California Department of Education Needs to Report Reliable and Valid Data on Title I Schools Identified for Improvement.

Published by the Department of Education, Office of Inspector General on 2002-02-15.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                     UNITED STAT ES'D1WARTMENT OF EDtJCNnON

                                                                                                        FEB 1·5 20D2

 TO:                                   SusaJ'1 B. Neuman 

                                       Ass{shim S~c;rJ;tary 

                                                   , . '. Ele'''''''''''~''''''                                                Education 

:S; If B..mC:r:                       FINAL AUD IT:'RJ:~:P()R'''
                                      Ca~ift}~lfi(( Depqi'tmefs(.cfEtliI.cathm l'lv'eetls to iff.port 'Reliable(wd Viilid Data
                                      on' tftle. I ,Sclipols :ldemi/i.e{iJp.rlmpr.owHlfem .
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(916) 930:-2399,

Pleas.e refet lo~heabovecontrol nllluber InaU corrcspon(\t::nce relmillg to this rer>ort,

cC', 	                  IpscphJohllsOo, DirOOtof,:Cori)pf:!1Satt:)1,'l!dtltmlOn:P'rogratlts.OESE
                        DeLores ~rarncr;Audi tLl..tlson Offi{;t'I.Or3SE                                                                                      .

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                       t1i'1rrw ST Anos rwp ARTMIi:-IT OF fc DUCA1'ION

                                                   FEB ! 5 2002                             eootrol Number
                                                                                            ED_O lGi AWe!}{!!)! 9

[)elaine Eootin
S"" $ "1'''';"10""'''' of Publ ic I""","han
C,liforni.    Dq>ID""'"' of E<l U<. tlOll
n l C"I';[oIM all
Soc"mcnlo, C.liforni. 958 14

ThIS t';., 1A udit Ilopon , entit led Caiifornf" iktx>n",,,,, ofEdllmlfon Neds Report Rclfable'Q
0",J V~liJ [)",,, "" Ti,l. I !i<hoolJ Iden,ifiedI'" Impn.,.",,",",, pr="ts the ,osul" fOTooe
scJ>IDCOt of our , ,,<lit of til<: C.Mom" Dcpartm¢fl( 0[ 10'1\..;;,"...., (CDE). n .. P""J'O'« o [ tbe ,ud,t
" to Je"""",", whether ClJE',          0"''''8'"'''''''
                                                 control, cmum th.. I'CTfOmllIDC< d... ror
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idClllif)illjl T illo I school' for                 ",liat>le. <.Ii<l, .,OJ ""'ely. Thi. rep<>t1 cov... o ur
,"Y;oW ofClJE'" procedure, ">cd to prepare its ",hool yeO! 1')9\)..2000 o;pOrt '" !he
U.S Dq'"rt"" n[ or [,d",""o " (U)) Qn tile "","1>or ~fT;'lc I oct>ooJ, ideoll fJ,d fOf LmprovemenL
We expanded tbe score of our       'w"   [0 school Y<'" 19%-1 997 lhrouw> 1998 -19')<j ((I '0.11)<0
cn£" repot'led data, We found          ,b.,
                                         cor did ,>01 Kpor1 r<liabk .00 valid G'" '0 ED,

                                              AU DIT RES ULTS

C [) ~ ~",j a ,),,,em in place to ,do"ufy ",1<1 oo'ily local edoc.,ion.1 agenco", (LEA,] of ,.;;10001,
identifi ed for ,mp",'"men', 00' i, rop<)fl<:J school n"",b<n ,o!:O 'hOI "-,,~ . igo> ifica"'ly low,""
II,," """" ,d,,,,,r,ed from thi. ')'Stem.

ED', Off,ce of Elcm<"wy        .,,<1
                                 Sow,,"",), ",Iuo.(ioo (QE~~) requ ire< S..", ano""lly "'pon '0
'he numocr ofT;,lo I ""hoo l. i<leo,i!l ed for 'mpro"omen!, ' for school ye'r> 1999-1000 . ,><1
2000-2001, 0 5S~ i"Wucted S, ..", lO reporr toc d"a on the" C<MsoJ"I",d Slate Perfono!a!lC<

, In Coliform" Titk I ,,'1>0<>1, ;J"",;f,<:<,( fa, 'n'pM '<"'''"'        Of" <.1 1.,1 Pm~ram 1011"'0'-<01<"'

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Control Number: ED-OIG/A09-B0019                                                               Page 2 of 7

Report.2 On Table C-1 of the performance report, States provide the number of Title I schools
identified for improvement by targeted assistance schools and schoolwide programs. To identify
the Title I schools for improvement, CDE uses its Program Improvement Database, which tracks
whether Title I schools do or do not make adequate yearly progress.

