negotiations amongst School Principals. There were a

relatively high number of transfer requests without dispositions and an inability to monitor them against established timelines and

criteria. In addition, significant subjectivity was used in the interpretation of supporting documentation which led to inconsistencies in

how requests were completed. There were also requests that were on a waitlist for an extended period that were not granted priority

over voluntary transfers. At a minimum, transfer criteria should be consistently identified and similarly interpreted in reaching

resolution. Timelines should be established to identify how long a transfer can remain outstanding. Priorities should be documented

and complied with regarding the order in which transfer requests are processed. Escalation procedures should exist to ensure that

transfers are performed equitably amongst schools. Lastly, monitoring of the operating standards and management reporting will

ensure that operations are functioning as planned.

Develop transfer standards, including documentation, timelines, and acceptance procedures with escalation, processing priorities,

monitoring and reporting practices to support accurate and timely dispositions of transfers. Monitoring should require that unmet

requests are tracked until resolved and standard reasons for denials should be established.

Management Responses: SE&P and Youth Development & Family Services will collaborate with the School Zone Chiefs to

establish transfer standards and monitoring practices. These protocols will be communicated across all schools and periodically

reinforced at Zone meetings. We will request support from the Chiefs of Schools to assist with noncompliance.

Responsibility: Gladys Pedraza-Burgos, Chief of Youth Development and Family Services; School Zone Chiefs (Ray Giamartino,Susan Kaufmann and Cheryl Holloway), Deputy Superintendent of Teaching and Learning.

Due Date: August 20I0

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Student Placement

Observations, Recommendations and Action Plans

Transfers - Alternate Programs

SE&P performs the administrative enrollment update to Chancery for the Young Mothers and Interim Health Academy, I'm Ready,and the Young Adults evening program. All requests are administered and originate outside of SE&P from other departments.

Documentation supporting the SE&P enrollment is not consistently obtained or retained by SE&P. Without this documentation, it is

difficult to align responsibility for the authorization for the placement and the duration of the placement. Procedures defining what

information is required from other departments to enroll students timely are not formalized. It is not apparent that such

communications have occurred with other departments to establish expectations. This lack of standards has resulted in requests for

SE&P to backdate enrollment data to update the student record. Requirements should be clear regarding the documentation required

to support enrollment, timelines for documentation, authorization, and the duration for placement. Since Chancery is the student

management system, key information regarding the placement should be maintained in Chancery.

Create, communicate and implement standard protocols that specify the documentation required for alternate placements,

timelines, authorizations, and the duration for placement.

Management Responses: A process for alternate placements is in development. Once the process is documented, we will

communicate with the appropriate stakeholders and reinforce implementation of the established protocols.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equity

and Placement.

Due Date: August 1, 2010

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Student Placement

Observations, Recommendations and Action Plans

Transfers - Special Ed

There are inadequate processes in place to address changes to special education student enrollment. The Committee on Special

Education (CSE) sends SE&P the yearly evaluations performed on Special Education students. The letters indicate whether or not

there is a change in the students required services. The letters are sent to SE&P individually for all students without regard to the need

for a change. There is no assurance that SE&P receives all of the letters, nor is there an easy way to identify when changes are

initiated on the form. SE&P staff communicated that parents have called and inquired about changes in their child's status and SE&P

was unable to locate a copy of the form. Letters are not received in a summarized format and SE&P does not log receipt of these

letters. In some cases, the required services in the letters are time sensitive. A process must be established to ensure that CSE letters

that require changes are easily identifiable and provided to SE&P in a timely manner. SE&P should consider requesting only the

letters with to reduce the administrative burden of filteri hundreds of documents for the ones with changes. _

Reevaluate the current process for receiving CSE change letters and determine if it isfeasible to only receive changes in services.

Establish a plan topromptly update Special Education students when services are changed.

