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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
7
8
10
11
12
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14
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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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