For the last four years, CDE reported school numbers that only represented from 14 to 60 percent
of the number of schools identified for improvement in the Program Improvement Database, as
shown in the following table.

                    Number of Title I Schools Identified for School or LEA Improvement
                                                                       School Years
                                                    1996-1997     1997-1998 1998-1999         1999-2000
    Reported to OESE
        Targeted assistance schools (TAS)                139           350            65           451
        Schoolwide programs (SWP)                        191           137           145           314
      Total                                              330           487           210           765
    Identified from CDE’s Program
    Improvement Database
      Totala                                             782         1,298         1,510         1,281
    Proportion of Total Schools Reported to
                                                    42 percent    38 percent    14 percent    60 percent
    Total School Identified from Database
     Total includes newly identified schools and previously identified schools that continued to be in
    improvement in the reported school year. The Program Improvement Database does not distinguish
    between TAS and SWP.

Our review of CDE’s Consolidated State Performance Report for school year 1999-2000 found
that CDE did not have sufficient management controls to ensure that the reported data were
reliable and valid. In particular, CDE did not fully meet ED’s data quality standards3 related to
accurate description, reporting, and editing because—

 States are required to submit a Consolidated State Performance Report to report performance
data for State formula grant programs authorized by the Elementary and Secondary Education
Act (ESEA), including the Title I, Part A – Improving Basic Programs Operated by Local
Educational Agencies Program.
  In March 2000, ED published Data Quality Standards to assist its internal managers as they
collect, analyze, and report data about Federal programs, including Title I, Part A. We used
these standards to evaluate CDE’s management controls over data quality. The OIG has
suggested that ED distribute the standards to States to help ensure that they provide reliable,
valid, and timely performance data to ED for such programs as Title I (OIG Information
Memorandum – State and Local No. 01-01, dated August 3, 2001, titled State-Reported Data
Used in Measuring Performance of Education Programs). While ED has not distributed the
standards to States, the Data Quality Standards are accessible on ED’s Website. We describe
the standards in more detail in this section and the BACKGROUND section of this report.
Control Number: ED-OIG/A09-B0019                                                         Page 3 of 7

   ƒ   CDE did not report schools that were previously identified for improvement. CDE
       limited the number of schools reported in Table C-1 of the Consolidated State
       Performance Report to the schools that were newly identified for improvement for the
       school year covered by the report. This occurred because CDE’s staff responsible for
       identifying schools for improvement and staff responsible for preparing the Federal
       report both misinterpreted the reporting forms and instructions. States should report the
       total number of schools that are in improvement status for the school year covered by the
       report, which would include both previously and newly identified schools. ED’s Data
       Quality Standards, Standard Two (Accurate Description) states that definitions and
       counts should be correct and mentions data providers using different definitions as an
       example of failing this standard.

   ƒ   CDE did not document its data collection process or retain supporting documentation.
       CDE did not have written procedures for reporting the number of schools identified for
       improvement in Table C-1. Also, CDE could not provide documentation of its
       development of the reported data. According to Standard Six (Reporting) of ED’s Data
       Quality Standards, full disclosure can be met, in part, by documenting data collection
       processes. In addition, Federal regulations require that programmatic documentation be
       retained for three years. Pursuant to 34 CFR § 80.42(b) (2000), “records must be retained
       for three years from the starting date specified in paragraph (c) of this section.”
       Paragraph (c) states “the retention period for the records of each funding period starts on
       the day the grantee or subgrantee submits to the awarding agency its single or last
       expenditure report for that period.” Without written procedures or record retention, there
       is little assurance that CDE provides OESE with comparable and reliable data from year
       to year.