Management Responses: We will reevaluate the current process for receiving CSE change letters to determine if it is possible to

reduce the amount of paperwork received by only getting CSE change letters when services change. We will also ensure that prompt

timelines are adhered to when student changes occur.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director , Student Equity

and Placement.

Due Date: August 20 I0

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Student Placement

Observations, Recommendations and Action Plans

Transfers - Communication

A formal protocol does not exist to communicate process changes to schools. Placement related procedural changes were made andcommunicated to schools through email. The process change was sent regarding the transfer process to all Secondary Principals by

the Assistant Director of SE&P. While the intent to communicate the change was reasonable, communications regarding changes to

interdepartmental processes should be discussed, reviewed and communicated with Senior Management approval to ensure

compliance. Informal communication methods for changes may not be formerly adopted nor embraced. Since acknowledgement and

acceptance was not required, a lack of compliance with procedures can occur that could have otherwise been avoided.

Establish formal communication protocols that include Senior Management acceptance and communicate changes toprocedures

affecting schools with appropriate support.

Management Responses: The Chief of Youth Development & Family Services and the School Zone Chiefs will discuss

communication protocols for changes in school procedures. The process will be formalized in writing and communicated to all

schools to ensure that protocols are understood.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student Equity

and Placement.

Due Date: August 2010

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Student Placement

Observations, Recommendations and Action Plans

Monitoring and Reporting

There is a general lack of metrics, tracking, monitoring and reporting performed in SE&P. Data and performance appears to becompiled on an ad hoc basis without any consistency. During our review, Counselor activities were starting to be measured. Since

metrics are not formalized, there is inconsistent performance since goals are not clear and outcomes are not measured. Registration

queues, wait times, and follow-up duration should be measured and monitored. Lottery metrics regarding problems, students

processed, choices provided, and wait lists fulfilled are neither reported nor trended. Transfers by zone, across zones, filled, unfilled,

time outstanding, and reasons by month and YTD, are also not reported or trended. Seat projections and availability do not show

adjustments to physical space capacity, decision capacity, or student required limitations for Integrated or Special Ed seats. Data is

collected in various formats, but greater benefit could be achieved via goals, monitoring and reporting.

Implement tracking, monitoring and reporting against standard metrics in SE&P functions including registration, lottery,

transfers, waitlists, and seat projections. Utilize the results to improve performance in SE&P.

Management Responses: A monthly report that compared standard metrics in SE& P functions to performance will be provided to

the Chief of Youth Development and Family Services. The First monthly report was provided in early February for the month of

January 2010. Initial metrics have been proposed and implemented to communicate the operating performance. SE&P will work with

the School Zone Chiefs in order to determine what information is required and reported on a quarterly basis.

Responsibility: Gladys Pedraza-Burgos, Chief, Youth Development and Family Services; Joseph Capezzuto, Director, Student

Equity and Placement.

Due Date: June 2010

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Student Placement

Observations, Recommendations and Action Plans

Staffing Concerns

There is no policy to disallow related parties from working within the same functional unit. When related personnel work in the samedepartment, there is increased risk of factors that can negatively impact the department's ability to meet objectives. When multiple

family members work in the same department, common time off for family related matters can occur, family issues that exist outside

of the workplace can become work challenges, and a greater chance of collusion can occur. During our audit we noted a mother and

daughter in the same office area, as well as ex-spouses within SE&P. To the extent possible management should minimize these types

of occurrences. Although our audit did not identify any specific issues relating to inappropriate activities, this practice can cause

undue pressure in an organization with limited staff.

Consider creating a policy that disallows related parties within the same department or in a direct reporting relationship to

minimize potential disruption to organizational objectives.

Management Responses: The Chief of Human Capital Initiatives agrees with this recommendation. HCI will work with Legal to

develop a District regulation. Such a change would be subject to collective bargaining agreements.

Responsibility: Michele Hancock, Chief of Human Capital Initiatives.

Due Date: September 30,2010

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