   ƒ   CDE did not review the reported data for reliability. Neither supervisory nor other staff
       reviewed the data on Table C-1 before CDE submitted its Consolidated State
       Performance Report for school year 1999-2000. Also, CDE staff did not compare the
       data with prior years’ reports or against independent sources to determine whether the
       reported data appeared reasonable or to identify possible anomalies. According to
       Standard Three (Editing) of ED’s Data Quality Standards, data should be clean which
       ED defines as the data being correct, internally consistent, and without mistakes. Checks
       to ensure this standard is met include: (1) a systematic review of the data by a person who
       did not prepare the report and is familiar with the data; (2) “eyeballing” of the data to see
       if they are reasonable given what is known about earlier years; and (3) discussions with
       the primary data providers about large changes or unusual findings to see if the anomalies
       might be due to editing errors. The absence of supervisory and analytical reviews
       increases the risk of reporting inaccurate performance data.

CDE needs to provide reliable and valid data so that ED can assess program results and fulfill its
requirements to present reliable annual performance information to Congress. In October 2001,
ED published its most recent annual report—State ESEA Title I Participation Information for
1998-99, Final Summary Report. The report included state-by-state data on the number and
percentage of Title I schools identified for improvement. If ED uses the data that CDE reported
for the school year 1999-2000 in its future reports to Congress, ED would incorrectly report that
16 percent (765 of 4,888) California schools were identified for improvement. Based on CDE’s
Control Number: ED-OIG/A09-B0019 	                                                       Page 4 of 7

Program Improvement Database, the percentage of California schools identified for
improvement was actually 26 percent (1,281 of 4,868 schools).


The Assistant Secretary for Elementary and Secondary Education should—

1.1. 	 Instruct CDE to report all Title I schools identified for improvement, including both
       newly and previously identified schools, in its Consolidated State Performance Report.

1.2. 	    Ensure that CDE retains documentation to support its development of the reported data.

1.3. 	    Ensure that CDE develops and implements written procedures for preparing the
          Consolidated State Performance Report, which include procedures for reconciling and
          reviewing the data prior to submitting the report to OESE. Reconciliation and review
          procedures should include supervisory review as well as an analytical review of the data
          across years and against independent sources—such as other databases or staff who are
          familiar with the data—to determine reasonableness and identify anomalies.

CDE’s Comments

CDE concurred with our findings and recommendations. CDE stated that it will report all Title I
schools identified for improvement and will maintain all supporting documentation for three
years. In addition, CDE plans to develop and implement procedures by February 15, 2002, for
preparing the Consolidated State Performance Report. A copy of CDE’s comments is included
as an attachment to this letter.

                                      OTHER MATTERS
During our review of Table C-1 of CDE’s Consolidated State Performance Report for school
year 1999-2000, we found reporting problems with two additional data elements and the
disclosure information. These problems did not affect the reported number of schools identified
for improvement, but they did affect other information that OESE includes in its Title I
Participation Database and may use to evaluate the Title I, Part A program.

Title I LEAs identified for improvement. CDE did not report the number of Title I LEAs
identified for improvement in its performance report for school year 1999-2000. We also noted
that CDE did not report this data in its report for school year 1996-1997. For school years
1997-1998 and 1998-1999, CDE consecutively reported the same data for the number of Title I
LEAs in total and the number of Title I LEAs identified for improvement.

Distinguished schools.4 CDE reported the number of schools eligible for State performance
awards rather than the number of schools that met Federal criteria for a distinguished school.

    In California, distinguished schools are called Title I Achieving Schools.
Control Number: ED-OIG/A09-B0019                                                       Page 5 of 7

Disclosure information. The reporting form for the Consolidated State Performance Report
instructs States to describe data quality issues in a section specifically designated for this
purpose. CDE used footnotes rather than the designated section. As a result, the data quality
issues were not entered into the Title I Participation Database and the data limitation may not be
properly disclosed in ED’s reports to Congress. Also, CDE did not disclose why it did not
provide the requested data on Title I LEAs identified for improvement and distinguished schools.

The Title I, Part A program was enacted under the ESEA, as amended by the Improving
America’s Schools Act of 1994, Public Law 103-382.5 The 1994 reauthorization of the ESEA
introduced standards-driven reform. Specifically, Title I services are to be linked to the same
State content and performance standards that are expected of all children, and aligned
assessments are to be used to measure students’ progress toward meeting these standards. In
addition, States must put in place a system of accountability designed to identify and assist
schools that do not make adequate progress towards meeting the standards. LEAs must annually
review the progress of each Title I school to determine whether the school is making adequate
yearly progress. Schools that do not make adequate progress for two consecutive years are to be
identified for improvement. LEAs are to provide technical and other assistance to schools
identified for improvement and must take corrective actions in schools that continue to be low
performing for three additional years after identification. In the same manner that LEAs review
the progress of schools, States are to annually review the progress of LEAs. LEAs that do not
meet performance targets for two consecutive years are identified for improvement. States must
take corrective action in LEAs that continue to be low performing for four years after being
identified for improvement.

In California, CDE is responsible for implementing the statewide accountability system and
administering the Title I, Part A program. For school year 1999-2000, California’s Title I
allocation was about $940 million. At the time of our review, California was continuing to phase
in its accountability system to conform with Title I accountability guidelines. For school year
1999-2000, CDE used the results of students’ Stanford-9 test to determine whether public
schools made adequate yearly progress. CDE uses an internal system, called the Program
Improvement Database, to compile data on Title I schools’ progress and, if applicable, data on
when the schools were identified for improvement and when schools exited improvement status.
From this database, CDE annually identifies and notifies the LEAs of their schools that were
identified for improvement.

In March 2000, ED published its Data Quality Standards as an appendix to its 1999
Performance Reports and 2001 Plans.6 For 1999-2000, ED had six data quality standards in

    ESEA was reauthorized by the No Child Left Behind Act of 2001 on January 8, 2002.
  Subsequent to the publication of the 1999 Performance Reports and 2001 [Annual] Plans in
March 2000, ED revised the Data Quality Standards by increasing the number of standards from
six to eight. In March 2001, ED published the revised standards as Draft Data Quality
Standards in its 2000 Performance Report and 2002 Annual Plans. For the purposes of this
audit, we used the March 2000 standards that were in effect during our audit period.
Control Number: ED-OIG/A09-B0019                                                       Page 6 of 7

place: (1) Validity—data adequately represent performance; (2) Accurate Description—
definitions and counts are correct; (3) Editing—data are clean; (4) Calculation—the math is
right; (5) Timeliness—data are recent; and (6) Reporting—full disclosure is made. For each
standard, ED provided a definition, examples of conditions that meet or fail to meet the standard,
and a Data Quality Checklist for use by primary data providers and secondary data managers.

As part of our review of CDE’s management controls over performance data used to identify
schools for improvement, we examined CDE’s procedures for preparing its performance report
to OESE. The purpose of this segment of the audit was to determine whether CDE reported
reliable data on the number of Title I schools identified for improvement. Our examination
covered the data that CDE reported in its Consolidated State Performance Report for school year
1999-2000. We expanded our analysis of the data to school years 1996-1997 through
1998-1999. We will issue a separate report on CDE’s management controls for ensuring the
quality of the performance data used to identify schools for improvement, after we have
completed the remainder of our review.7

To accomplish our objective, we interviewed State officials and staff responsible for collecting
data used to report the number of schools identified for improvement to OESE. We confirmed
that the data CDE had reported to OESE over the last four years were recorded in the Title I
Participation Database. We also compared the data CDE had reported to OESE with the data in
CDE’s Program Improvement Database. In addition, we interviewed program and contractor
officials from OESE and ED’s Planning and Evaluation Service within the Office of the
Undersecretary about their definition for the data requested in the Federal performance report
related to schools and LEAs identified for improvement.

We relied on computerized records in CDE’s Program Improvement Database to determine the
number of schools identified for improvement, but we did not assess the reliability of these
records for this segment of the audit. We will assess the data reliability of the Program
Improvement Database as we continue the audit of CDE’s management controls over the
performance data.

We performed our fieldwork at CDE offices in Sacramento, California, from July to September
2001. We held an exit briefing with CDE officials on September 26, 2001. Our audit was
performed in accordance with generally accepted government auditing standards appropriate to
the scope of the review described.

 This audit was conducted as part of a joint project of the U.S. Comptroller General’s Domestic
Working Group to determine whether data used for the purpose of identifying Title I schools in
need of improvement are reliable, valid, and timely. The participants in the joint effort are the
ED-OIG, U.S. General Accounting Office, Texas State Auditor’s Office, Pennsylvania
Department of Auditor General, and Philadelphia City Controller’s Office.
                                                        :     ~·L.··


 We were mlab.1e toidenlify CnE's contrqlsuucture appUcable to re()olti.ng. the numbel'of
 schools identiftcd fodmprovement SillCCCDE did not h~we wnttenprocedures and failed to
 ret..l:ins·upportingdocumemation. In addition, CDE oft1cials could not providcL'l sufficient oral
 ~plana'ion. Qn howdnta on the number ofschools Jdenti fiedfor impl'ovemerlt were .c:o11 ected and
.~porfed. bi"iJl~¢Qnsplid~ted SUire PClio.rmal.icelfeJ19rr fotsRflOdl; mar.lQ?9~2QOO .
.Ba~d:'o:lfbiIT,nWi,ijw,wcC9nc~ud:cd thatG.QE;di'd'ltofha'Ye rilanagem~l(;(l:rtfr()ls .lo ;e:nsute lhl~
.reU~}tlitY::6(t~~,:llulllbero.f"sch®lsjdel1ti'fioo.fort~ntJrovemellt,th~tjiTe:portootQ.OB.SE; The
AUDIT RESt.fCts·sectiotJ CIt the'repor:t·pro\lJdys:d~tan~Qnourtlndj ng...

  St3tenlent~·thattli.lilla~ia]JlractiCe:s',need.iTn'provel'nen!~; •. as·,,\rcH':i.\s:o,therconclusious'and
  rocomme:ridail0nsin tbis report represerJ,t the,opi~jo,E~s:~dttlle,bftlce'o(l:nspector.Oenera1 .
.,ne,te:Jminatjons.qf coIitc:th:¢.~c:n9ntobiCJaJ.t~riWj,l1b~·~deby .lhe:~Lp'pr(lpriate,pep~rtme.llt··~f
      . . . .- :Ot]dalS.
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 ffyouhalie ahy addhiohalconimel1ts or:infoffilation that you believe mar have a bearing on the'
 resOlution -oftbisaudit, yon should send 'them directly to thetoHowing ED official, who will
 c011Sider them before taking final action onth¢·audit:

                                                Susan B. Neun1~n
                                                Assistant S-ccretary
                                                ()nlceofelem~ntary.and $ec.ondary Education
                                                U;S. pevlllftrhel)t :ofBducatipo
                                                :F~deratBliildirig'No.6:··            .
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:ri:is~luti'9·il'ofitit~its:~ytiiilba.ti#i'tin;i~~/~,~hoil:9~,lI16:lih(n~~"~~4 r~~ml'l1el)dat~91i~ ·c,o.#~a.}ied
. tH~r~it1. 11\~rerofe.
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···In accordrulce.1Nith:.tIi~::Frced4)m,:9nni9nF<)~&,ll,· A4t'(S :t~tS;C:'§;~)~)~:(epoM~::i$$~ltQ EDls
.:grail~,ee8~arid~ontiac,~tsaL:etna.9~~EYJiJal:tJ~~lf iYqubSlk:qt to~m~lTlb¢f.;Jptfue .pre,ss and ;.general
public to th~C:.Xlci3l inf<>,rm~~i9f1:#phtafnetl:lli~tet~i isnot.$~bjed)o'excwpH~ni under,the} Act

                                                                                  A, Cmte'r
                                                                       Assistant Inspeclor .deneralfor AmHt

                                IYELA t is'E'~A~T t:'i 

                                :::Ia',:~, S:.II~~ijr,"1r;ti:l. ~(!'~:II.:' ltP:lr~h·:::..,:r' 

 Decembc:r 28,2001

.Gkiria Fikluf
:'RegiQri."al J:Il$cpe.ctbr~Gene{~lJot Audi [
U.S; ,l)tp~.rtmeJ\t ofEUi.tcation
,Offlce'o{ mspc(;:(or:qencri:),."
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Thank you i:[;.rth~ opporttiniry f&or:CY,ic'~",-, and~i)ml'Mnt,~n you:F oraft\:ltJ{fir ,~pcii1:afth~ C~ii1oT1lia
De'p<1t1l)lent ;ofEdl1:¢tltion'$(CDE)c(Hnp~ r3hc,~ ~;ltth F:cd'~ral maci.;;tgementcchtrclso,\/8r reporting
ofT:th~i petfolmancedat<l (Audit No.A69-BOOl9);·                                                       .

Ade[;:li~edi'eporrof th:e action taken m implemelll,eadl of your ~u.ldj~.reC:brrim~:hd3Gc·ns is
·endo!i¢(t rfy(.lu h;1ve ariy que:s.tionsabout th~~c{:'rrecti VO!;<:!Cd.OfL taken .by the C[)E Ot the
iiif~mlaqOpln. o'JI n::sptJnse,p~ea.!ie co!'! tact the:CDE's Audi L Re~p'(mseCoordinit()r ,Gleim
O:Stnf..ec~,it (916}322~l288,                                    .                  ,              ..

 th ii:.fDeputy $uperinmnden t .ofiu15ti 9:In.Sl,ructio!)

cc; 	        Lc:sii~,F'auss.~l~Chi~tq·~p1i:W::$UPi:l~Iht~'A9C~ffcii·P:Qliby PiHdPrdWrlpHt:
             J&1mleMer.9()i~i D~lity 'Sup,bH ritemi,ent,: Curridi]lrni·a~_d.1it5trticdo:rial. Leackrship
             Br~l1ch  .'     .      ........                    ,'"   ". '.                ,

             Hanna Vhdkcr. Director. Spcclati7.:ed PJ'ogramst)iv!siol1

                       CALIFO R ~IA DEJ'ARTMEl>'T OF EDUCATlO N

                AC"T I O ~'   TAKEN TO N PLE,\iEl'-'T         RECOM ),1 EK D A ll O ~S 


                                                 ol    -; 

c.n omj. 1500nmenl ofE(i "o,,;oo (CPl') !! I'""",,,,, The CDE ",iii ",mplot< Ih,
C.,.,,,,Mated Performarn;c R"1"'n bv the d,,. ","" _ Th ;, repo' t will ",el ude ,II Title I
>ehools id"",,;;«j fo' Prog..-am ImproYOTlCTII in . 1I 5 cohon. ( 1'1'97-0 1). The reporl will
.Iso i:;:;, ude 'he 10lal   """,b<, wi[h •   """ '''''t of ",bool wide and "'gC1oo "',,"nOe.
Il«ommmd.. iQ" 1.2_En. uco to" en,; ret.i., doc" mcnf''';''" ,,, "" 'r"" ;"
<I<>'olopm, " ' of tho « po , oroi d." .

CDE R",pO" '" All documCIl"" OIl to ,-upp<jn 'ho "l¢n,i!;COlion ofTh l, I Program
ImprovCIrlC"' school, \>,,11be ",,,,,'>toed for . t 10"" 'Orce ycm.

CDF. Respo"<o' By Fcbru'I)' II, 2ool. CDE ,"';11 w.. elop o" d implement procOOl'Td lix
jlf '~"g th< Co"">lid",,,,' S,,,,,, p"jo, ,,,once Rqxm.
                             REPORT DISTRIBUTION LIST

                            CONTROL NO. ED-OIG/A09-B0019 

Auditee                                              ED Action Official
 Delaine Eastin                                       Susan B. Neuman, Assistant Secretary
 State Superintendent of Public Instruction           Office of Elementary and Secondary Education
 California Department of Education
 721 Capitol Mall
 Sacramento, California 95814

                          Other ED Officials/Staff (electronic copy)
 Audit Liaison Officer 
                                   Assistant General Counsel
 Office of Elementary and Secondary Education 
            Office of the General Counsel

 Director, Compensatory Education Programs 
                    Deputy Secretary
 Office of Elementary and Secondary Education 
                 Office of the Deputy Secretary

 Assistant Secretary 
                                          Chief of Staff
 Office of Legislation and Congressional Affairs 
              Office of the Secretary

 Assistant Secretary                                            Under Secretary
 Office of Intergovernmental and Interagency Affairs            Office of the Under Secretary

 Director                                                       Director
 Financial Improvement and Post Audit Operations                Office of Public Affairs
 Office of the Chief Financial Officer

 Post Audit Group Supervisor                                    Press Secretary
 Financial Improvement and Post Audit Operations                Office of Public Affairs
 Office of the Chief Financial Officer

 Indirect Cost Group Supervisor                                 Correspondence Control
 Financial Improvement and Post Audit Operations                Office of General Counsel
 Office of the Chief Financial Officer


 Sacramento City Unified School District